Back to Trust Centre
GDPR Article 28 Infrastructure Register

Authorized Sub-Processors

Last updated: 26 September 2026 · Current list of third-party infrastructure and service providers engaged by Personal Academy to host, process, and secure customer data.

Executive Sub-Processor Summary · Strict 30-Day Prior Notice

Every provider that processes customer data on our behalf is listed below with its purpose, hosting location, data categories involved, and a link to its own trust documentation. Each sub-processor’s own security and compliance documentation is linked from its row; we do not republish their audit reports. In accordance with GDPR Article 28(2), we commit to giving customers at least 30 calendar days prior written notice before authorizing any new sub-processor, with full contractual right to object.

Sub-Processor Modification Policy & 30-Day Notification Mechanism

Personal Academy maintains strict procedural controls governing sub-processor lifecycle management:

  1. Advance Written Notice: Personal Academy provides enterprise customers with at least 30 calendar days prior written notice before authorizing any new sub-processor to access, store, or process customer personal data.
  2. Notification Channel: Notices are delivered via email to designated tenant technical contacts and published to this public registry.
  3. Right to Object: Customers maintain the contractual right to object to the appointment of any new sub-processor on reasonable data protection grounds. If an objection cannot be mutually resolved, the customer may terminate the affected service component without penalty.
  4. Subscription Service: Customers may subscribe to automated sub-processor update notifications by emailing privacy@personalacademy.app with the subject line “Sub-Processor Registry Subscription”.
Section 1

Core Infrastructure & Platform Sub-Processors

These audited enterprise infrastructure and service providers are engaged by Personal Academy to host and deliver the standard platform.

Sub-ProcessorPurpose & ServiceData ProcessedLocationTrust Link
Supabase

Primary database, authentication provider, object storage and serverless (edge function) runtime for the whole platform. Database backups are managed by Supabase.

All application data: accounts, course content, learner progress, audit events, and files uploaded to course materials storage.

Account and profile dataCourse content and learner progressAudit eventsUploaded files
Managed Postgres, authentication, storage and edge-function hosting (region set at project creation).
Trust Page
Vercel

Hosts the production build of the Next.js application, edge delivery and web analytics.

The built application (compiled code, not a copy of the database), its HTTPS traffic, request metadata and cookieless page-view counts.

Request metadata (IP address, user agent)Page-view counts
Vercel’s build and edge network (US-based operator).
Trust Page
OpenRouter

Single gateway to third-party language models, so the platform is not locked to one model vendor.

Prompts and generated content for AI-powered activities (coaching, content generation, quiz assistance) — routed to the underlying model configured per activity. Guardrails keep untrusted user content out of the system prompt before it leaves our servers. Text, speech and transcription run under zero data retention. Image and video generation (only where an organisation switches on "Image and video generation without zero data retention") use a separate key under which the image or video provider may keep the prompt and the output for a short time.

AI prompts and generated contentImage and video prompts and outputs (not under zero data retention, organisation opt-in)
United States (model routing service; the downstream provider is configurable per AI activity).
Trust Page
Anthropic

AI model provider, and the AI assistant our support team uses to triage support requests and draft replies.

AI prompts and generated content, when an AI activity is configured to use a Claude model (via OpenRouter or direct). For support: the support emails, chat transcripts and tickets our team processes with Claude to triage them and draft replies.

AI prompts and generated contentSupport messages and the names and email addresses in them
United States.
Trust Page
OpenAI

AI model provider.

AI prompts and generated content, when an AI activity is configured to use an OpenAI model (via OpenRouter or direct).

AI prompts and generated content
United States.
Trust Page
Google Gemini

AI model provider.

AI prompts and generated content, when an AI activity is configured to use a Gemini model.

AI prompts and generated content
United States / EU (Google infrastructure).
Trust Page
ElevenLabs

Text-to-speech for course narration.

Lesson narration text sent for speech synthesis, only when course narration is generated.

Narration text
United States / EU.
Trust Page
Resend (or the organisation’s own SMTP provider)

Email delivery (invitations, reminders, alerts, receipts).

Recipient email addresses, names and message bodies of transactional and notification emails.

Email address and nameNotification content
United States (Resend); the organisation’s own provider where SMTP is configured.
Trust Page
Google Workspace

Email sending (SMTP relay for transactional and notification email) and our support and contact mailboxes.

Recipient email addresses, names and message bodies of emails sent through Google Workspace SMTP, and the messages people send to our support and contact mailboxes.

Email address and nameNotification contentSupport messages
United States / EU (Google infrastructure).
Trust Page
Sentry (only when error monitoring is switched on)

Error monitoring, so faults are found and fixed.

Error reports and performance traces: stack traces, the page or API route, browser and device type, and the internal user ID. Email addresses, IP addresses, cookies, request bodies and tokens are removed before a report is sent.

Error reportsInternal user IDBrowser and device metadata
United States / EU (region chosen when the Sentry organisation is created).
Trust Page
Razorpay

Payments and subscription billing.

Payment card, UPI and net-banking details, billing contact info.

Payment details (held by Razorpay, not by us)Billing contact
India.
Trust Page
Stripe (only where an organisation connects its own account)

Organisation-configured payments for storefront sales.

Payment details for that organisation’s own storefront sales, held by Stripe on behalf of the organisation.

Payment details (held by Stripe)Billing contact
United States / EU (Stripe infrastructure).
Trust Page
Browser push services (Google, Apple, Mozilla, Microsoft)

Delivering web-push notifications.

A push subscription endpoint and the notification payload, only for people who opt in to browser notifications.

Push subscription endpointNotification content
Operated by the browser vendor.
Trust Page
Google Analytics / Tag Manager

Website analytics.

Cookies (_ga, _ga_*), page views, device and browser metadata — public website only, after consent.

Cookie identifiersPage viewsDevice and browser metadata
United States / EU (Google infrastructure).
Trust Page
Meta Platforms (Pixel)

Marketing attribution.

Cookies (_fbp), page views, conversion events — public website only, after consent.

Cookie identifiersPage viewsConversion events
United States (Meta infrastructure).
Trust Page
Google Ads (conversion tag)

Measuring which advertisements lead to sign-ups.

Cookies (_gcl_au), ad-click identifiers and conversion events — public website only, after marketing consent.

Cookie identifiersAd-click identifiersConversion events
United States / EU (Google infrastructure).
Trust Page
LinkedIn (Insight Tag)

Marketing attribution for LinkedIn campaigns.

Cookies (li_fat_id), page views, device metadata and conversion events — public website only, after marketing consent.

Cookie identifiersPage viewsDevice and browser metadataConversion events
United States / EU (LinkedIn infrastructure).
Trust Page
Postmark and SendGrid (only where selected as the email provider)

Alternative email delivery providers and sending-domain verification.

Recipient email addresses, names and message bodies, only when EMAIL_PROVIDER or an organisation’s sending domain is set to one of these vendors.

Email address and nameNotification content
United States.
Trust Page
Pexels

Stock imagery for course authoring.

Search keywords typed by a course author when searching stock photos or video; no learner data.

Search keywords
United States / EU.
Trust Page
Integrations an organisation connects itself (Slack, Microsoft Teams and 365, Google Calendar and YouTube, Salesforce, HubSpot, LinkedIn Learning, Canva)

Customer-initiated integrations. Not engaged by us on a customer’s behalf; listed for transparency.

Only the data an organisation administrator chooses to sync (for example names, email addresses, completion records, calendar events) after that administrator authorises the connection with the vendor.

Names and email addressesLearning completionsCalendar events
Per vendor; chosen and controlled by the customer.
Trust Page
Learning Record Store an organisation names (xAPI forwarding and import)

Customer-initiated xAPI connection, configured by an organisation administrator in Admin > LRS. Not engaged by us on a customer’s behalf; listed for transparency.

xAPI statements (who did what learning, when, with what result). Forwarding sends copies of the organisation’s statements to that LRS; import pulls statements from that LRS at the customer’s instruction (statements pulled from a customer-named LRS at the customer’s instruction).

Learner identifiersLearning activity and results
Per vendor; chosen and controlled by the customer.
Trust Page
Microsoft Teams bot connector (chat-native learning)

Customer-initiated chat app (CHT). Only engaged once an organisation administrator installs the Academy app in their Microsoft Teams tenant; listed for transparency.

Replies and cards the Academy bot posts into a Teams chat the organisation installed it in: the message text, buttons and the Teams conversation and user identifiers needed to deliver them.

Chat messages sent by the botTeams user and conversation identifiers
Per vendor; chosen and controlled by the customer.
Trust Page
Content-library providers an organisation connects itself (Percipio, Udemy Business, Go1, edX, Microsoft Learn)

Third-party course catalogues an organisation licenses.

Catalogue and enrolment requests made with credentials the organisation supplies; learner identifiers only where the organisation enables enrolment sync.

Course catalogue metadataEnrolment identifiers
Per vendor; chosen and controlled by the customer.
Trust Page
Google (Gmail and Google Drive connectors)

Customer-initiated connector for ambient learning (Gmail, Google Drive). Not engaged by us on a customer’s behalf; listed for transparency.

Requests made with the OAuth or API credentials an organisation administrator (or, for Gmail, the individual worker) authorises, to read the mailbox message metadata or Drive files that connection is scoped to so they can be matched to learning in the flow of work.

Mailbox metadataDocumentsNames and email addresses in those items
Per vendor; chosen and controlled by the customer.
Trust Page
Microsoft (Outlook and SharePoint connectors)

Customer-initiated connector for ambient learning (Outlook, SharePoint). Not engaged by us on a customer’s behalf; listed for transparency.

Requests made with the OAuth or API credentials an organisation administrator (or, for Outlook, the individual worker) authorises, to read the mailbox items or SharePoint documents that connection is scoped to so they can be matched to learning in the flow of work.

Mailbox metadataDocumentsNames and email addresses in those items
Per vendor; chosen and controlled by the customer.
Trust Page
Zendesk (support-ticket connector)

Customer-initiated connector for ambient learning (Zendesk). Not engaged by us on a customer’s behalf; listed for transparency.

Requests made with the OAuth or API credentials an organisation administrator authorises, to read the support tickets that connection is scoped to so they can be matched to learning in the flow of work.

Support ticketsNames and email addresses in those items
Per vendor; chosen and controlled by the customer.
Trust Page
Freshworks (Freshdesk support-ticket connector)

Customer-initiated connector for ambient learning (Freshdesk). Not engaged by us on a customer’s behalf; listed for transparency.

Requests made with the OAuth or API credentials an organisation administrator authorises, to read the support tickets that connection is scoped to so they can be matched to learning in the flow of work.

Support ticketsNames and email addresses in those items
Per vendor; chosen and controlled by the customer.
Trust Page
ServiceNow (incident connector)

Customer-initiated connector for ambient learning (ServiceNow). Not engaged by us on a customer’s behalf; listed for transparency.

Requests made with the OAuth or API credentials an organisation administrator authorises, to read the incidents that connection is scoped to so they can be matched to learning in the flow of work.

IncidentsNames and email addresses in those items
Per vendor; chosen and controlled by the customer.
Not linked
Atlassian (Jira and Confluence connectors)

Customer-initiated connector for ambient learning (Jira, Confluence). Not engaged by us on a customer’s behalf; listed for transparency.

Requests made with the OAuth or API credentials an organisation administrator authorises, to read the Jira issues or Confluence pages that connection is scoped to so they can be matched to learning in the flow of work.

IssuesDocumentsNames and email addresses in those items
Per vendor; chosen and controlled by the customer.
Trust Page
GitHub (code connector)

Customer-initiated connector for ambient learning (GitHub). Not engaged by us on a customer’s behalf; listed for transparency.

Requests made with the OAuth or API credentials an organisation administrator authorises, to read the repository activity that connection is scoped to so they can be matched to learning in the flow of work.

Repository activityUser names
Per vendor; chosen and controlled by the customer.
Trust Page
Notion (knowledge connector)

Customer-initiated connector for ambient learning (Notion). Not engaged by us on a customer’s behalf; listed for transparency.

Requests made with the OAuth or API credentials an organisation administrator authorises, to read the Notion pages that connection is scoped to so they can be matched to learning in the flow of work.

DocumentsNames in those items
Per vendor; chosen and controlled by the customer.
Trust Page
HubSpot (CRM connector)

Customer-initiated connector for ambient learning (HubSpot). Not engaged by us on a customer’s behalf; listed for transparency.

Requests made with the OAuth or API credentials an organisation administrator authorises, to read the CRM records that connection is scoped to so they can be matched to learning in the flow of work.

CRM recordsNames and email addresses in those items
Per vendor; chosen and controlled by the customer.
Trust Page
Salesforce (CRM connector)

Customer-initiated connector for ambient learning (Salesforce). Not engaged by us on a customer’s behalf; listed for transparency.

Requests made with the OAuth or API credentials an organisation administrator authorises, to read the CRM records that connection is scoped to so they can be matched to learning in the flow of work.

CRM recordsNames and email addresses in those items
Per vendor; chosen and controlled by the customer.
Trust Page
Zoho (Zoho CRM connector)

Customer-initiated connector for ambient learning (Zoho CRM). Not engaged by us on a customer’s behalf; listed for transparency.

Requests made with the OAuth or API credentials an organisation administrator authorises, to read the CRM records that connection is scoped to so they can be matched to learning in the flow of work.

CRM recordsNames and email addresses in those items
Per vendor; chosen and controlled by the customer.
Trust Page
Meta (WhatsApp Business Platform; only where the WhatsApp and SMS add-on is enabled)

Delivering learner messages over WhatsApp and SMS.

The recipient phone number and the text of the learner message for organisations that enable the WhatsApp and SMS add-on, when the platform has configured Meta as the WhatsApp provider; inbound replies and opt-outs (STOP) are received back by webhook.

Phone numbersMessage contentDelivery and opt-out status
Per provider.
Trust Page
Twilio (WhatsApp and SMS; only where the WhatsApp and SMS add-on is enabled)

Delivering learner messages over WhatsApp and SMS.

The recipient phone number and the text of the learner message for organisations that enable the WhatsApp and SMS add-on, when the platform has configured Twilio as the WhatsApp or SMS provider; inbound replies and opt-outs (STOP) are received back by webhook.

Phone numbersMessage contentDelivery and opt-out status
Per provider.
Trust Page
MSG91 (SMS; only where the WhatsApp and SMS add-on is enabled)

Delivering learner messages over WhatsApp and SMS.

The recipient phone number and the text of the learner message for organisations that enable the WhatsApp and SMS add-on, when the platform has configured MSG91 as the SMS provider.

Phone numbersMessage contentDelivery and opt-out status
Per provider.
Trust Page
Section 2

Customer-Initiated Integration Connectors (Transparent Disclosure)

The following third-party platforms are not general platform sub-processors engaged by Personal Academy. They are connected exclusively at the discretion of an organization’s administrator to facilitate specific enterprise workflows. Data exchanged is restricted to scopes authorized by the customer and governed by the customer’s direct agreements with each vendor:

Enterprise Collaboration

Slack Technologies (Slack), Microsoft Corporation (Microsoft 365, Teams, Outlook, OneDrive), Google LLC (Google Workspace, Google Calendar, YouTube)

Connected solely on administrator request to deliver in-workflow learning notifications, calendar sync, and interactive bot messaging.

Enterprise CRM & Service Desks

Salesforce, Inc., HubSpot, Inc., ServiceNow, Inc., Atlassian (Jira, Confluence), Zendesk, Inc., Freshworks, Inc., Zoho Corporation

Connected on demand to sync user course completion records, support tickets, and performance indicators into corporate business systems.

External Content Catalogs

Skillsoft (Percipio), Udemy Business, Go1, edX, Microsoft Learn

Connected to aggregate external enterprise course catalogs into the Personal Academy learner portal.

Messaging & Notifications

Meta Platforms (WhatsApp Cloud API), Twilio Inc. (SMS), MSG91 (DLT SMS)

Connected to send authorized SMS notifications or WhatsApp micro-lessons to enrolled corporate learners.

For enterprise sub-processor inquiries, DPA execution, or objection notices, contact privacy@personalacademy.app.