Customer Personal Data Sub-processors
Last updated: 23 August 2026
Scope
This is the authorised list of providers that process Customer Personal Data for Inqelo. It is the same list incorporated into Schedule 3 of the Data Processing Agreement and Annex III of the Standard Contractual Clauses.
Customer-configured suppliers are the customer's suppliers. Stripe is not listed because it processes account-holder billing data rather than Customer Personal Data.
Authorised sub-processors
| Sub-processor | Processing | Location |
|---|---|---|
| Requesty Ltd (company no. 15165717) | EU LLM routing and gateway services for extraction, enhancement, formatting, summarisation, setup and valuation. Prompts and outputs are not retained or used for training. | Frankfurt, Germany |
| Model hosting providers authorised under Requesty's DPA: Google LLC (Vertex AI), Microsoft Azure AI, TensorX Ltd., sference, Amazon Web Services (Bedrock), Nebius AI and Inceptron AB | Model inference reached only through Requesty. Inqelo restricts approved routes to EU processing, zero retention and no training. Requesty contracts with and remains responsible for these providers. | European Union regions |
| AssemblyAI Inc. | Call transcription. Final transcription artifacts begin automatic deletion after 30 days, and content submitted through the European servers is not used for model training. | Dublin, Ireland through the EU endpoint |
| LlamaIndex Inc. | Parsing Customer-uploaded documents. | European Union through the EU endpoint |
| ClickHouse, Inc. (Langfuse Cloud) | LLM trace storage. Traces expire after 90 days and can be deleted for an individual. | European Union region |
| Amazon Web Services, Inc. and the AWS Contracting Party for the account country | File storage, retrieval and control-plane storage. | Frankfurt, Germany |
| DigitalOcean, LLC | Primary datastore and application hosting. | Amsterdam, Netherlands |
| VostokInc SAS (ScrapingBee) | Retrieval of publicly accessible webpages on Customer instruction. The request may use a Customer-selected proxy country outside the EEA. | Request-specific |
| Cloudflare, Inc. | Edge delivery, network security and TLS termination for the Platform. | Global edge network |
| Twilio Inc. (SendGrid) | Service and alert email, including alert content containing Lead Data. | European Union residency endpoint |
| CallTrackingMetrics | Tracking number supply, call handling and call recording, where Inqelo supplies the call tracking. Used for customers in the European Union and the Americas. | United States |
| FoneDynamics | Tracking number supply, call handling and call recording, where Inqelo supplies the call tracking. Used only for customers in Australia and New Zealand. | Australia |
Call tracking
Where Inqelo supplies the tracking numbers, the provider is an Inqelo Sub-processor and is chosen by region: CallTrackingMetrics for the European Union and the Americas, FoneDynamics for Australia and New Zealand. Where Customer brings its own call tracking, that provider is the Customer's supplier and is not listed here.
Model hosting
The model hosting providers in the list are Requesty's Sub-processors, not direct Inqelo suppliers. Inqelo reaches them only through Requesty and restricts its approved routes to European Union processing, zero retention and no training. Requesty is responsible for contracting with and remaining liable for those providers under its DPA. Adding a provider that is not named on this list remains a change requiring notice; changing models on an already named provider is not.
Changes and notices
The DPA provides at least 30 days' written notice before an intended addition or replacement. Every active Platform account receives the notice at its account email address. To correct an account email address, contact admin@inqelo.com.
Changelog:
- 23 August 2026: added CallTrackingMetrics and FoneDynamics as regional call-tracking Sub-processors for Inqelo-supplied tracking numbers.
- 5 August 2026: replaced the internal vendor-diligence matrix with a concise authorised list; corrected the Langfuse, ScrapingBee and Cloudflare agreement positions and legal entities; removed unresolved internal notes; and corrected provider retention and training statements.
- 4 August 2026: named the model hosting providers and stated that a change of model on a named provider is not a change to this list.
- 2 August 2026: initial public list.