Trust and privacy

What is a sub-processor?

A sub-processor is a company that a service provider uses to process your data on its behalf, such as a hosting provider, an AI model provider or an email delivery service. Under the GDPR the provider must tell you who its sub-processors are and hold them to the same data protection terms.

This is a general explanation, not legal advice. If your business is the controller and a software tool is your processor, every company that tool relies on to handle your data is a sub-processor. The list usually lives in or next to the data processing agreement.

Why it matters

Each sub-processor is another place your customers’ data goes. The list tells you where the data is stored, which countries it passes through, and which companies’ terms apply. A provider normally has to tell you before adding a new sub-processor, so you can object.

For AI tools in particular, the list answers a question buyers often ask: which AI companies see the email, and on what terms?

An example

An email drafting tool lists three sub-processors: a cloud host for storage, an AI provider for writing drafts, and an error-monitoring service that sees technical details but no email content.

In ReplyPen: The companies ReplyPen relies on, and what each one sees, are listed on where your data goes.

Related terms

ReplyPen drafts replies to customer email in Gmail and Outlook, with a Check note under each Draft showing what it relied on.

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Last updated September 2026