Subprocessors

We use third party subprocessors, such as cloud service providers and customer support software. We establish UK GDPR compliant data processing agreements with each subprocessor, extending Data Protection Act 2018 and UK GDPR safeguards everywhere personal data is processed.

The following is a list of subprocessors we use for internal Data Processing activities whereby ARKK is the Controller.

Sub-processor	Description	Location of data processed	Applicable ARKK Platform/Services
Guru UKDedicated Ltd, Acton House, Perdiswell Park, Worcester, England, WR3 7GD, UK	Guru host our SugarCRM platform, which is ARKK’s second Customer Relationship Management (CRM) solution. It also validates customer has the right to use the service.	Data residency is located within the UK.	Applicable to Regulatory, iXBRL, ESEF and Desktop Adapter.
SugarCRM 548 Market Street, PMB 59423, San Francisco, CA 94104-5401	SugarCRM platform, is ARKK’s Customer Relationship Management (CRM) solution. It also validates customer authentication to services permitted.	Data Residency within AWS EU West 2 region in London United Kingdom.	Applicable to Regulatory, iXBRL, ESEF and Desktop Adapter.
Adobe Systems Software Ireland Limited (Adobe Acrobat Sign) 4–6 Riverwalk, Citywest Business Campus, Dublin 24, Ireland (parent: Adobe Inc., 345 Park Avenue, San Jose, CA 95110, USA)	eSignature solution for electronic signing of agreements with clients and suppliers.	EU data centres (EU data residency) — Netherlands and Germany — EU/EEA Mechanism: Full UK adequacy — no transfer safeguard required. Adobe Inc. also holds EU-US Data Privacy Framework certification (UK-US Data Bridge) as a fallback for any US processing.	Applicable to clients signing contracts with ARKK.
Microsoft Limited Microsoft Campus Thames Valley Park Reading, Berkshire RG6 1WG	Microsoft Office 365 suite including email Exchange, SharePoint etc.	Data residency located in European Union.	Applicable to email exchange & administrative document storage in SharePoint.
Microsoft Limited / Anthropic Inc. (Claude LLM via Microsoft Copilot) Reading, Berkshire RG6 1WG, UK / San Francisco, USA	Claude LLM operating as a Microsoft sub-processor within M365 Copilot. Inference runs on AWS USA infrastructure. No ARKK tenant data is used for model training. A Transfer Risk Assessment has been completed.	AWS USA (inference only); M365 EU data boundary applies to storage Mechanism: Microsoft Enterprise DPA + Standard Contractual Clauses + UK-US Data Bridge (DPF)	Applicable to ARKK staff using M365 Copilot for internal work tasks.
Hubspot, Inc. 2 Canal Park, Cambridge, MA 02141 United States	Email communication platform enabling ARKK to communicate with prospects, and clients by providing product updates, and relevant marketing information.	Data residency located in the United States of America.	Applicable to all prospects, clients and platform users.
Zendesk Inc. 989 Market Street, San Francisco, CA 94103, USA	Customer support platform. Used to log and respond to all support-related enquiries.	EU data centres — Ireland and Netherlands Mechanism: EU-US Data Privacy Framework (DPF) + Standard Contractual Clauses	Applicable to all platforms and services.
Aircall SAS 14 Rue René Boulanger, 75010 Paris, France	VoIP, call recording, and Conversation Intelligence platform. Call recordings stored on AWS Frankfurt (EU). All AI-derived data (transcripts, summaries, sentiment scores, action items) stored exclusively on AWS Oregon, USA — covered by UK IDTA. A Transfer Risk Assessment has been completed (residual risk: Low).	Call recordings: AWS Frankfurt, Germany (EU/EEA) AI/analytics data: AWS Oregon, USA Mechanism (AI data): UK International Data Transfer Agreement (IDTA)	Applicable to ARKK sales and client support call operations.
Waydev Inc. USA 1007 North Orange Street #97, Wilmington, Delaware DE 19801, USA	Software development analytics platform. Processes individually attributed SDLC metrics (DORA metrics, PR activity, cycle time) for ARKK's engineering team.	AWS Oregon, USA Mechanism: UK International Data Transfer Agreement (IDTA)	Applicable to ARKK internal engineering and development operations.
Tabnine Ltd (Tabnine Inc.) 94 Yigal Alon Street, Tel Aviv 6789156, Israel	AI code-completion assistant providing developer code suggestions from ARKK source-code context. Ephemeral processing only — code snippets are discarded immediately after a suggestion is generated; no code is stored or used to train models (models trained solely on permissively licensed code). Deployed as a private EU VPC instance. Governed by an Enterprise Agreement and Data Processing Agreement including ephemeral-processing and no-code-storage terms.	Private EU VPC deployment — EU/EEA; ephemeral, code not retained. Vendor entities in Israel and the USA.	Applicable to ARKK software development / engineering (internal developer tooling).
Lempire SAS (lemlist) 7 rue Meyerbeer, 75009 Paris, France	B2B email outreach platform used for sales prospecting. A Legitimate Interests Assessment (LIA) has been completed. PECR compliance requirements apply for electronic marketing.	France — EU/EEA member state Mechanism: Full UK adequacy — no transfer safeguard required	Applicable to ARKK sales and marketing outreach activities.

The following list of subprocessors are used to provide Automation services to our customers. ARKK acts as the Processor and the client is the Controller when processing B2B customer personal data.

Sub-processor	Description	Location of data processed	Applicable ARKK Platform/Services
Microsoft Limited Microsoft Campus Thames Valley Park, Reading, Berkshire RG6 1WG, UK	Microsoft Office 365 suite including email Exchange, SharePoint etc.	Data residency located in the European Union.	Applicable to all platforms and services.
Microsoft Limited Microsoft Campus Thames Valley Park, Reading, Berkshire RG6 1WG, UK	Microsoft Azure is ARKK’s cloud service provider utilising platform as a service (PaaS) model. Hosting all products and services ARKK offers.	Data residency located in Republic of Ireland and Netherlands.	Applicable to all platforms and services.
Zendesk Inc. 989 Market Street, San Francisco, CA 94103, USA	Customer support platform. Used to log and respond to all support-related enquiries.	EU data centres — Ireland and Netherlands Mechanism: EU-US Data Privacy Framework (DPF) + Standard Contractual Clauses	Applicable to all platforms and services.
Atlassian - (Jira) Atlassian Pty Ltd Level 6 341 George St, Sydney, NSW 2000, Australia	The Development team use Jira from Atlassian for issue tracking. Jira also integrates with Freshdesk enabling customer support tickets to appear in Jira. Allowing the corresponding development team to resolve technical issues the client is facing. Tickets related to the Automation platform are only made available to the group of Developers in Jira who work on Automation platform.	Data residency located in Germany / Ireland due to ARKK’s user base in the EU.	Applicable to all platforms and services.
Userpilot, Inc. 2035 Sunset Lake Road, Newark, Delaware 19702, USA	Allows ARKK to gather usage data from our platforms in order to construct guides, walk throughs, and notifications. Also provides valuable data to inform product decisions, e.g. adoption of new features, what areas of the platform are causing issues etc.	Data residency Paris, France.	Applicable to Automation, Regulatory, iXBRL/ESEF platform.
MailJet 4, rue Jules Lefebvre 75009 Paris, France	MailJet integrates with ARKK's platform, which handles email communication to users such as outstanding activities, or registration email.	Data residency located in Frankfurt, Germany and Saint-Ghislain, Belgium.	Applicable to all platforms and services.

The following list of subprocessors are used to provide Regulatory Platform services to our customers. ARKK acts as the Processor when processing B2B customer personal data.

Sub-processor	Description	Location of data processed	Applicable ARKK Platform/Services
Guru UKDedicated Ltd, Acton House, Perdiswell Park, Worcester, England, WR3 7GD, UK	Guru host our SugarCRM platform, which is ARKK’s second Customer Relationship Management (CRM) solution. It also validates customer has the right to use the service.	Data residency is located within the UK.	Applicable to Regulatory, iXBRL, ESEF and Desktop Adapter.
SugarCRM 548 Market Street, PMB 59423, San Francisco, CA 94104-5401	SugarCRM platform, is ARKK’s Customer Relationship Management (CRM) solution. It also validates customer authentication to services permitted.	Data Residency within AWS EU West 2 region in London United Kingdom.	Applicable to Regulatory, iXBRL, ESEF and Desktop Adapter.
Microsoft Limited Microsoft Campus Thames Valley Park, Reading, Berkshire RG6 1WG, UK	Microsoft Office 365 suite including email Exchange, SharePoint etc.	Data residency located in the European Union.	Applicable to all platforms and services.
Microsoft Limited Microsoft Campus Thames Valley Park, Reading, Berkshire RG6 1WG, UK	Microsoft Azure is ARKK’s cloud service provider utilising platform as a service (PaaS) model. Hosting all products and services ARKK offers.	Data residency located in Republic of Ireland and Netherlands.	Applicable to all platforms and services.
Zendesk Inc. San Francisco, CA 94103, USA	Customer support platform. Used to log and respond to all support enquiries. Integrates with Atlassian Jira.	EU data centres — Ireland and Netherlands Mechanism: EU-US Data Privacy Framework (DPF) + Standard Contractual Clauses	Applicable to all platforms and services.
Atlassian - (Jira) Atlassian Pty Ltd Level 6 341 George St, Sydney, NSW 2000, Australia	The Development team use Jira from Atlassian for issue tracking. Jira also integrates with Freshdesk enabling customer support tickets to appear in Jira. Allowing the corresponding development team to resolve technical issues the client is facing. Tickets related to the Regulatory platform are only made available to the group of Developers in Jira who work on the Regulatory platform.	Data residency located in Germany / Ireland due to ARKK’s user base in the EU.	Applicable to all platforms and services.
Userpilot, Inc. 2035 Sunset Lake Road, Newark, Delaware 19702, USA	Allows ARKK to gather usage data from our platforms in order to construct guides, walk throughs, and notifications. Also provides valuable data to inform product decisions, e.g. adoption of new features, what areas of the platform are causing issues etc.	Data residency Paris, France.	Applicable to Automation, Regulatory, iXBRL/ESEF platform.
MailJet 4, rue Jules Lefebvre 75009 Paris, France	MailJet integrates with ARKK's platform, which handles email communication to users such as outstanding activities, or registration email.	Data residency located in Frankfurt, Germany and Saint-Ghislain, Belgium.	Applicable to all platforms and services.

The following list of subprocessors are used to provide iXBRL/ESEF tagging services (via cloud portal) to our customers. ARKK acts as the Processor when processing B2B customer personal data.

Sub-processor	Description	Location of data processed	Applicable ARKK Platform/Services
Guru UKDedicated Ltd, Acton House, Perdiswell Park, Worcester, England, WR3 7GD, UK	Guru host our SugarCRM platform, which is ARKK’s second Customer Relationship Management (CRM) solution. It also validates customer has the right to use the service.	Data residency is located within the UK.	Applicable to Regulatory, iXBRL, ESEF and Desktop Adapter.
SugarCRM 548 Market Street, PMB 59423, San Francisco, CA 94104-5401	SugarCRM platform, is ARKK’s Customer Relationship Management (CRM) solution. It also validates customer authentication to services permitted.	Data Residency within AWS EU West 2 region in London United Kingdom.	Applicable to Regulatory, iXBRL, ESEF and Desktop Adapter.
Microsoft Limited Microsoft Campus Thames Valley Park, Reading, Berkshire RG6 1WG, UK	Microsoft Office 365 suite including email Exchange, SharePoint etc.	Data residency located in the European Union.	Applicable to all platforms and services.
Microsoft Limited Microsoft Campus Thames Valley Park, Reading, Berkshire RG6 1WG, UK	Microsoft Azure is ARKK’s cloud service provider utilising platform as a service (PaaS) model. Hosting all products and services ARKK offers.	Data residency located in Republic of Ireland and Netherlands.	Applicable to all platforms and services.
Zendesk Inc. San Francisco, CA 94103, USA	Customer support platform. Used to log and respond to all support enquiries. Integrates with Atlassian Jira.	EU data centres — Ireland and Netherlands Mechanism: EU-US Data Privacy Framework (DPF) + Standard Contractual Clauses	Applicable to all platforms and services.
Atlassian - (Jira) Atlassian Pty Ltd Level 6 341 George St, Sydney, NSW 2000, Australia	The Development team use Jira from Atlassian for issue tracking. Jira also integrates with Freshdesk enabling customer support tickets to appear in Jira. Allowing the corresponding development team to resolve technical issues the client is facing. Tickets related to the iXBRL/ESEF platform are only made available to the group of Developers in Jira who work on the iXBRL/ESEF platform.	Data residency located in Germany / Ireland due to ARKK’s user base in the EU.	Applicable to all platforms and services.
Userpilot, Inc. 2035 Sunset Lake Road, Newark, Delaware 19702, USA	Allows ARKK to gather usage data from our platforms in order to construct guides, walk throughs, and notifications. Also provides valuable data to inform product decisions, e.g. adoption of new features, what areas of the platform are causing issues etc.	Data residency Paris, France.	Applicable to Automation, Regulatory, iXBRL/ESEF platform.
MailJet 4, rue Jules Lefebvre 75009 Paris, France	MailJet integrates with ARKK's platform, which handles email communication to users such as outstanding activities, or registration email.	Data residency located in Frankfurt, Germany and Saint-Ghislain, Belgium.	Applicable to all platforms and services.
N G & CO - NextGen 112, Shivlok House-II, Karampura Comm. Complex, New Delhi, 110015, India	NextGen (based in India) provides ARKK an outsourcing service for iXBRL, using ARKK’s iXBRL adapter in occasional instances when ARKK’s internal iXBRL team is over capacity.	Data residency located in Delhi, India (accessed & processed by NextGen).	Applicable only to iXBRL tagging service with the written agreement of the customer.

The following list of subprocessors are used to provide the Desktop Adapter to our customers. ARKK acts as the Processor when processing B2B customer personal data.

Sub-processor	Description	Location of data processed	Applicable ARKK Platform/Services
Guru UKDedicated Ltd, Acton House, Perdiswell Park, Worcester, England, WR3 7GD, UK	Guru host our SugarCRM platform, which is ARKK’s second Customer Relationship Management (CRM) solution. It also validates customer has the right to use the service.	Data residency is located within the UK.	Applicable to Regulatory, iXBRL, ESEF and Desktop Adapter.
SugarCRM 548 Market Street, PMB 59423, San Francisco, CA 94104-5401	SugarCRM platform, is ARKK’s Customer Relationship Management (CRM) solution. It also validates customer authentication to services permitted.	Data Residency within AWS EU West 2 region in London United Kingdom.	Applicable to Regulatory, iXBRL, ESEF and Desktop Adapter.
Microsoft Limited Microsoft Campus Thames Valley Park, Reading, Berkshire RG6 1WG, UK	Microsoft Office 365 suite including email Exchange, SharePoint etc.	Data residency located in the European Union.	Applicable to all platforms and services.
Zendesk Inc. San Francisco, CA 94103, USA	Customer support platform. Used to log and respond to all support enquiries.	EU data centres — Ireland and Netherlands Mechanism: EU-US DPF + Standard Contractual Clauses	Applicable to all platforms and services.
Atlassian - (Jira) Atlassian Pty Ltd Level 6 341 George St, Sydney, NSW 2000, Australia	The Development team use Jira from Atlassian for issue tracking. Jira also integrates with Freshdesk enabling customer support tickets to appear in Jira. Allowing the corresponding development team to resolve technical issues the client is facing. Tickets related to the Desktop Adapter are only made available to the group of Developers in Jira who work on the Desktop Adapter.	Data residency located in Germany / Ireland due to ARKK’s user base in the EU.	Applicable to all platforms and services.
MailJet 4, rue Jules Lefebvre 75009 Paris, France	MailJet integrates with ARKK's platform, which handles email communication to users such as outstanding activities, or registration email.	Data residency located in Frankfurt, Germany and Saint-Ghislain, Belgium.	Applicable to all platforms and services.
SoftwareKey 1319 Green Forest Ct Suite 406, Winter Garden, FL 34787 USA	SoloServer from SoftwareKey is a third-party tool ARKK use to create and validate desktop licenses for our desktop software. ARKK’s desktop software/adapters installed on the customers local workstations, communicates with SoloServer to activate the licenses.	Data residency located in the United States of America.	Applicable only to the Desktop Adapter.

Subprocessors

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