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DPA ANNEX D
Docebo Sub-processors January 2026
Docebo Sub-processors - Software Services infrastructure
Entity Name Description of the Processing Data Processed Processing Location Applicable Docebo Notes
Software Service /
Features
Service provider (IaaS/PaaS/SaaS) for All data uploaded into and collected USA, EU, UK, Canada, India, or All Docebo Software *Associated system logs and backup data are retained for
all application data storage and through the Docebo Software Australia**, according to AWS Services 12 months.
processing required to support Services.* region options available for the
Docebo Software Services Docebo Software Service chosen **Disaster Recovery location for Australia processing
functionalities. by the Customer in the location will be located in Singapore
Agreement or otherwise agreed
upon during the implementation ***Limited data related to the Docebo Usage Dashboard
and configuration phase of and media conversion component
Docebo Software Services.*** are processed in the EU only, regardless of the AWS
region option chosen by the Customer in the Agreement.
USA (for Customers who have Docebo Learning
chosen a hosting location for Evaluation
Docebo Learn LMS hosted in the
US or Canada)
EU ( for Customers that have
chosen a hosting location for
Amazon Web
Docebo Learn LMS in the EU, UK,
Services India, or Australia)***
Bedrock****: Generative AI-powered Data contained in the source files USA (for Customers who have Docebo AI ****Additional details on AWS Bedrock data privacy and
functionalities, including content uploaded to the AI functionalities, and chosen a hosting location for functionalities security practices are available here.
generation, enhancement, revision, any input provided by the End User Docebo Learn LMS hosted in the *****An overview of the Docebo AI functionalities is
US or Canada) available at the following link
file transcription, and translation, for through the use of the AI
EU ( for Customers who have Some of the AI functionalities available in the Docebo
Docebo AI functionalities, as governed functionalities. chosen a hosting location for Learn LMS are optional and can be enabled or disabled by
under the applicable Software Service Docebo Learn LMS in the EU, Customers at any time. More details on Docebo AI
Addendum incorporated into the Data contained within the Learn LMS India, or Australia) functionalities and their settings are available here.
Agreement*****. to which AI functionalities apply, as
described in more detail here.
Docebo Sub-processor list January 2026 Page 1 of 5
Docebo Sub-processors - Software Services infrastructure
IaaS provider for Docebo's resource IP addresses, email addresses, and Ireland (EU) Helpdesk / Support The Personal Data transferred are related only to
planning application (Provisio), usernames of the End User involved in Services Customers' Docebo Software Services Administrators
including related data storage and the Support Services. Full name of Customer Success involved in Support Services.
processing, as well as customer Docebo Software Service Services
support to address technical or Administrator. Professional Services
service issues.
Service Provider used to create videos Input provided by the LMS Admins EU Docebo Creator
from text via artificial representations used to prompt AI Avatars to speak
of individuals (“AI Avatars”) and perform.
Colossyan Any information LMS Admins decide to
upload to create a customized AI
Avatar, including their voice, picture, or
video footage (available in late 2025)
Application and infrastructure log IP addresses, email addresses, and USA All Docebo Software Data retention on Datadog is limited to 30 days.
Datadog, Inc.
monitoring. usernames of End Users. Services
Vertex AI: Generative AI-powered Data contained within the Learn LMS USA (for Customers who have Docebo Learn LMS *An overview of the Docebo AI functionalities is available
functionalities, including content to which AI functionalities apply, as chosen a hosting location for (AI functionalities at the following link
generation, enhancement, revision, described in more detail here. Docebo Learn LMS hosted in the only) Some of these AI functionalities available in the Docebo
US or Canada) Learn LMS are optional and can be enabled or disabled by
and file transcription and translation,
Google LLC EU ( for Customers who have Customers at any time. More details on Docebo AI
for Docebo AI functionalities, as chosen a hosting location for functionalities and their settings are available here.
governed under the applicable Docebo Learn LMS in the EU,
Software Service Addendum India, or Australia)
incorporated into the Agreement*
Lunaweb Content format conversion Learning object files are uploaded to Germany (EU) Docebo Learn LMS
GmbH (Cloudconvert). Docebo Learn LMS.
Content Service provider integrated Learn LMS End User email addresses, Australia Docebo Content* *The sub-processing is performed only when:
into Docebo Learn LMS: delivery of encrypted UID, time stamps, and - The Customer enables the Content feature
content (Courses/Learning Objects) to other details included in the SCORM - Only for content provided by GO1
End Users upon Customer’s LMS file (full name and location). Other
GO1 Pty Ltd
Administrators activation and information that may be included in The Customer’s Administrator is responsible for informing
management. the SCORM file by the customers' LMS End Users that, by using Docebo Content, their Personal
administrators. Data can be shared outside of Docebo to GO1.
Information collected via SCORM is deleted within 45
Docebo Sub-processor list January 2026 Page 2 of 5
Docebo Sub-processors - Software Services infrastructure
days of collection.
Content Service provider integrated Information included in the SCORM USA Docebo Content* *The sub-processing is performed only when:
into Docebo Learn LMS: delivery of file. - The customer enables the Content feature
content (Courses/Learning Objects) to - only for content provided by OpenSesame
OpenSesame
End Users upon Customer’s LMS The customer’s Administrator is responsible for informing
Administrators' activation and End Users that, by using Docebo Content, their Personal
management. Data can be shared outside of Docebo to OpenSesame.
Azure OpenAI: generative AI-powered Data contained in the source files USA (for Customers who have Docebo AI *Additional details on Microsoft Azure data privacy and
functionalities, including content uploaded to the AI functionalities, and chosen a hosting location for functionalities security practices are available here.
generation, enhancement, revision, any input provided by the End User Docebo Learn LMS hosted in the
US or Canada) **An overview of the Docebo AI functionalities is
and file transcription and translation, through the use of the AI
Microsoft* EU ( for Customers who have available at the following link.
for Docebo AI functionalities, as functionalities. chosen a hosting location for Some of these AI functionalities available in the Docebo
governed under the applicable Data contained within the Learn LMS Docebo Learn LMS in the EU, Learn LMS are optional and can be enabled or disabled by
Software Service Addendum to which AI functionalities apply, as India, or Australia) Customers at any time. More details on Docebo AI
incorporated into the Agreement**. described in more detail here. functionalities and their settings are available here.
Integration-platform-as-a-service Always applicable: USA Docebo Learn LMS (*) Data storage location is chosen by the Customer in the
provider for native and custom 3rd (1) User record: Non-sensitive Germany (EU)(*) (**) Agreement, or otherwise agreed upon during the
party integrations and automation identification data (first and last Docebo Connect (**) implementation and configuration phase of Docebo
services. name), contact details (email address) Software Services.
of End Users.
Depending on the specific integration: (**) The sub-processing is performed only when:
(2) Formal learning tracking - a specific integration built upon Workato is enabled and
information (course completion status, configured, as specified in the Docebo Learn LMS
final results/score, certificates) documentation
Workato, Inc. (3) Informal learning tracking (asset - when the Docebo Connect module is enabled and used
publication/fruition tracking, asset
ranking)
(4) Questions/Answers tracking
(5) Learn skill mapping/evaluation
(6) Learning Reporting data (Docebo
platforms report)
(7) IP Addresses
(8) API Key and Logs
(9) Access Token
Docebo Sub-processor list January 2026 Page 3 of 5
Docebo Sub-processors - Software Services infrastructure
Data laking/warehousing of learning Email, usernames, first name, last USA Docebo Learn LMS The data storage location used will be located in the same
and analytical data used by the name, avatar, additional fields, and EU Learn Data region chosen by the Customer for its AWS data storage.
Snowflake reporting and dashboarding features groups/branches memberships of End Canada
of Docebo Learn LMS and stream Users. UK
processing of Learn LMS events. Australia
Image and video management and Images and videos uploaded to the USA Docebo Shape
Cloudinary media asset Content Delivery Software Services.
Network.
Service Provider used to provide Input provided by the LMS Admins USA* Docebo Creator * This information is only processed in real time by Tavus
dynamic artificial version of an used to prompt Virtual Avatars to and automatically deleted once the Creator session ends.
Tavus individual’s likeness ("Virtual Avatar") speak and perform.
and used to support real-time Conversation transcripts provided by
conversational video conversations each End User during the session with
with End Users. the Virtual Avatar*.
Docebo Sub-processors - Support Services
Entity Name Purpose Processed Data Location Docebo Support Notes
Services involved
Ticketing service for inbound Software IP addresses, email addresses, and Germany (EU) Helpdesk / Support Services The Personal Data transferred are related only to
Service customer support, or through usernames of Docebo Software Service Customer Success Services Customers' Docebo Software Services Administrators
the widget support integrated into the Administrators involved in the Support Professional Services involved in Support Services.
Zendesk, Inc. Software Service. Services, as well as any other information
submitted by the Administrators for the
sole purpose of dealing with customer
support requests.
Internal tracking of requests handled IP addresses, email addresses, and EU (Ireland, Germany) Helpdesk / Support Services The Personal Data transferred are related only to
by Docebo Support and Customer usernames of End Users involved in the and US (California) Customer Success Services Customers’ Docebo Software Services Administrators
Atlassian, Inc.: Success. support services. Professional Services involved in Support Services.
Jira Data submitted by the Docebo Software
Service Administrators with the ticket to
the Support Services.
Docebo Sub-processor list January 2026 Page 4 of 5
Management of surveys to collect Email addresses and usernames of Germany (EU) Helpdesk / Support Services The Personal Data transferred are related only to
Qualtrics Customer satisfaction feedback on the Docebo Software Service Administrators Customer Success Services Customers' Docebo Software Services Administrators
Docebo product user experience. involved in the Support Services. Professional Services involved in Support Services.
Professional Service tool used (i) Email address and Full Name of the End USA Professional Services The Personal Data transferred are related only to
internally by Docebo to manage User associated with the Professional Customers' Docebo Software Services Administrators
involved in Support Services.
Kantata Professional Service time tracking and Services.
Mavenlink (ii) externally as a customer-facing
project management tool for service
delivery.
Customer success analytics and Email address, Full Name, phone number, USA Customer Success Services
engagement tool Docebo Software Service Administrator
Totango
job title, and Customer’s physical
address.
Docebo Sub-processors - Docebo Affiliates
The Docebo group of companies engages personnel to provide service support and other management functions related to the Services offered under our Agreement with Customers.
Support and management activities encompass engineering tasks related to ensuring the availability, latency, scalability, and efficiency of the Services, as well as product management and
customer support. This means that the following Docebo entities may act as a Sub-processor to the Docebo entity, which is your contractual counterpart.
Entity Name Subject Matter of the Processing Processed Data Location Applicable Docebo Product
Docebo S.p.A. Italy (EU)
Docebo NA, Inc. USA
Maintenance and operation of the Software
Docebo France SAS France (EU)
Services production and underlying
Docebo Software Suite Administrators’ email addresses, telephone numbers,
Docebo UK Limited infrastructure. UK All Docebo Software Services
usernames, IP addresses, and data submitted to the support services.
Docebo DACH GmbH Germany (EU)
Support and Customer Success activities.
Docebo Inc. Canada
Docebo Australia Pty Ltd. Australia
Docebo Sub-processor list January 2026 Page 5 of 5