Subprocessors
Last updated: 4 June 2026
About this list
Qlareti B.V. engages the following third-party subprocessors in providing the Ora coaching platform. This list is maintained alongside our Data Processing Agreement (DPA) and reflects the subprocessors currently used to process Customer Personal Data.
Material changes to this list will be reflected on this page. Customers with a current DPA in place receive prior notice of any new or replacement subprocessor, with the right to object on reasonable grounds.
EEA-resident subprocessors
The following subprocessors process Customer Personal Data within the European Economic Area. No international data transfer applies.
| Subprocessor | Role | Location | Transfer mechanism |
|---|---|---|---|
| Amazon Web Services EMEA SARL | Cloud infrastructure (compute, networking, object storage) | EEA (eu-west-1, Ireland) | Intra-EEA |
| MongoDB, Inc. (Atlas) | Managed database (primary application data store) | EEA (eu-west-1, Ireland) | Intra-EEA |
| LiveKit (self-hosted by Qlareti) | Real-time voice room infrastructure | EEA (within Qlareti’s EEA infrastructure) | Intra-EEA |
Non-EEA subprocessors
The following subprocessors are established outside the EEA. International data transfers to these subprocessors are governed by the Standard Contractual Clauses adopted under Commission Implementing Decision (EU) 2021/914 of 4 June 2021, supplemented where appropriate by transfer impact assessments.
| Subprocessor | Role | Location | Transfer mechanism |
|---|---|---|---|
| Anthropic PBC | Large Language Model (primary coaching responses, supervisor audit, session summary) | United States | Standard Contractual Clauses |
| OpenAI, L.L.C. | Large Language Model (background extraction, secondary tasks) | United States | Standard Contractual Clauses |
| Deepgram, Inc. | Speech-to-text transcription | United States | Standard Contractual Clauses |
| ElevenLabs, Inc. | Text-to-speech voice synthesis | United States | Standard Contractual Clauses |
| Twilio, Inc. (SendGrid) | Transactional email delivery | United States | Standard Contractual Clauses |
EEA-only inference routing (on request)
For Customers requiring EEA-only Processing by Large Language Models, Qlareti can configure inference routing through EEA-resident model providers, including:
- Anthropic on AWS Bedrock in eu-central-1 (Frankfurt), or
- Azure OpenAI in an EU region (Sweden Central, France Central, or similar).
This routing is provided subject to commercial agreement and may affect pricing.
No training on Customer Personal Data
Qlareti does not use Customer Personal Data to train AI models, and contractually requires its AI subprocessors to do the same. Anthropic and OpenAI contractually commit, under their commercial API terms, not to train on content submitted via their commercial endpoints.
Changes and notification
Customers with a current Data Processing Agreement in place receive at least thirty (30) days' prior notice of any addition or replacement of a subprocessor. The right to object on reasonable grounds, and the consequences of objection, are governed by the DPA.
Contact
For questions about this list or Qlareti's data-processing practices, please contact privacy@qlareti.com.