Snapshot 7549

Document
Subprocessor list
URL
https://trust.docebo.com/subprocessors
Fetched
HTTP status
200
Content type
application/pdf
Fetch mode
browser
Size
187073 bytes
SHA-256 (raw)
1576d06b30003458e8fa7be62e7a502ddea36587c3b3f0c42d74aa711ab2913f
SHA-256 (normalized text)
b941ffc512fab16375dd987d4703bb26fe22f739e8ab32bc49a74601a97d7766

Raw (normalized text)

Scripts and page chrome removed; this is what change detection compares.

                                                                                         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