Overview of the categories of sub-processors pursuant to GDPR Art. 28 paras. 2 and 3 and revDSG Art. 9 para. 3 · Stand: 2026-10-02
To operate the platform, the provider engages sub-processors. This page sets out the categories of current sub-processors with purpose, types of data, place of processing and contractual basis. The list of sub-processors by name is part of the data processing agreement. The page is updated whenever changes occur; pursuant to section 15 of the Terms, customers may raise reasoned objections within 30 days.
| Category | Purpose | Data | Location | Contractual basis |
|---|---|---|---|---|
| Data centre, application and file storage | Running the application (compute) and file storage, redaction of personal data before it is filed in the immutable audit trail | Operational platform data, stored files, audit logs | Switzerland | Data processing agreement (DPA) with the provider, in force |
| Key custody | Key management (key sovereignty remains with SOTHURA SAFE GmbH) | Key material | Switzerland | Data processing agreement (DPA) with the provider, in force |
| Database | Database hosting | Operational data, field-encrypted details, audit trails | Switzerland | Data processing agreement (DPA) with the provider |
| AI computing capacity | AI analysis of documents | Documents submitted for AI analysis | EU | Data processing agreement (DPA) with the provider, in force |
| Email delivery | Transactional email delivery | System notifications, login emails, reports | EU | Data processing agreement (DPA) with the provider |
| Network protection | Protection against attacks, including form protection (login, registration, contact forms) | Connection data; content only transiently in working memory | Nearest network node, for Switzerland usually Zurich or Geneva | Data processing agreement (DPA) with the provider |
| Connection to the customer email and calendar system | Only to the extent the customer uses the connection: issuing and validating the sign-in tokens for the Outlook add-in. Where the customer switches the integration on, additionally calendar and mail synchronisation with the customer workplace (Microsoft 365). For the content of a mail the adviser opens in the add-in, the provider of the customer system is not a sub-processor of SOTHURA SAFE: that content sits in the customer's own tenant at Microsoft 365, for which the customer holds their own contract with that provider | Sign-in tokens; where the integration is switched on, appointments, messages and their attachments | Sign-in service of the customer system, reachable globally; the data location follows the customer tenant. For synchronisation, the data location of the environment the customer operates at Microsoft 365 | Data protection addendum of the provider; contracting entity and filing are being recorded |
Operational platform data (database, file storage, audit logs) is stored in Switzerland. AI computing capacity is provided in data centres in the EU; the category is listed in the table above. Email delivery runs through a provider in the EU. Network protection operates at the nearest network node, for Switzerland usually Zurich or Geneva; it processes connection data, content only transiently in working memory. For general market and news research, the platform uses an internet search. Customer and document data is not passed to the search. Calendar and mail synchronisation with Microsoft 365 only runs where the customer switches the integration on. Processing then takes place in the workplace environment the customer operates; the customer determines its data location through their own configuration. For the Outlook add-in, the sign-in service of the customer system issues the sign-in tokens; the content of a mail opened in the add-in stays in the customer tenant at Microsoft 365 until the adviser files it in the platform. For any third-country transfers, the Standard Contractual Clauses (SCC) of the European Commission apply.
A data processing agreement is in place with each sub-processor in the categories listed above. The DPAs are stored in the internal compliance archive and made available to customers for review on request, to the extent required by contract or by law.
The provider informs customers of planned changes or additions to the sub-processor list. Pursuant to section 15 of the Terms, objections must be submitted in writing to security [at] sothura [dot] com within 30 days. In the case of legitimate data-protection or security-related objections, the customer has a special right of termination if no equivalent alternative can be offered.
SOTHURA SAFE GmbH, Wassergasse 5, 4573 Lohn-Ammannsegg, Canton of Solothurn. Registered in the commercial register of the Canton of Solothurn, UID CHE-429.131.582. Management is held by Silvio Siegenthaler and Michel Di Vito, joint signature by two. The full provider identification is set out in the legal notice.