engageSPARK Subprocessors
Last updated: August 17, 2026
Published at: https://www.engagespark.com/legal/subprocessors
This list identifies the Subprocessors engaged by engageSPARK to process Contact Personal Information (CPI) on behalf of its Customers, as defined in the Data Processing Agreement (DPA).
Updates. engageSPARK will provide notice of new Subprocessors in accordance with the DPA.
| Name, Privacy policy or GDPR statement | Type | Purpose | Country | Shared data | Transfer safeguard |
|---|---|---|---|---|---|
|
Anthropic, PBC https://www.anthropic.com/legal/commercial-terms https://www.anthropic.com/legal/data-processing-addendum |
Subprocessor | AI features | United States | CPI Processed by the Services’ AI features. | EU-US Data Privacy Framework (DPF), UK Extension to the EU-US DPF, Swiss-US DPF; SCCs as fallback. |
| Clearfeed, Inc | Support / Operational Tool | Customer support | United States | Not a Subprocessor. Receives CPI only if Customer sends CPI to engageSPARK via this channel (which Customer should not do — see the DPA’s terms on Out-of-Service Materials). | EU-US DPF, UK Extension, Swiss-US DPF; SCCs as fallback. |
|
Cloudflare, Inc. https://www.cloudflare.com/trust-hub/gdpr/ |
Subprocessor | Infrastructure & Security | United States | CPI transiting our public endpoints. | EU-US DPF, UK Extension, Swiss-US DPF; SCCs as fallback. |
|
Fireflies.AI Corp. https://fireflies.ai/data-processing-agreement |
Support / Operational Tool | Customer support | United States | Not a Subprocessor. Receives CPI only if Customer sends CPI to engageSPARK via this channel (which Customer should not do — see the DPA’s terms on Out-of-Service Materials). | EU-US DPF, UK Extension, Swiss-US DPF; SCCs as fallback. |
|
Google LLC / Google Cloud EMEA Limited https://cloud.google.com/privacy/gdpr |
Subprocessor | Infrastructure, Security, and AI features | Germany, United States | CPI Processed by the Services. | EU-US DPF, UK Extension, Swiss-US DPF; SCCs as fallback. Primary service data and voice recordings remain in the EU. |
|
Hetzner Online GmbH https://www.hetzner.com/AV/DPA_en.pdf |
Subprocessor | Infrastructure & Security | Germany | CPI Processed by the Services. | EU/EEA processing, no restricted transfer for EU, UK (UK–EEA adequacy), or Switzerland (Swiss-EEA adequacy). |
|
Intercom, Inc. https://www.intercom.com/legal/data-processing-agreement |
Support / Operational Tool | Customer support | United States | Not a Subprocessor. Receives CPI only if Customer sends CPI to engageSPARK via this channel (which Customer should not do — see the DPA’s terms on Out-of-Service Materials). | EU-US DPF, UK Extension, Swiss-US DPF; SCCs as fallback. |
|
Mailgun Technologies, Inc. (Sinch) |
Subprocessor | United States | CPI Processed by the Services’ Email action features. | EU-US DPF, UK Extension, Swiss-US DPF; SCCs as fallback. | |
|
Aivision Products SRL (MeetGeek) https://meetgeek.ai/data-processing-agreement |
Support / Operational Tool | Customer support | Romania | Not a Subprocessor. Receives CPI only if Customer sends CPI to engageSPARK via this channel (which Customer should not do — see the DPA’s terms on Out-of-Service Materials). | EU/EEA processing, no restricted transfer for EU, UK (UK–EEA adequacy), or Switzerland (Swiss-EEA adequacy). |
|
Meta Platforms, Inc. https://www.facebook.com/privacy/policy/ https://www.facebook.com/legal/terms/dataprocessing/ |
Support / Operational Tool | Customer support | United States | Not a Subprocessor. Receives CPI only if Customer sends CPI to engageSPARK via this channel (which Customer should not do — see the DPA’s terms on Out-of-Service Materials). | EU-US DPF, Swiss-US DPF; SCCs as fallback (with UK IDTA for UK transfers, as Meta is not certified to the UK Extension). |
|
Microsoft Corporation https://privacy.microsoft.com/en-gb/privacystatement |
Support / Operational Tool | Communication and collaboration with Customers via Outlook, Teams, and similar Microsoft 365 tools | United States, Germany | Not a Subprocessor. Receives CPI only if Customer sends CPI to engageSPARK via these channels (which Customer should not do — see the DPA’s terms on Out-of-Service Materials). | EU-US DPF, UK Extension, Swiss-US DPF; SCCs as fallback. |
|
Microsoft Corporation https://privacy.microsoft.com/en-gb/privacystatement |
Subprocessor | Internal collaboration | United States, Germany | We store the minimum necessary CPI in short-retention folders to help us provide customer support or provide the Services. | EU-US DPF, UK Extension, Swiss-US DPF; SCCs as fallback. |
|
Microsoft Corporation https://privacy.microsoft.com/en-gb/privacystatement |
Subprocessor | Azure AI features | United States, Germany | CPI Processed by the Services’ AI features. | EU-US DPF, UK Extension, Swiss-US DPF; SCCs as fallback. |
|
OpenAI, L.L.C. https://openai.com/policies/services-agreement/ https://openai.com/policies/data-processing-addendum/ |
Subprocessor | AI features | United States | CPI Processed by the Services’ AI features. | EU-US DPF, UK Extension, Swiss-US DPF; SCCs as fallback. |
|
SentinelOne, Inc. (Scalyr) https://www.sentinelone.com/legal/privacy-policy/ |
Subprocessor | Infrastructure | United States | CPI only to the extent it appears in our Voice application logs. | EU-US DPF, UK Extension, Swiss-US DPF; SCCs as fallback. |
|
Functional Software, Inc. (Sentry) https://sentry.io/legal/dpa/ |
Subprocessor | Infrastructure | United States | CPI only to the extent it appears in our UI logs. | EU-US DPF, UK Extension, Swiss-US DPF; SCCs as fallback. |
|
Slack Technologies, LLC (Salesforce, Inc.) https://slack.com/trust/compliance/gdpr |
Subprocessor | Internal collaboration | United States | We store the minimum necessary CPI in a dedicated channel with a 7-day auto-deletion policy to help us provide customer support or provide the Services. | EU-US DPF, UK Extension, Swiss-US DPF; SCCs as fallback. |
|
Viber Media S.‡ r.l. (Rakuten Group) |
Support / Operational Tool | Customer support | Luxembourg | Not a Subprocessor. Receives CPI only if Customer sends CPI to engageSPARK via this channel (which Customer should not do — see the DPA’s terms on Out-of-Service Materials). | EU/EEA processing, no restricted transfer for EU, UK (UK–EEA adequacy), or Switzerland (Swiss-EEA adequacy). Onward transfers within the Rakuten Group covered by Rakuten Group Binding Corporate Rules. |
|
WhatsApp LLC, WhatsApp Ireland Limited https://www.whatsapp.com/legal/privacy-policy https://www.whatsapp.com/legal/business-data-processing-terms |
Support / Operational Tool | Customer support | Ireland, United States | Not a Subprocessor. Receives CPI only if Customer sends CPI to engageSPARK via this channel (which Customer should not do — see the DPA’s terms on Out-of-Service Materials). | Primary processing by WhatsApp Ireland in the EU/EEA. Onward transfers to WhatsApp LLC and Meta Platforms in the US under EU-US DPF, Swiss-US DPF; SCCs as fallback (with UK IDTA for UK transfers, as WhatsApp LLC and Meta are not certified to the UK Extension). |