This page lists the third-party sub-processors that OPTICOMM AI S.R.L. ("OptiComm") engages to process personal data on behalf of its customers in connection with the Services, as referenced in our Data Processing Agreement.
We impose data protection obligations on each sub-processor that are no less protective than those in our DPA, and we remain responsible for their performance. Where a sub-processor is located outside the EEA, transfers are protected by an adequacy decision or the EU Standard Contractual Clauses with supplementary measures as needed. Where available, we use EU-based processing regions.
How to stay informed of changes: We provide at least 30 days' notice before adding or replacing a sub-processor, giving customers the opportunity to object on reasonable data-protection grounds. To subscribe to change notifications, email privacy@opticomm.ai.
Infrastructure and hosting
| Sub-processor | Service provided | Processing location | Transfer mechanism |
|---|
| Amazon Web Services (AWS) | Cloud hosting / infrastructure | EU region(s) | Adequacy / SCCs as applicable |
| Google Cloud (Google Cloud EMEA / Google Ireland) | Cloud hosting / infrastructure | EU region(s) | Adequacy / SCCs as applicable |
| Microsoft Azure (Microsoft Ireland Operations) | Cloud hosting / infrastructure | EU region(s) | Adequacy / SCCs as applicable |
| Supabase (Supabase, Inc.) | Managed database, authentication, storage and serverless functions for the OptiComm mobile app and voice agents | EU (Stockholm, eu-north-1) | Adequacy / SCCs as applicable |
AI / machine-learning providers
| Sub-processor | Service provided | Processing location | Transfer mechanism |
|---|
| OpenAI | Large language model / inference; transcription | EU and/or US | SCCs + supplementary measures |
| Anthropic | Large language model / inference | EU and/or US | SCCs + supplementary measures |
| Google (Vertex AI / Gemini) | Large language model / speech services | EU and/or US | Adequacy / SCCs as applicable |
| ElevenLabs | Conversational AI voice agents: speech-to-text, text-to-speech and real-time voice conversations | EU and/or US | SCCs + supplementary measures |
Voice / telephony
| Sub-processor | Service provided | Processing location | Transfer mechanism |
|---|
| Twilio | Telephony / call connectivity for AI voice agents | EU and/or US | SCCs + supplementary measures |
Mobile app delivery and diagnostics
| Sub-processor | Service provided | Processing location | Transfer mechanism |
|---|
| Apple (Apple Distribution International Ltd.) | App distribution via the App Store and push notification delivery (Apple Push Notification service) for the OptiComm mobile app | EU and/or US | Adequacy / SCCs as applicable |
| Sentry (Functional Software, Inc.) | Crash and error reporting for the OptiComm mobile app; reports contain no user identity | EU and/or US | SCCs + supplementary measures |
Operations
| Sub-processor | Service provided | Processing location | Transfer mechanism |
|---|
| Google (Analytics / Workspace) | Website analytics; business email | EU and/or US | Adequacy / SCCs as applicable |
NVIDIA is a startup-program partner (NVIDIA Inception), not a data sub-processor, so it is intentionally not listed here. Cloud GPU/compute used for AI is provided through the cloud infrastructure providers above.
Change log
| Date | Change | Effective |
|---|
| September 15, 2026 | Added Supabase, Apple (App Store / APNs) and Sentry for the OptiComm mobile app; clarified the ElevenLabs scope | September 15, 2026 |
| March 31, 2026 | Initial publication | March 31, 2026 |
