Joqiva Subprocessors

Third-party providers that Joqiva uses to process Customer Personal Data where Joqiva acts as processor.

Effective date: 24 Feb 2026 | Last updated: 12 October 2026

Introduction

This Subprocessors page identifies third-party providers that Joqiva uses to process Customer Personal Data on behalf of Joqiva customers where Joqiva acts as processor. This page forms part of the Joqiva Data Processing Agreement available. Providers listed as approved subprocessors are approved only for the processing functions described on this page. Other providers used for Joqiva's own controller-side business operations may be described in the Privacy Policy, Cookie Policy, Refund Policy, Partner Terms or other relevant notices.

1. Who we are

Joqiva is operated by FOP Mykola Marchuk Mykolaiovych, an individual entrepreneur registered in Ukraine, trading as Joqiva. Joqiva's current legal entity details, trading name, website, country of establishment, registered business address, correspondence address, registration information, UK VAT status, contact details, privacy contact and UK/EU representative information are maintained in the Legal Notice.

2. Scope of this page

This page applies to third-party providers that process Customer Personal Data for Joqiva where Joqiva acts as processor under the Joqiva DPA. Customer Personal Data means personal data contained in customer, enquiry, job, quote, invoice, file, email, payment report, reminder, audit log, document, workspace and related operational data that Joqiva processes on behalf of a Joqiva customer. This page does not list every provider used only for Joqiva's own internal business administration where that provider does not process Customer Personal Data as a subprocessor. This page also does not list providers that act only as independent controllers for their own services, unless Joqiva includes them for transparency. Where a provider processes Customer Personal Data as a subprocessor, Joqiva lists the provider on this page with its processing function, data categories, relevant location categories and transfer information.

3. Controller and processor model

For Customer Personal Data: (a) the Joqiva customer is normally the controller; (b) Joqiva is normally the processor; and (c) the providers listed in the "Approved subprocessors" section may act as subprocessors. For account registration, subscription billing, support, security, website operation, service administration, legal compliance, internal product analytics, service analytics and Joqiva's own business operations, Joqiva may act as an independent controller. Those controller processing activities are explained in the Joqiva Privacy Policy.

4. Important payment clarification

Joqiva does not process, collect, hold, transfer, settle, control or transmit money owed by End Customers to Joqiva customers. End Customers pay directly into the Joqiva customer's bank account by bank transfer. Joqiva does not initiate bank transfers, access payment accounts, or instruct banks or payment institutions to move End Customer funds. Joqiva may display bank transfer instructions, allow End Customers to indicate that they have paid, record payment reports, record owner confirmation, show overdue invoice status and send reminders. Joqiva does not use a payment processor for End Customer invoice payments. Any subscription billing provider used by Joqiva is only for Joqiva subscription fees payable by Joqiva customers to Joqiva. Subscription billing must not be mixed with End Customer invoice payment tracking.

5. Joqiva access locations

Joqiva provides a business workflow SaaS service. Customer Personal Data may be accessed by authorised Joqiva personnel or contractors from Joqiva operating locations, the United Kingdom and other locations described in the DPA for the purposes of providing, securing, supporting and maintaining the Service. Joqiva itself is not a subprocessor of its customers. This section is included for transparency because access to Customer Personal Data from outside the United Kingdom may be treated as an international transfer under applicable data protection law. Where required, international transfers involving Joqiva are addressed in the Joqiva DPA. Valid transfer mechanisms may include adequacy arrangements, UK transfer terms, standard contractual clauses, an applicable exception, or another lawful transfer mechanism available under applicable data protection law. Transfer risk assessments, data protection tests and supplementary measures may be used to support or assess a transfer mechanism where required, but they are not standalone transfer mechanisms.

6. Approved subprocessors

The subprocessors below are approved for the listed purposes where Joqiva has an applicable vendor agreement, data processing agreement or equivalent data protection terms in place. A provider is not approved to process Customer Personal Data as a subprocessor unless it is listed in this section or added in accordance with section 12 of the DPA. 6.1 Supabase Provider: Supabase, Inc., or the applicable Supabase contracting entity under Joqiva's vendor terms. Service: Core platform services for account access, workspace records, files, permissions and related Service operation. Purpose of processing: Supabase is used to support core Service operation, including account access, workspace records, files, access controls, audit-related records and related operational functionality. Types of Customer Personal Data processed: Supabase may process Customer Personal Data stored or generated in Joqiva workspaces, including: (a) workspace user and access information; (b) customer and End Customer names; (c) customer and End Customer contact details; (d) enquiry, job, quote and invoice data; (e) invoice items and quote items; (f) quote acceptance and decline records; (g) payment workflow records and payment reports; (h) bank transfer instructions provided by the Joqiva customer; (i) files, PDFs and attachments; (j) payment evidence or payment proof files; (k) inbound email records linked to workspace data; (l) audit logs; (m) access logs and technical metadata; (n) integration and operational event records where stored in the platform; and (o) other Customer Personal Data submitted to or generated in the Service. Location of processing: Primary service region: United Kingdom. Support, security and operational processing may occur in other provider locations, including locations outside the United Kingdom, as described in Supabase's applicable terms and subprocessor information. Transfer safeguards: Supabase data processing terms or equivalent contractual terms, together with applicable transfer mechanisms such as adequacy arrangements, UK transfer terms, standard contractual clauses or another lawful transfer mechanism where required. Status: Approved core platform provider. 6.2 Twilio SendGrid Provider: Twilio Inc. (Twilio SendGrid services). Service: Service email delivery, inbound email processing, email event processing and related communications services. Purpose of processing: Twilio SendGrid is used to send service emails, workspace invitation emails, quote emails, invoice emails, reminders and account-related emails, and to process delivery events, bounces and related email metadata. Where Joqiva enables inbound email processing, Twilio SendGrid may also process inbound email content and attachments. The email delivery purpose also includes the consent-based Next Service Due invitations enabled under clause 13A of the Terms, their refusal facilities and the associated delivery events. Reminder consent evidence remains in Joqiva's controlled records; it is not routinely placed in email custom arguments or delivered as message content. For the delivery performed on Joqiva's instructions, SendGrid acts within the processing chain described in the DPA. Twilio's applicable contractual terms also identify certain operations in which Twilio acts as an independent controller. Those operations are assessed separately; describing the delivery service as a subprocessor does not change its role for a different processing purpose. The transfer mechanism must match the contracting entity, data, destination and applicable onward-transfer obligations. A reference to the Data Privacy Framework is used only where the relevant recipient and transfer are covered by an active applicable participation. SendGrid is not covered by Twilio's BCR Services definition. Appropriate contractual safeguards and any required transfer assessment apply where adequacy does not cover the transfer. Email delivery is handled through Twilio SendGrid. SMS delivery is handled through Twilio where SMS delivery is enabled. Types of Customer Personal Data processed: Twilio SendGrid may process Customer Personal Data contained in or related to emails, including: (a) sender and recipient names; (b) sender and recipient email addresses; (c) email subject lines; (d) email body content; (e) inbound email content; (f) email attachments; (g) quote or invoice links; (h) customer-facing page links; (i) reminder content; (j) delivery events; (k) bounce events; (l) open and click events where configured and lawful; (m) IP addresses; (n) timestamps; (o) message identifiers; and (p) related technical metadata. Open and click tracking: Open and click tracking is disabled in Joqiva's current configuration, and Joqiva's deployed-environment configuration rejects these tracking flags. If Joqiva later changes the Service to enable open tracking, click tracking or similar email tracking, Joqiva will first update the relevant technical controls and assess and implement applicable privacy, PECR, consent and disclosure requirements. Location of processing: SendGrid-related processing may take place in the United States, European Union and other North American provider locations. Twilio's current subprocessor list identifies Amazon Web Services for SendGrid processing in the United States and European Union, DataBank/Lumen for SendGrid processing in North America, and Digital Realty for SendGrid processing in North America and the European Union. Joqiva's current SendGrid account is not represented as an EU Data Resident Subuser. Joqiva therefore does not claim that Next Service Due email is processed only in the European Union. Transfer safeguards: For an in-scope transfer to Twilio Inc. in the United States, Joqiva relies first on Twilio Inc.'s active participation in the UK Extension to the EU-US Data Privacy Framework for covered non-HR data. The recipient, active status, UK Extension and covered data type are checked against the official participant list. If that adequacy route does not cover a transfer, the UK IDTA provisions in the Twilio DPA and a current data protection test are required before the transfer proceeds. SendGrid is not covered by Twilio's BCR Services definition, and Joqiva does not rely on those BCRs for SendGrid. The Joqiva operator is established in Ukraine. Under Twilio's published regional contracting allocation, and in the absence of a superseding signed order form, the applicable provider entity for this configuration is Twilio Inc. Status: Active email communications provider. 6.3 Twilio Provider: Twilio Inc. Service: SMS communications and UK telephone-number/SIP connectivity provider. Purpose of processing: Where service SMS is available and enabled, Twilio is used to send quote and invoice delivery or resend messages, quote follow-ups, invoice reminders, visit reminders and visit-date-change notifications, and to process related delivery and segment information. Manual service SMS includes user-selected quote delivery or resend, invoice delivery or resend, invoice reminders and visit reminders. Automatic service SMS includes scheduled quote follow-ups, scheduled invoice reminders, scheduled visit reminders and visit-date-change notifications triggered after a workspace user changes the visit date. Where Joqiva Receptionist is enabled, Twilio Elastic SIP Trunking is also used to provision or hold an eligible UK business phone number, receive inbound PSTN calls, route them securely to the selected conversational voice provider, support configured transfers and provide call duration, routing, delivery and cost records. Recording at the Twilio trunk is disabled unless Joqiva expressly configures and documents a different recording path. Twilio is not used for Joqiva SaaS subscription billing or End Customer invoice payments. Types of Customer Personal Data processed: Twilio may process Customer Personal Data needed to deliver and track SMS messages, including: (a) recipient phone number; (b) SMS message content, including the workspace sender label, quote or invoice reference, visit date or date-change text, reminder or quote-expiry wording, one-way "Do not reply" wording and a secure customer-facing short link; (c) message purpose and template information; (d) provider message and messaging-service identifiers; (e) SMS acceptance, delivery, failure and error status metadata; (f) timestamps; (g) estimated or actual segment count, encoding and provider price or currency information where returned; and (h) related technical metadata required to send, track and reconcile the message; (i) caller and business phone numbers for Receptionist calls; (j) SIP call identifiers, routing, status, timestamps and duration; (k) transfer and failure metadata; and (l) telephony usage and cost records. SMS delivery: SMS delivery is an attempted communication and may generate delivery status, error, segment and provider cost information. Joqiva does not promise that every SMS will be delivered. Joqiva service SMS templates are one-way and state "Do not reply". Joqiva does not currently provide an in-product inbound SMS reply or STOP-command workflow. Recipient opt-out records are applied within Joqiva before a number is selected for an eligible manual or automatic send. Preferred-channel records remain in Joqiva as workflow preferences; neither type of preference record is sent to Twilio as message content. The Joqiva customer is responsible for ensuring that each recipient phone number belongs to the intended recipient and is accurate and current, that each service message is lawful under applicable data protection and electronic communications law and supported by any required notice, consent or other permission, and that recipient opt-outs and channel preferences are recorded and honoured promptly. The Joqiva customer must not re-enable a recipient for service SMS without an appropriate request or other lawful authority. Availability: The Twilio SMS integration is used only where SMS is supported by the applicable plan and entitlements, the provider and runtime configuration is complete, SMS and any relevant automation are enabled for the workspace, the recipient has an eligible SMS-capable number and has not opted out, and segment allowance and rate limits permit the send. Voice connectivity is used only where Receptionist is entitled, activated and configured for the workspace. Voice processing region and storage depend on the production Twilio regional configuration. Joqiva must verify the selected region and applicable transfer safeguards before activation and does not claim a UK-only or EU-only configuration unless that exact runtime configuration has been confirmed. Location of processing: Provider locations used for communications, support, security or operational services, including locations outside the United Kingdom. Transfer safeguards: Twilio data processing terms or equivalent contractual terms, together with applicable transfer mechanisms such as adequacy arrangements, UK transfer terms, standard contractual clauses, approved certification or another lawful transfer mechanism where required. Status: Approved communications provider used for configured service SMS and Receptionist telephony connectivity. 6.3A Retell AI Provider: Retell AI, Inc. Service: Conversational voice runtime for Joqiva Receptionist. Purpose of processing: Where Receptionist is enabled, Retell processes live call audio to conduct the configured conversation, generate speech and transcripts, call Joqiva's allowlisted tools, return structured outcomes, support configured transfers and provide call, recording, transcript and usage information needed for the Joqiva workflow. Types of Customer Personal Data processed: Retell may process caller and business phone numbers; live voice audio; caller names and contact details provided during the call; transcripts and summaries; call time, duration, routing and status; service, address, urgency, visit-request and message details; limited matched customer or job context supplied for the call; tool request and result data; transfer status; and related technical, safety, usage and cost metadata. Storage and retention: Joqiva configures provider storage and retention to be no longer than the workspace Receptionist retention setting. Recording is a separate workspace choice and is off by default in Joqiva. Provider recording and transcript artifacts are deleted through Joqiva's retention and erasure workflows. The provider's published controls currently include storage minimisation and configurable retention, but the exact production setting must be verified before a workspace is activated. Human control: Retell is not given direct database access. Joqiva validates and scopes every business tool. A caller or model statement cannot by itself create a final Job, promise availability or price, confirm payment, access another workspace or mark a transfer successful. Location and transfers: Retell AI is based in the United States and states that personal information is primarily stored and processed in the United States and may be processed in other provider locations. A signed data processing addendum and applicable UK transfer safeguards must cover production processing. Joqiva does not claim UK-only or EU-only voice processing. Provider dependencies: Retell may use the subprocessors identified in its current Trust Center for speech recognition, language, voice generation, hosting, security and support. Joqiva must re-check that list and the production agent configuration before activation because available upstream providers can change. Status: Selected Receptionist conversational voice provider. Production activation remains conditional on verified provider configuration, contractual safeguards, storage/retention settings and operational acceptance. 6.4 OpenAI Provider: OpenAI OpCo, LLC. Service: AI-assisted processing provider. Purpose of processing: OpenAI may be used to provide AI-assisted enquiry extraction and AI-assisted extraction of customer and contact details from text manually submitted by a Joqiva user. AI-assisted features may help extract, classify, summarise or prepare fields from submitted email or message text and manually pasted enquiry, customer or contact text. AI-assisted output requires user review. It does not create final jobs, final quotes, final invoices, final customer communications or final business decisions automatically. Types of Customer Personal Data processed: OpenAI may process Customer Personal Data submitted for AI-assisted processing, including: (a) submitted email or message body text; (b) manually pasted enquiry, customer or contact text; (c) customer display names and legal names; (d) business names, company numbers and VAT numbers; (e) contact names and role titles; (f) email addresses and phone numbers; (g) billing, service, registered or other submitted address details; (h) enquiry details, service requirements and job descriptions; (i) notes submitted by Joqiva users; (j) limited attachment metadata, such as content type, size and scan or validation status, where an inbound email contains attachments; (k) extracted fields and AI-assisted output; (l) timestamps; and (m) related technical metadata. The current AI-assisted extraction implementation does not send attachment file contents to OpenAI. Training and model improvement: OpenAI states that data submitted to its API is not used to train or improve general models by default unless the customer expressly opts in. Joqiva does not authorise an optional training or model-improvement opt-in for Customer Personal Data submitted through Joqiva unless Joqiva expressly states otherwise, has a lawful basis and obtains any required authorisation. Retention: Joqiva's current AI extraction implementation uses the OpenAI Responses API with provider application-state storage disabled for each request through store=false. It does not use provider-hosted Conversations, Assistants, Threads, Files or Vector Stores for this extraction flow. Separately, OpenAI may retain safety and abuse-monitoring records containing submitted content, generated output or related metadata for up to 30 days under its standard API data controls, unless a more restrictive approved retention control applies. OpenAI may retain data for longer where legally required. Joqiva does not claim that Zero Data Retention or Modified Abuse Monitoring applies unless that control is enabled for the relevant provider organisation or project. Joqiva configures AI-assisted processing to minimise unnecessary retention and avoids storing AI provider responses as Joqiva business records where they are not needed. Joqiva's own 30-day raw-content cleanup is separate from OpenAI's provider-side retention and is described in the Privacy Policy, DPA and AI Processing Notice. Location of processing: Provider locations used for AI-assisted processing, support, security or operational services, including locations outside the United Kingdom, unless a specific data residency arrangement applies. Transfer safeguards: OpenAI data processing terms, standard contractual clauses, UK transfer terms or another lawful transfer mechanism where required. Status: Approved AI service provider for AI-assisted enquiry and customer-detail extraction where the feature is enabled. 6.5 Vercel Provider: Vercel Inc., or the applicable Vercel contracting entity under Joqiva's vendor terms. Service: Web application delivery and related platform services. Purpose of processing: Vercel may be used to deliver Joqiva web application and customer-facing pages and to support related request handling, operational logging and service diagnostics. Types of Customer Personal Data processed: Vercel may process limited Customer Personal Data and service metadata where it appears in service requests, logs or diagnostics, including: (a) IP addresses; (b) browser and device information; (c) page and request metadata; (d) customer-facing page access metadata; (e) account or workspace identifiers where included in application requests; (f) error and diagnostic metadata; and (g) other Customer Personal Data necessarily transmitted while providing the service. Location of processing: Provider locations used for service delivery, support, security and operational services, including locations outside the United Kingdom. Transfer safeguards: Vercel data processing terms or equivalent contractual terms, together with applicable transfer mechanisms such as adequacy arrangements, UK transfer terms, standard contractual clauses or another lawful transfer mechanism where required. Status: Approved web application delivery provider. 6.6 DigitalOcean Provider: DigitalOcean, LLC, or the applicable DigitalOcean contracting entity under Joqiva's vendor terms. Service: Application operation and related platform services. Purpose of processing: DigitalOcean may be used to provide and operate Joqiva application services and related operational functions required to provide, secure and maintain the Service. Types of Customer Personal Data processed: DigitalOcean may process Customer Personal Data transmitted through or stored temporarily by hosted Joqiva services, including: (a) account and workspace request metadata; (b) customer and End Customer names and contact details where processed through application services; (c) enquiry, job, quote and invoice data where processed through application services; (d) files, PDFs, email content, attachments and payment proof data where processed through application services; (e) logs, events and operational metadata; and (f) other Customer Personal Data necessary for Service operation. Location of processing: Provider locations used for service delivery, support, security and operational services, including locations outside the United Kingdom. Transfer safeguards: DigitalOcean data processing terms or equivalent contractual terms, together with applicable transfer mechanisms such as adequacy arrangements, UK transfer terms, standard contractual clauses or another lawful transfer mechanism where required. Status: Approved application services provider. 6.7 Cloudflare Provider: Cloudflare, Inc., or the applicable Cloudflare contracting entity under Joqiva's vendor terms. Service: Traffic delivery, security and abuse-prevention services. Purpose of processing: Cloudflare may be used to deliver and protect Joqiva services through traffic management, security checks, abuse and bot prevention, and related availability and reliability functions. Types of Customer Personal Data processed: Cloudflare may process limited Customer Personal Data and request metadata, including: (a) IP addresses; (b) request and access metadata; (c) browser and device information; (d) security and abuse-prevention signals; (e) customer-facing page access metadata; and (f) other data necessarily transmitted while the provider protects and delivers the Service. Location of processing: Provider service delivery, security, support and operational locations, including locations outside the United Kingdom. Transfer safeguards: Cloudflare data processing terms or equivalent contractual terms, together with applicable transfer mechanisms such as adequacy arrangements, UK transfer terms, standard contractual clauses or another lawful transfer mechanism where required. Status: Approved traffic delivery and security provider. 6.8 Sentry Provider: Functional Software, Inc. dba Sentry, or the applicable Sentry contracting entity under Joqiva's vendor terms. Service: Service monitoring, reliability diagnostics and issue investigation. Purpose of processing: Sentry may be used to identify, diagnose, investigate and resolve application errors, reliability issues and security-relevant operational incidents. Types of Customer Personal Data processed: Sentry may process limited diagnostic data where it appears in error events or performance traces, including: (a) IP addresses where collected; (b) browser, device and runtime information; (c) service request metadata; (d) user, account or workspace identifiers where configured; (e) error messages and diagnostic context; and (f) limited Customer Personal Data accidentally included in error context despite Joqiva's minimisation controls. Location of processing: Provider locations used for monitoring, support, security and operational services, including locations outside the United Kingdom. Transfer safeguards: Sentry data processing terms or equivalent contractual terms, together with applicable transfer mechanisms such as adequacy arrangements, UK transfer terms, standard contractual clauses or another lawful transfer mechanism where required. Status: Approved service monitoring and diagnostics provider. 6.9 Ideal Postcodes Provider: IDDQD Limited, trading as Ideal Postcodes. Service: Address lookup and postcode search services. Purpose of processing: Ideal Postcodes is used to provide address lookup, postcode search, address selection and related address-normalisation functionality. Types of Customer Personal Data processed: Ideal Postcodes may process address lookup data, including: (a) postcode or address search text; (b) address fragments entered by Joqiva users; (c) a provider address identifier used to resolve a selected result; (d) address results returned by the provider; (e) request origin, referring application information and request metadata; and (f) related provider and technical metadata. Location of processing: United Kingdom and any other support, security, infrastructure or operational locations identified in IDDQD Limited's applicable terms and subprocessor information. Transfer safeguards: IDDQD Limited's applicable data processing terms. If the service involves a restricted transfer outside the United Kingdom, Joqiva will rely only on a transfer mechanism incorporated into the applicable contractual terms or otherwise lawfully put in place for that transfer. Status: Active address lookup provider.

7. Article 27 representatives

Joqiva has appointed Euverify Ltd (UK) and Euverify Ltd (Ireland) as UK and EU GDPR Article 27 representatives. These representatives act as contact points for UK/EU GDPR matters and data protection requests where applicable. They are not Joqiva's data protection officer, controller, processor, subprocessor, UK branch, EU branch, registered office or establishment. Provider: Euverify Ltd (UK) Purpose: UK GDPR Article 27 representative and secure GDPR request portal. Location: United Kingdom Provider: Euverify Ltd (Ireland) Purpose: EU GDPR Article 27 representative for EEA individuals where EU GDPR applies and secure GDPR request portal. Location: Ireland Contact: gdpr@euverify.com Portal: https://gdpr.euverify.com/verify/280fd1c9-68eb-438f-a2cd-92302bb9129e

8. Other transparency providers that are not normally DPA subprocessors

8.1 Analytics provider Provider: PostHog, Inc. Service: PostHog Cloud EU, reached by the current web integration through Joqiva's first-party analytics ingestion endpoint at e.joqiva.co.uk. The provider interface is hosted at eu.posthog.com. Purpose: Limited website and product analytics for Joqiva's own service-improvement purposes, as described in the Privacy Policy and Cookie Policy. Analytics processing is normally controller-side Joqiva processing unless Joqiva expressly states that the provider processes Customer Personal Data as a subprocessor. Modes and identifiers: With analytics-storage consent, Joqiva sends personless events that may contain pseudonymous PostHog distinct, browser-device, session and window identifiers persisted in analytics cookies or browser storage. After analytics storage is rejected, Joqiva may send limited personless cookieless events without cookies, localStorage, sessionStorage or a persistent browser identifier; PostHog may derive a privacy-preserving server-side hash and process limited request metadata. Personless means that no PostHog personal profile is created, not that every event is fully anonymous. Data minimisation: The current integration disables autocapture, session replay, heatmaps, personal profiles, automatic page views, performance capture and automatic exception capture. It sends only allowlisted event and property metadata. Joqiva does not intentionally send customer quote content, invoice content, payment proof content, bank details, payment instructions, AI source input or output, email bodies, customer names, customer email addresses, customer phone numbers, credentials, secrets or full URLs containing access information to PostHog. Status: Active controller-side analytics provider; not listed as a DPA subprocessor for Customer Personal Data. 8.2 Subscription billing provider Joqiva may use a billing provider or merchant of record to process Joqiva subscription fees, invoices, payment attempts, payment status, tax information, refunds and billing support information. Subscription billing is separate from End Customer invoice payments. Billing providers are not used for customer invoice bank-transfer payment tracking. Billing-provider processing is normally Joqiva controller-side processing, as described in the Privacy Policy and Refund Policy, unless Joqiva expressly states that the provider processes Customer Personal Data as a subprocessor. 8.3 Joqiva Partner Programme Joqiva currently uses its own systems only to receive and manually review applications from potential partners. Potential partner application processing is Joqiva controller-side processing, as described in the Privacy Policy. Active referral tracking, affiliate attribution, conversion validation, a commission ledger and a payout programme have not launched. Joqiva does not use an external affiliate network and no external affiliate network receives potential partner application data, Customer Personal Data, workspace data, document data, subscription billing data or payment data. Before launching a referral or commission programme or appointing a provider for it, Joqiva will update this page and the applicable privacy, cookie and partner terms disclosures. 8.4 Customer-selected accounting platforms Provider: Xero Limited or the Xero entity that supplies the Customer's Xero service; and Sage Group plc or the Sage entity that supplies the Customer's Sage Accounting service. Role: Xero and Sage Accounting are customer-selected third-party accounting services. The Customer has a separate account and agreement with the selected provider and directs Joqiva to connect the selected Workspace and accounting organisation. Neither provider is engaged by Joqiva as a general infrastructure subprocessor for every customer, and a provider receives Customer Personal Data only when an authorised Workspace user enables that connection. Purpose and data: Joqiva uses the selected provider's official API to create or update supported contacts, invoices and credit or correction records and to read organisation settings, accounts, tax rates, items, payment allocations, refunds, prepayments, overpayments and outstanding balances needed for reconciliation. Depending on the records selected by the Customer, data may include customer or contact names, business names, addresses, email addresses, phone numbers and VAT numbers; invoice and credit lines, amounts, tax treatment, dates, references and status; provider identifiers; and connection, mapping, change-detection, reconciliation, conflict and audit metadata. Joqiva does not use either accounting connection to create payments, obtain bank credentials, initiate transfers or move money. Data handling and offboarding: The selected provider processes data under the Customer's separate provider agreement and applicable privacy information. A verified Joqiva disconnect stops future API access and deletes Joqiva's encrypted provider OAuth credentials, but does not delete records already held by the provider. Joqiva may retain non-secret mappings, hashes, provider identifiers and financial or audit history according to the Privacy Policy and DPA. Provider-side access, correction and deletion must be managed in the selected provider where required. AI boundary: Xero and Sage Accounting API data is not sent to Joqiva's AI provider and is not used by Joqiva to train or fine-tune AI models. Status: Active customer-selected accounting platforms disclosed for transparency; not listed as general Joqiva DPA subprocessors.

9. Future subprocessors and provider categories

Joqiva may add, replace or remove subprocessors in accordance with the DPA. Future subprocessors may include providers for core service operation, security, reliability, support, communications, file review or scanning, analytics, subscription billing, AI-assisted processing or other Service functions. A provider is not approved to process Customer Personal Data as a subprocessor unless it is listed as an approved subprocessor on this page or is added in accordance with section 12 of the DPA. Where Joqiva makes a material change to subprocessors that process Customer Personal Data, Joqiva will provide notice and an opportunity to object as described in the DPA.

10. Providers not used for End Customer invoice payments

Joqiva does not process, collect, hold, transfer, settle, control or transmit money owed by End Customers to Joqiva customers. End Customers pay directly into the Joqiva customer's bank account by bank transfer. Joqiva does not use a payment processor for End Customer invoice payments. Any subscription billing provider used by Joqiva is used only for Joqiva subscription fees and is separate from End Customer invoice payment tracking. Communications providers such as Twilio SendGrid and Twilio are not used to process End Customer invoice payments.

11. Subprocessor due diligence

Before engaging a subprocessor that may process Customer Personal Data, Joqiva assesses, as appropriate: (a) the purpose of processing; (b) the categories of Customer Personal Data involved; (c) the categories of data subjects involved; (d) the provider's role and instructions; (e) security measures; (f) confidentiality obligations; (g) access controls; (h) data location and transfer safeguards; (i) retention and deletion commitments; (j) breach notification process; (k) subcontracting and onward transfer terms; (l) availability of a data processing agreement or equivalent terms; and (m) whether the provider offers sufficient guarantees to support Joqiva's obligations under the DPA.

12. Subprocessor contractual obligations

Where Joqiva uses a subprocessor to process Customer Personal Data, Joqiva will put in place a written contract or equivalent legal terms requiring the subprocessor to protect Customer Personal Data. Those terms must require the subprocessor to: (a) process Customer Personal Data only for the documented purposes and services for which the subprocessor is engaged; (b) process Customer Personal Data only under appropriate instructions; (c) maintain appropriate confidentiality; (d) use appropriate technical and organisational measures; (e) assist with data protection obligations where applicable; (f) support deletion, return or retention controls as required by applicable law and the DPA; (g) notify Joqiva of relevant personal data breaches where required; and (h) impose substantially equivalent protections on any approved onward subprocessors where required by applicable data protection law. Joqiva remains responsible to the Joqiva customer for the performance of its subprocessors as set out in the DPA.

13. International transfers

Joqiva and its subprocessors may process or access Customer Personal Data from countries outside the United Kingdom. Where required by applicable data protection law, Joqiva will use an appropriate transfer mechanism, which may include: (a) adequacy arrangements; (b) UK transfer terms or addenda; (c) standard contractual clauses; (d) approved certification, rules or equivalent safeguards where applicable; (e) an applicable exception where lawful and proportionate; (f) another lawful transfer mechanism permitted by applicable data protection law. Where Joqiva or the relevant party relies on appropriate safeguards rather than adequacy regulations or an exception, Joqiva will carry out or rely on an appropriate transfer risk assessment, data protection test or equivalent assessment where required. Supplementary technical, contractual or organisational measures may be applied where needed to support the relevant transfer mechanism. Joqiva will assess international transfers in light of the nature of the data, the provider, the destination country, the processing activity and the safeguards available.

14. Changes, notice and objections

Joqiva informs affected Customers directly of intended additions or replacements of Subprocessors in accordance with section 12 of the DPA. The ordinary advance-notice period is at least 30 calendar days. The notice identifies the provider, processing function, relevant locations, intended start date and objection channel. Publication on this page supports but does not replace direct notification. Customers may raise reasonable data protection objections before the intended start date. Unresolved timely objections and exceptional urgent changes are handled under section 12 of the DPA. No statement on this page removes the requirement for the applicable prior authorisation or permits a processing change solely by retrospective publication.

15. Vendor subprocessor chains

Joqiva's subprocessors may use their own subprocessors. Where a Joqiva subprocessor uses its own subprocessors, Joqiva relies on the contractual commitments, data processing terms, security measures and subprocessor controls provided by that vendor. Joqiva does not reproduce every vendor subprocessor chain on this page, but may refer to the vendor's own subprocessor list, data processing terms, trust centre or security documentation where appropriate. Joqiva remains responsible to the Joqiva customer for subprocessors as described in the DPA and applicable data protection law.

16. Data minimisation

Joqiva configures subprocessors so that they process only the Customer Personal Data reasonably necessary for the relevant service. Joqiva also seeks to avoid sending unnecessary Customer Personal Data to monitoring, support, AI, logging, communications or infrastructure providers that act as subprocessors. Joqiva does not intentionally send customer quote content, invoice content, payment proof content, bank details, payment instructions, AI source input or output, email bodies, customer names, customer email addresses, customer phone numbers, credentials, secrets or full URLs containing access information to providers unless necessary for the relevant Service function, lawful, documented and covered by the DPA or another applicable legal basis. Where email or SMS delivery is used, the communications provider may receive message content containing a customer-facing link because that is necessary to deliver the message to the intended recipient. Customers should not submit unnecessary sensitive personal data, special category personal data, criminal offence data, children's data, full payment card details, passwords or irrelevant personal data into Joqiva.

17. Questions

For questions about subprocessors, international transfers or this page, use the contact details maintained in the Legal Notice. The current privacy contact and legal contact are listed in the Legal Notice.

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