AXL Sub-Processors
Last updated: 28 August 2026 Effective date: 5 May 2026 Version: 1.1
Overview
AXL EdTech Booster LLC ("AXL") engages third-party service providers, known as Sub-Processors, to support the delivery of the AXL educational SaaS platform (the "Services"). This page lists those Sub-Processors and is incorporated by reference into the AXL Data Processing Addendum (https://app.axl.tech/docs/dpa/en).
Sub-Processors are categorised as:
- Core infrastructure — used for all customers as part of the platform's standard operation
- Optional / customer-enabled — engaged only where a customer activates a corresponding feature or integration.
Where customer data is hosted
Customer Data is hosted in Amazon Web Services data centres in Frankfurt, Germany (eu-central-1) within the European Economic Area. Backups are retained in the same AWS region.
Operational and support access by AXL personnel and contractors is restricted to the United States, the United Kingdom and Canada (the latter two being subject to European Commission adequacy decisions).
Notification of changes
AXL provides at least thirty (30) days' notice of changes to this list. To subscribe to email notifications of changes, write to privacy@axl.tech with subject line "Subprocessor Updates Subscription".
Customers may object to a new Sub-Processor on reasonable data-protection grounds within fifteen (15) days of notification, in accordance with the Data Processing Addendum.
A. Core infrastructure Sub-Processors
These Sub-Processors are engaged for all customers as part of the standard operation of the Services.
| Sub-Processor | Service | Categories of data | Location |
|---|---|---|---|
| Amazon Web Services EMEA SARL | Cloud infrastructure: ECS (compute), S3 (object storage), CloudFront (CDN), SQS (queues), CloudWatch (logs), Lambda, Route 53, ECR, KMS, EC2 | All categories of Customer Data, in transit and at rest | Frankfurt, Germany (eu-central-1) |
| Amazon Web Services EMEA SARL — Amazon RDS | Managed PostgreSQL — primary operational database | All operational Customer Data: users, courses, orders, CRM, settings | Frankfurt, Germany (eu-central-1) |
| Amazon Web Services EMEA SARL — Amazon ElastiCache | Managed Redis — caching, sessions, pub/sub, queues | Session and cache data, event payloads | Frankfurt, Germany (eu-central-1) |
| New Relic, Inc. | Application performance and error monitoring | Logs, traces, request metadata, error data | United States |
B. Optional / customer-enabled Sub-Processors
The Sub-Processors in this section are engaged only when a customer activates the corresponding feature or integration. Where a customer does not activate a feature, the corresponding Sub-Processor does not Process that customer's data.
Email delivery
| Sub-Processor | Purpose | Location |
|---|---|---|
| ElasticEmail Inc. | Transactional and marketing email delivery and webhooks | United States |
| Mailgun Technologies, Inc. | Transactional email delivery and webhooks | United States |
| Customer-provided SMTP | Customer-configured email sending | As determined by Customer |
Payment processing
Engaged only when activated by the customer:
Stripe, Inc.; PayPal, Inc.; Midtrans; Fondy; Square, Inc.; Authorize.Net; MercadoPago; CyberSource; BitPay; EcPay; SmartGlocal; Mobbex; ProntoPaga.
Categories of data: payment metadata, payer/order references, payment status. Card data is handled by the relevant gateway and is not retained by AXL outside gateway-issued tokens or references.
Video, media, push and translation
| Sub-Processor | Purpose | Location |
|---|---|---|
| Kinescope | Video upload, processing, hosting, playback and deletion | European Union |
| Google LLC — Translate API | Automatic translation of customer-supplied text | United States |
| Google LLC — Fonts | Web font delivery | United States |
| Google LLC — Safe Browsing | Unsafe-link/domain checks | United States |
| Google LLC — Calendar / Meet | Calendar event creation with Google Meet conference link | United States |
| Zoom Communications, Inc. | Creation/management of Zoom meetings and retrieval of recording metadata | United States (default; Customer may select Zoom data-residency options) |
| Firebase Cloud Messaging (Google LLC) | Web/mobile push notifications | United States |
| Expo (Exponent, Inc.) | Mobile push notifications | United States |
Messaging and social channels
Engaged only when activated by the customer:
Telegram FZ-LLC / Telegram Messenger Inc.; Viber Media S.à r.l.; Meta Platforms, Inc. (Facebook, Instagram, Messenger, Conversions API); WhatsApp; LINE Corporation.
Telephony (voice calls and SMS)
Engaged only when a customer obtains a telephone number through AXL, or connects a phone number as an assistant channel.
| Sub-Processor | Purpose | Categories of data | Location |
|---|---|---|---|
| Telnyx LLC | Telephone numbers, voice call carriage, SMS delivery, call recording storage at the carrier | Calling and called numbers, call time and duration, call audio, message content and delivery metadata | United States |
| Twilio Inc. | Telephone numbers, voice call carriage, SMS and WhatsApp message delivery | Calling and called numbers, call time and duration, call audio, message content and delivery metadata | United States |
AI processing
Engaged where a customer uses AI-assisted features (assistant, page/quiz/email builders, call transcription and summaries, AI voice calls).
| Sub-Processor | Purpose | Categories of data | Location |
|---|---|---|---|
| OpenRouter, Inc. | Routing of AI model requests to the providers below | Prompt and response content submitted to the model | United States |
| Google LLC (Gemini) | AI language models | Prompt and response content, including customer-supplied text and images | United States |
| OpenAI, L.L.C. | AI language models | Prompt and response content | United States |
| Deepgram, Inc. | Speech-to-text: transcription of voice messages and, where enabled on a number, of call recordings | Audio of voice messages and call recordings, and the resulting transcript | United States |
| Retell AI, Inc. | AI voice calls, where the customer enables the integration | Call audio, transcript, call metadata | United States |
Call recordings, their transcripts and the summaries generated from them are Processed only where the customer enables recording and analysis on the telephone number concerned, and can be switched off per number at any time.
Analytics and advertising integrations
Engaged only when configured by the customer:
Google LLC (Google Analytics); Meta Platforms, Inc. (Conversions API).
Other operational integrations
| Sub-Processor | Purpose |
|---|---|
| Oopspam | Spam detection on inbound data |
| ipapi.co | IP-based geolocation enrichment |
| ApiLayer (Exchange Rate API) | Currency-conversion lookups |
Transfer mechanisms
Where Customer Data is transferred to a Sub-Processor located outside the European Economic Area, AXL relies on:
- the European Commission's adequacy decisions in respect of the United Kingdom and Canada
- the EU Standard Contractual Clauses (Module Three: Processor to Processor) for transfers to Sub-Processors not covered by an adequacy decision; and, where applicable,
- supplementary measures including encryption in transit and at rest, access controls, and contractual safeguards.
Contact
For questions about this list or sub-processor changes, contact privacy@axl.tech.
For privacy or data-protection enquiries within the European Union, the EU Representative of AXL is Prighter Group, Schellinggasse 3/10, 1010 Vienna, Austria — https://app.prighter.com/portal/18576877104.