1. Purpose of This Page
This page lists the sub-processors Parakletos AI Limited (“Parakletos”) engages to provide the Vakyya Service. It is provided as part of Parakletos’s commitment to giving Customer organisations the visibility they need to complete their own data protection assessments and to discharge their obligations as data controllers.
This list is incorporated by reference into the Data Processing Agreement that Parakletos enters into with each Customer organisation, and into the Privacy Policy. Customer-specific variations, where any apply, are set out in the applicable Order Form or DPA.
A clear distinction is drawn throughout this page between:
- Service sub-processors, which may process Customer Content; and
- Business operations providers, which support Parakletos’s relationship with the Customer and the operation of Parakletos as a business and do not process Customer Content as part of their role.
2. Authorisation and Notification of Changes
Customer organisations provide general written authorisation for Parakletos to engage the sub-processors listed on this page, subject to the change-notification and objection rights set out in the Data Processing Agreement.
We maintain this page as our current list of authorised subprocessors. We will provide reasonable notice of material changes where required by our DPA or applicable law. Parakletos provides Customer organisations with not less than thirty days’ written notice before adding a new sub-processor, removing an existing sub-processor, or making a material change to the role or processing location of an existing sub-processor.
To subscribe to notifications of sub-processor changes, contact privacy@vakyya.com.
A Customer organisation may object to a new or changed sub-processor on reasonable data protection grounds, as set out in Section 7.3 of the Data Processing Agreement.
Where Parakletos engages a sub-processor, it imposes by contract data protection obligations equivalent in substance to those Parakletos owes to the Customer, and remains liable to the Customer for the acts and omissions of that sub-processor.
3. Service Sub-Processors
These sub-processors may process Customer Content as part of delivering the Vakyya Service.
3.1 Infrastructure
| Sub-Processor | Entity and Country of Establishment | Location of Processing | Role | Data Categories | Transfer Safeguard |
|---|---|---|---|---|---|
| Google Cloud EMEA Limited (Google Cloud Platform) | Ireland | United Kingdom (europe-west2, London) and Germany (europe-west3, Frankfurt) | Compute, storage, networking | All Customer Content; service telemetry; account and access data | UK/EU only; no restricted transfer intended for Customer Content. Support access may involve Google personnel outside the UK/EU under Google’s Cloud Data Processing Addendum, EU SCCs and UK Addendum where applicable. |
| Cloudflare, Inc. | United States | Cloudflare edge points of presence; TLS termination at the edge serving the Vakyya zone | Edge routing, DDoS protection, bot management, TLS termination | Request metadata; Customer Content in transit where traffic transits Cloudflare | UK IDTA / UK Addendum to EU SCCs |
3.2 AI Processing
These sub-processors provide third-party artificial intelligence capability used by the pipeline. Customer Content is not used by these providers to train or fine-tune their models. Parakletos does not instruct or permit such use, and Customer Content is not retained by these providers beyond the period required to return the response, except where the provider retains short-term operational logs for its own abuse monitoring and platform security.
| Sub-Processor | Entity and Country of Establishment | Location of Processing | Role | Transfer Safeguard |
|---|---|---|---|---|
| Google Cloud EMEA Limited (Vertex AI) | Ireland | UK (europe-west2) or Germany (europe-west3), per the Customer’s assigned region | Translation via Vertex AI Translation LLM and Cloud Translation NMT models, in the Customer’s assigned region | UK/EU only; no restricted transfer intended for Customer Content. |
The Service does not include any in-app conversational AI assistant, and does not transmit Customer Content to assistant-model providers (see Section 6).
3.3 Payments
| Sub-Processor | Entity and Country of Establishment | Location of Processing | Role | Data Categories | Transfer Safeguard |
|---|---|---|---|---|---|
| Stripe Payments Europe Limited (with Stripe, Inc. where strictly necessary) | Ireland; United States (where strictly necessary) | Ireland (EU); United States (where strictly necessary for card scheme processing and global fraud signals) | Card payment processing, invoice settlement, fraud prevention | Billing contact data; transaction records; card data (Parakletos does not see card numbers) | UK IDTA / UK Addendum to EU SCCs for restricted transfers |
3.4 Human Review and Specialist Linguistic Services (where contracted)
Where an Order Form provides for named-reviewer human review of transcripts, translations, or captions, the human reviewers contracted for that role are sub-processors. Human review is not enabled by default; it is added only where scoped in writing in the Order Form.
Reviewer details for a given engagement are disclosed in the Order Form, including:
- Identity of the reviewer (named individual or named agency).
- Country of operation and country of work performance.
- Languages covered.
- Scope of the review (transcript, translation, captioning, or any combination).
- Confidentiality and data protection obligations imposed on the reviewer, in all cases equivalent in substance to those in the DPA.
For all human review engagements, the following controls apply:
- Access is granted only to named individuals approved in the Order Form, on a least-privilege basis.
- Reviewers may not retain Customer Content locally beyond the period necessary to complete the review, and must certify return or deletion on completion.
- Reviewers may not upload, paste, or otherwise transmit Customer Content to any third-party translation, transcription, AI, storage, or collaboration tool (including but not limited to public LLM chat interfaces, public machine-translation websites, and consumer cloud storage) unless that tool is expressly authorised in the applicable Order Form.
4. Internal Processing Operated by Parakletos
The following processing is performed by Parakletos on infrastructure operated by Parakletos in the Customer’s assigned region. It is not sub-processing, and is described here for transparency.
| Function | Operated by | Location | Description |
|---|---|---|---|
| Speech-to-text | Parakletos | UK (europe-west2) or Germany (europe-west3), per the Customer’s assigned region | Whisper-family models, executed on Parakletos infrastructure. No Customer Content is sent to a third-party transcription provider. |
| Machine translation (open-source path) | Parakletos | UK (europe-west2) or Germany (europe-west3), per the Customer’s assigned region | Opus-MT / MarianMT models, executed on Parakletos infrastructure. Used for language pairs and quality tiers where the open-source path is selected. |
| Glossary preservation, captioning, and pipeline orchestration | Parakletos | UK (europe-west2) or Germany (europe-west3), per the Customer’s assigned region | Parakletos-developed processing applied to model outputs. |
The selection between the open-source path and the Vertex AI path for any given job is determined by language pair and quality tier, recorded in the audit log for that job, and made available to the Customer on request.
Each Customer environment is assigned a primary processing region in the applicable Order Form. Parakletos does not move Customer Content to another processing region except as expressly permitted by the DPA or the Order Form.
5. Business Operations Providers
These providers support Parakletos’s operation of the Vakyya business. They do not process Customer Content as part of their role, except where indicated.
| Provider | Entity and Country of Establishment | Location | Role | Data Categories |
|---|---|---|---|---|
| Resend, Inc. | United States | United States | Transactional and service-related email delivery, including booking and compliance-pack enquiry notifications to the Parakletos sales inbox | Authorised user email addresses; website enquiry contact details (name, work email, company, role, jurisdiction); service notification subject and body; delivery metadata |
| Calendly LLC | United States | United States | Meeting scheduling and booking services | Name, work email, role, and company name of prospective customers booking calls |
| Self-hosted error tracking (Sentry software) | United Kingdom (operated by Parakletos on Google Cloud) | United Kingdom | Application error tracking and stability monitoring | Application error reports, with PII scrubbing controls applied on capture |
| Vercel, Inc. | United States | Vercel global edge network (US entity; not constrained to a specific geography); transfer covered by UK International Data Transfer Addendum to the EU Standard Contractual Clauses | Hosting and delivery of the public Vakyya website (vakyya.com). Not used for the customer portal, API, or any Customer Content. Planned to be migrated to Google Cloud (europe-west2) and removed from this list at that time. | Website visitor request metadata (IP addresses, request headers); no Customer Content |
The Vakyya website does not currently operate any analytics product, first-party or third-party. If analytics is introduced in the future it will be a self-hosted, first-party platform operated by Parakletos in the United Kingdom, will be added to this table at that time, and will be set only after the visitor has provided consent through the cookie controls described in the Cookie Policy.
The transactional email and error-tracking services above are operated on Google Cloud (see Section 3.1). The public Vakyya website (vakyya.com) is currently hosted on Vercel (see row above).
Parakletos does not use Google Analytics, Google Tag Manager, Firebase Analytics, Meta Pixel, LinkedIn Insight Tag, TikTok Pixel, HubSpot, Salesforce, Intercom, Drift, Slack Connect, Microsoft Clarity, or any equivalent third-party analytics, customer-relationship, advertising, behavioural-tracking, or chat technology in the Service or on the Vakyya Website. Customer Content is not processed through any CRM, marketing automation, or advertising platform.
6. Providers Not Used for Customer Content Processing
The following providers are not used in the current Vakyya Service architecture. This list is provided for clarity in procurement conversations and is non-exhaustive.
- Anthropic, PBC (Claude API): Not used.
- OpenAI: Not used.
- Microsoft Azure OpenAI Service or Azure AI Translator: Not used.
- DeepL SE: Not used.
- Otter.ai, Fireflies.ai, Rev.com, Trint, AssemblyAI, or any third-party transcription API: Not used. Transcription is performed on Parakletos’s own infrastructure.
7. Onward Sub-Processors
Sub-processors listed above may themselves rely on further service providers to deliver their services, for example, Google Cloud is itself built on internal Google infrastructure, and Cloudflare relies on data-centre operators in the regions where it operates. These onward providers are addressed in the contracts Parakletos holds with the listed sub-processors. Where a Customer requires visibility into onward sub-processors for a specific sub-processor’s services, this can be addressed through the audit provisions of the Data Processing Agreement.
8. Access by Parakletos and Provider Personnel
Access to Customer Content by Parakletos personnel is restricted to authorised individuals with a documented business need (for example, to investigate a specific support incident raised by the Customer, or to respond to a security event). Access is least-privilege and is logged where technically available. Parakletos does not access Customer Content for product development, marketing, model training, or analytics purposes.
Sub-processor support personnel access Customer Content only in accordance with the relevant sub-processor’s published data processing terms, and only to the extent strictly necessary to deliver the relevant infrastructure or service.
9. Contact
To subscribe to sub-processor change notifications, to request further information about a specific sub-processor, or to raise an objection to a proposed change:
Email: privacy@vakyya.com
Postal:
Parakletos AI Limited
First Floor, 85 Great Portland Street
London W1W 7LT
United Kingdom
This Sub-Processors page was last updated on 29 May 2026.