Sub-Processor List

Introduction

This document lists the third-party sub-processors that THEAX LTD (trading as Axel Up) uses to provide A.X.E.L Portal services. These companies may process your personal data as part of delivering our services.

We work only with reputable providers who maintain appropriate data protection standards and comply with applicable privacy laws including UK GDPR.

Current Sub-Processors

The following table shows all third-party processors currently used in our services:

Data Transfer Safeguards

Where personal data is transferred to sub-processors located outside the UK/EU, we ensure appropriate safeguards are in place:

Adequacy Decisions

Some transfers rely on adequacy decisions where the UK has determined that the destination country provides adequate data protection.

Standard Contractual Clauses

For transfers to countries without adequacy decisions, we use Standard Contractual Clauses (SCCs) approved by UK and EU authorities to ensure your data receives equivalent protection.

Additional Safeguards

• Technical measures such as encryption in transit and at rest
• Contractual restrictions on data usage and sharing
• Regular audits and compliance assessments
• Transparency reports from major processors

Sub-Processor Selection

We carefully evaluate all sub-processors based on:

• Data protection compliance: GDPR, UK GDPR, and other applicable regulations
• Security measures: Technical and organizational safeguards
• Contractual protections: Data processing agreements and liability terms
• Industry reputation: Track record and certifications
• Geographic considerations: Data residency and transfer requirements

Changes to Sub-Processors

Notification Process

We will notify you of changes to our sub-processor list by:

• Updating this page with at least 30 days' advance notice
• Sending email notifications for significant changes
• Publishing update announcements in your account dashboard

Right to Object

You have the right to object to the appointment of a new sub-processor. If you object:

• Notify us in writing within 30 days of the announcement
• We will work with you to address your concerns
• If we cannot reach a resolution, you may terminate your agreement without penalty

Sub-Processor Compliance

All sub-processors are required to:

• Process personal data only as instructed by us
• Implement appropriate technical and organizational security measures
• Maintain confidentiality of personal data
• Assist with data subject rights requests
• Notify us of any data breaches without undue delay
• Delete or return personal data when instructed

Your Rights

Regarding sub-processor arrangements, you have the right to:

• Object to new sub-processors as described above
• Request information about specific sub-processing arrangements
• Exercise your data subject rights regardless of where your data is processed
• Receive copies of relevant data processing agreements upon request

Contact Information

For questions about sub-processors or to exercise your rights:

• General inquiries: info@axelup.dev
• Data protection matters: privacy@axelup.dev
• Sub-processor objections: Include "Sub-Processor Objection" in the subject line