Sub-processor List

Effective Date: October 15, 2026
Last Updated: October 15, 2026
Document Version: 1.1
Company: Smartplace Pty Ltd, trading as Smartta AI

About This Document

This document lists all sub-processors engaged by Smartplace Pty Ltd, trading as Smartta AI to provide services in connection with our workforce management platform. As required by data protection laws including GDPR, CCPA, and the Australian Privacy Act, we maintain this comprehensive list to ensure transparency about data processing activities.

We review providers at least yearly; those handling personal data must protect it under written terms.

1. Sub-processor Categories

Our sub-processors are categorized based on their role in our service delivery:

2. Current Sub-processor List

Last Reviewed: October 9, 2026

Service Provider Service Description Data Processing Purpose Data Location Status Added Date
Essential Services
Amazon Web Services (AWS)
Amazon.com, Inc.
Seattle, WA, USA
Cloud infrastructure, computing, storage, and networking services All application data storage, processing, and hosting services Sydney, Australia
(ap-southeast-2)
Active 2023-01-01
Auth0 by Okta
Okta, Inc.
San Francisco, CA, USA
Identity and access management, user authentication User authentication, session management, identity verification Australia & United States Active 2023-02-15
Cloudflare
Cloudflare, Inc.
San Francisco, CA, USA
Bot check (Cloudflare Turnstile) on sign-in Checks that a sign-in attempt comes from a person, using signals from the visitor's browser. No platform traffic is proxied through Cloudflare and no customer records are sent to it. Global network Active 2023-01-15
SendGrid by Twilio
Twilio Inc.
San Francisco, CA, USA
Transactional email delivery and management User notifications, system alerts, transactional communications United States
(Global delivery)
Active 2023-03-01
Twilio SMS
Twilio Inc.
San Francisco, CA, USA
SMS delivery and two-factor authentication Security notifications, 2FA codes, system alerts Global with Australian local numbers Active 2023-03-01
AI Services
Anthropic (Claude)
Anthropic, PBC
San Francisco, CA, USA
AI model processing for the platform's AI features Prompts sent by AI features, which may include customer workforce data United States Active 2026-10-15
OpenAI
OpenAI OpCo, LLC
San Francisco, CA, USA
AI model processing for the platform's AI features Prompts sent by AI features, which may include customer workforce data United States Active 2026-10-15
Google (Gemini)
Google LLC
Mountain View, CA, USA
AI model processing for the platform's AI features Prompts sent by AI features, which may include customer workforce data United States Active 2026-10-15
Delivery & Integration Partners
NoahFace
NoahFace Pty Ltd
Sydney, NSW, Australia
Facial recognition time and attendance hardware and software Employee clock-in/out via facial recognition, time and attendance data processing Australia Active 2025-09-01
Infrastructure Services
Database and caching services are locally hosted on Smartta AI infrastructure - no database sub-processors are engaged.
Analytics & Monitoring
Analytics and monitoring services are locally hosted on Smartta AI infrastructure - no monitoring sub-processors are engaged.
Security & Payment Services
Stripe
Stripe, Inc.
San Francisco, CA, USA
Payment processing, subscription billing Payment transactions, billing information, financial records Global
(Stripe Payments Australia)
Active 2023-02-01
Xero
Xero Limited
Wellington, New Zealand
Accounting software integration Financial data synchronization, invoice processing Australia & New Zealand Active 2023-05-01
Development & Deployment
GitHub
GitHub, Inc.
San Francisco, CA, USA
Source code management, CI/CD, software development Development workflows, deployment logs (no customer data) United States Active 2023-01-01
Docker Hub
Docker, Inc.
Palo Alto, CA, USA
Container registry and image management Application deployment images (no customer data) United States Active 2023-01-01
Atlassian
Atlassian Pty Ltd
Sydney, NSW, Australia
Project management, issue tracking, team collaboration Development workflows, project metadata (no customer data) Australia Active 2025-09-01

Data Protection Safeguards

We review providers at least yearly; those handling personal data must protect it under written terms.

3. Data Transfer Mechanisms

For sub-processors located outside Australia:

4. Sub-processor Management Process

4.1 Provider Review

We review providers at least yearly; those handling personal data must protect it under written terms.

Change Management

Customer Notification: We notify customers by email at least 30 days before a new sub-processor begins processing personal data, as set out in our Data Processing Agreement.

Objection Rights: Customers may object to a new sub-processor within 30 days of the notice. If an objection cannot be resolved, the customer may terminate the affected services without penalty.

5. Removed Sub-processors

The following table shows sub-processors that have been discontinued:

Service Provider Service Description Removal Date Reason Data Handling Replacement
No sub-processors have been removed to date.

6. Regional Compliance

6.1 GDPR (EU and UK)

6.2 CCPA/CPRA (California)

6.3 Australian Privacy Act

Questions and Updates

For questions about our sub-processors or to request updates:

  • Privacy Team: privacy@smartplace.ai
  • Data Protection Officer: dpo@smartplace.ai
  • Security Team: security@smartplace.ai
  • Legal Team: legal@smartplace.ai

This list is updated before a new sub-processor is engaged, as set out in our Data Processing Agreement.

7. Related Documents

Smartplace Pty Ltd (ACN 639 781 678), trading as Smartta AI
C/- Margetson & Associates, Unit 21, 598-602 Forest Road, Penshurst, NSW 2222, Australia
Sub-processor list maintained for transparency and regulatory compliance