Compliance documentAVG art. 28 lid 2 en 4

Sub-processors of Stilops

Per party: what it does, where it processes, and the status of the processing agreement, including where one is missing.

This is an automatic translation of the Dutch document. In case of any difference, the Dutch text prevails. Read the Dutch text

Version18-10-2026LanguageEnglishPDFText file

Source of truth: the same list as in the privacy statement (section "Subverwerkers"); an automated check keeps the two identical.

This document states for each party what it does, where it processes data and what the status of the data processing agreement is — including where that is still open. Nowhere does it say "DPA signed" unless that has been recorded as evidence in the compliance register; as of 16-10-2026 that is the case only for the servers of Hetzner. The data processing agreement (DPA) for the mail hosting with Hetzner was concluded on 16-10-2026; the evidence thereof is still to be recorded in the register.

PartyPurposeCountryData processing agreement (status 17-10-2026)
AnthropicExecution of agent tasks (the language model behind each agent), via the services of Anthropic.United StatesOffers a data processing agreement with EU standard contractual clauses; acceptance by Stilops not yet recorded as evidence — open.
Hetzner Online GmbHHosting of the servers on which Stilops and customer data run.Germany (EU)Processing within the EU. DPA (Art. 28 GDPR) version 1.2 concluded via the Hetzner account, dated by Hetzner 22-9-2026; the PDF has been archived as evidence and recorded in the register — accepted, evidence archived.
Hetzner Online GmbH (e-mail)E-mail hosting of Stilops itself (Hetzner Webhosting): the sender account for transactional e-mail to customers (password reset, registration confirmation, invitations, ticket replies, decision notifications) and the mailboxes of Stilops' internal agents. Customer agents have no mailbox and do not send e-mail. Cold outreach to prospects via this host is not a given (Hetzner Webhosting does not permit bulk mail) and requires a separate decision.Germany (EU)Processing within the EU. DPA (Art. 28 GDPR) concluded via the Hetzner account for the mail hosting on 16-10-2026, including communication data (e-mail) — concluded; evidence still to be recorded in the register.
Cloudflare, Inc.DNS and traffic protection for the domains of Stilops.United StatesOffers a DPA with EU standard contractual clauses; acceptance not yet recorded as evidence — open.
StripePayments and invoicing data for a paid subscription.United States / IrelandOffers a DPA with EU standard contractual clauses; acceptance not yet recorded as evidence — open.
Kadaster (PDOK Locatieserver)Converting Dutch addresses into coordinates when a customer agent with route planning calculates a route using the route tool; only the address line, no names (since 17-10-2026).Netherlands (EU)Public government service; no data processing agreement offered. Receives only address lines without a name — decided by Fabian 17-10-2026.

What a customer may expect from this

  • If this list changes (new party, different country, different arrangement), the privacy statement changes accordingly and receives a new version number. A check in the repository enforces that the names in both sources remain identical.
  • A customer who objects to a sub-processor can report this via [email protected].
  • Until 16-10-2026, Stilops' e-mail ran via MXroute (United States), without a data processing agreement and without a transfer mechanism. Since that date, all e-mail runs via Hetzner in Germany. MXroute still holds the e-mail from before the switch. A final transfer and the termination are still in progress; after that, MXroute will no longer be used for personal data, and Stilops will then ask MXroute to confirm the deletion of mailboxes and domain in writing.
  • The browser vendor (Google for Chrome, Microsoft for Edge) processes audio for the voice functions (dictation, meeting recording) on the user's own device; that audio does not reach Stilops. This is stated in the privacy statement, but is not a sub-processor of Stilops within the meaning of Art. 28 GDPR and is therefore not included in the table.

What needs to happen to close the open items

  1. For Anthropic, Cloudflare and Stripe (Hetzner servers were completed on 11-10-2026, Hetzner mail on 16-10-2026): accept the DPA offered (usually a click in the supplier's customer portal), archive the accepted version as a PDF and set the reference as evidence on the controls iso27001:A.5.23, nis2:art.21(2)(d) and nen7510:5.22.
  2. MXroute is closed: on 16-10-2026 the e-mail was transferred to Hetzner (EU) with a data processing agreement. What still follows: recording the DPA evidence for the mail hosting in the register; completing the final transfer and the termination with MXroute, and then having the deletion of mailboxes and domain confirmed in writing.

Questions about this document? Email [email protected].