Legal
Sub-processor Register
Current, version-controlled register · referenced by the Standard Data Processing Agreement
Company details updated: 25 September 2026
This is the register the Standard Data Processing Agreement refers to as the Sub-processor Register: the current, version-controlled overview of the sub-processors omniday ApS (CVR 46730186) uses to process Customer Personal Data. Only providers and features actually used for the Customer process the Customer's data. Location and the GDPR Chapter V transfer basis are stated per provider; upon request, Omniday makes documentation of the transfer basis available, subject to necessary redaction of confidential information.
| Provider | Purpose | Location | Transfer basis |
|---|---|---|---|
| Microsoft Ireland Operations Limited (Microsoft Azure) | Cloud services: hosting, data storage, key management and identity; AI services, including language, speech and vectorisation; operational and security logging as well as quality and error monitoring. | EU: Azure regions within the EU. AI services run in Azure regions within the EU. | EU processing; Microsoft Products and Services Data Protection Addendum incl. EU Standard Contractual Clauses where applicable |
| Twilio Inc. and its affiliates | Communication services, including e-mail delivery and telephony (phone numbers and calls), where the Customer activates the feature. | EU data residency is used for Customer Data where available; any transfer outside the EU/EEA is based on the EU standard contractual clauses. | EU data residency for Customer Data where available; EU Standard Contractual Clauses for any transfer outside the EU/EEA |
| Eleven Labs Inc. (ElevenLabs) | AI telephony: speech recognition, speech synthesis and conversation handling, including the language models ElevenLabs makes available, where the Customer activates the phone feature. ElevenLabs does not record call audio and is configured not to retain call data after the call. ElevenLabs’ own sub-processors, including providers of language models, are listed at compliance.elevenlabs.io. | USA, and the locations of ElevenLabs’ own sub-processors. Transfers are based on the EU-U.S. Data Privacy Framework and otherwise on the EU standard contractual clauses in ElevenLabs’ data processing addendum. | EU-U.S. Data Privacy Framework (EU Commission adequacy decision, GDPR Art. 45), under which ElevenLabs states it is certified; EU Standard Contractual Clauses in ElevenLabs’ data processing addendum as fallback |
Integrations with the Customer's own systems
INTEGRATIONS WITH THE CUSTOMER’S OWN SYSTEMS
Where the Customer connects the platform to a system the Customer itself has an agreement with — for example its own booking or case-management system — and access takes place using credentials issued within the Customer’s own customer relationship, the provider of that system is not a sub-processor under this DPA. In that case, Omniday merely transmits data to and from the system on the Customer’s instructions, and the Customer’s own agreement with the provider governs the processing there.
Where Omniday itself engages a provider as part of the service, the provider is added to the Sub-processor Register in accordance with Section 7 before processing begins.
How changes to this register are notified
Changes follow Section 7 of the Standard Data Processing Agreement, which provides:
Omniday notifies the Customer’s account administrator at least 14 days before a planned addition or replacement. The Customer may raise a reasoned objection within that period. The parties will first seek a reasonable solution; if this is not possible, the Customer may deactivate the affected feature or terminate the affected service before the change takes effect.
Customers are notified directly by e-mail — notices are sent to the Customer's account administrator.
Changelog
| Date | Change | Effective date | DPA version |
|---|---|---|---|
| 2026-08-05 | Register created with the initial sub-processor list. | 2026-08-05 | standard-1.0-en |
| 2026-10-12 | Microsoft and Twilio entries described by service area rather than by individual features: Microsoft Azure cloud services, including AI speech services, in Azure regions within the EU; Twilio communication services, including e-mail delivery and telephony (phone numbers and calls), provided by Twilio Inc. and its affiliates. No provider added or removed. | 2026-10-12 | standard-1.2-en |
| 2026-10-21 | Eleven Labs Inc. (ElevenLabs) added for AI telephony — speech recognition, speech synthesis and conversation handling, including the language models ElevenLabs makes available — where the Customer activates the phone feature. ElevenLabs does not record call audio and is configured not to retain call data after the call; its own sub-processors, including providers of language models, are listed at compliance.elevenlabs.io. Notice before a planned addition or replacement is 14 days from DPA v1.3. | 2026-10-21 | standard-1.3-en |