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SpotMe Group
SUBPROCESSORS FOR THE SPOTME ENTERPRISE ENGAGEMENT
PLATFORM
Approval and review Details
Document version 2.0.3
Last updated April 17, 2026
Approval authority CEO
Owner Legal & Procurement Manager <legal@spotme.com>
1 SCOPE
This documentation describes the subprocessors and certain other entities authorized to access information provided
to SpotMe by its customers, referred to as “Customer Data”. “Customer Data” means all information processed or stored
on computers or other electronic media by customers or by SpotMe on customers’ behalf and provided to SpotMe in
the course of customers’ use of SpotMe’s services, as well as any information derived from such information. Customer
Data includes, without limitation: (a) information provided to SpotMe by Users (as defined in the contractual documents)
or by other third parties; and (b) personal data from such Users or other third parties.
2 PROCESS FOR MAKING AN OBJECTION
a) Make a formal objection. Not all of the subprocessors listed below process Customer Data for all services offered by
SpotMe. Customers may provide a reasonable objection only to any new subprocessors that would have access to
Customer Data by sending a written message to privacy@spotme.com within ten (10) business days after receipt of
notice of a change.
b) SpotMe response. SpotMe will use commercially reasonable efforts to make available or recommend to Customer a
commercially reasonable change in SpotMe’s services to avoid processing of Customer Data by the objected-to new
subprocessor without unreasonably burdening SpotMe or the Customer. For the avoidance of doubt, a “reasonable
objection” to a subprocessor must show an objective, evidence-based reason to believe that such new subprocessor
fails to provide sufficient guarantees to implement the appropriate technical and organizational measures in such a
manner that processing will meet the requirements of the EU Data Protection Laws and ensure the protection of the
rights of the data subject(s).
c) Resolution. Customer understands that the listed subprocessors are essential for providing the SpotMe services. If
after ninety (90) days from receipt of the objection notice, Customer has a reason to believe that corrective action taken
by SpotMe with regard to the objected-to subprocessor still does not provide sufficient guarantees that the processing
complies with EU Data Protection Laws, Customer may request termination of the affected services which cannot be
provided by SpotMe without the use of the objected-to new subprocessor (under the applicable Order Form(s) or
Statement(s) of Work). Such termination request shall be in writing. In the event of termination pursuant to this request,
such termination shall not be a termination for breach, and SpotMe will refund Customer any prepaid fees covering the
remainder of the term of such Order Form(s) or Statement(s) of Work following the effective date of termination with
respect to such terminated services, without imposing a penalty for such termination on Customer.
3 SUBPROCESSORS
3.1 SUBPROCESSORS WHO PROVIDE TECHNOLOGIES TO POWER CERTAIN SPOTME
SERVICES
The following subprocessors provide technologies used to deliver specific SpotMe services. If you deploy one of the
services below, the subprocessor(s) identified for that service may process, store, or otherwise access Customer Data
in the course of helping to provide that service.
legal@spotme.com
SpotMe Group
Subservice organization Services in scope Location of processing
Amazon Web Services, Inc. Cloud hosting services United States (based on hosting location
(or any of its affiliates in the Email delivery services contract with customer additional locations
respective location as are EU, Australia, Singapore)
indicated here)
Aiven Ltd. Usage statistics United States (based on hosting location
contract with customer additional locations
are EU, Australia, Singapore)
MailChimp, Inc. Email delivery services United States
Wordly, Inc. Captioning services United States
Datadog, Inc. Metrics, monitoring, and logs United States
Microsoft Corporation Communication services and data EU
visualisation
3.2 SUBPROCESSORS WHO PROVIDE ANCILLARY SERVICES TO SUPPORT SPOTME
SERVICES
The following subprocessors provide ancillary services to help support, operate, and maintain the Services. In such
cases, the subprocessor(s) identified may process, store, or otherwise access limited Customer Data in the course of
providing their ancillary services.
Subservice organization Services in scope Location of processing
Google LLC Corporate organization and United States, EU
communication system;
Processing of data subject requests
via email
Atlassian, Inc. Customer support system; United States, EU
Processing of data subject and
customer support requests
Appcues, Inc. Administrative user tools; United States
User onboarding activities
Intercom, Inc. Users messaging platform, used for United States
communication with users (chat)
Cyclr Systems Ltd. Application for computer system United Kingdom
integrations
Typeform SL Online forms for collection, storage United States, EU
and management of customer
feedback
Dropbox, Inc. Corporate organization and United States, EU
communication system;
If requested by Customer, used for
sharing of participant lists or other
business material
Kantata, Inc. Operations Management and Team United States
Collaboration Tool;
If requested by Customer, used for
sharing of participant lists or other
business material
legal@spotme.com
SpotMe Group
Hubspot, Inc. Email delivery for Customer user United States, EU
feedback and engagement
OneTrust LLC Cookie consent management platform United States, EU
Salesforce, Inc. Services support United States, EU
3.3 SPOTME CONTROLLED SUBSIDIARIES AND AFFILIATES
The following SpotMe controlled subsidiaries and affiliates support, operate, deliver, and maintain the services and in
the course of doing so may process, store, or otherwise access Customer Data. This data resides only in SpotMe
facilities, on SpotMe systems, and subject to SpotMe policies and supervision.
Subservice organization Location of processing
SpotMe SA Switzerland
SpotMe, Inc. United States
SpotMe Pte. Ltd. Singapore
SpotMe EOOD EU
4 CHANGE LOG
Date of change Change
June 23, 2023 Removed: SoftLayer Technologies, Inc.
Added: Wordly, Inc.; Datadog, Inc.; Aiven Ltd.; Hubspot, Inc.; OneTrust LLC;
Salesforce, Inc.
December 22, 2023 Typeform SL: updated location of processing
May 7, 2025 Added Microsoft Corporation in the subservice organization list
Removed Nexmo, Inc., StreamYard, Inc.
Added clarity in Services in scope descriptions
April 17, 2026 Removed: EEG Enterprises, Inc.
Added clarity in Services in scope descriptions
legal@spotme.com