Subprocessors

Transparent publication in accordance with Art. 28.2 and 28.4 GDPR

Version: 2026.1 (annex revision 2026-08-11)

Last updated: 11 augustus 2026

Publication URL: id2bytes.com/subprocessors

DPA Annex: Bijlage B

📢 Notification of Changes
ID2Bytes® informs clients at least 30 days in advance when adding new subprocessors or changes in processing location. Clients have the right to object within this period.

10 Total Subprocessors

10 Actively Used

9 Categories

30 Days Objection Period

📊 Overview All Subprocessors

Subprocessor	Category	Location	International Transfer
Microsoft Azure	Cloud Infrastructure	EU (primary)	Possibly US (DPF + SCCs)
Azure OpenAI	AI Model Provider	EU (primary)	DPF + SCCs
Mollie	Payment Processing	NL/EU	None (EU only)
Microsoft 365	Communication	EU (primary)	DPF + SCCs
Your Hosting B.V.	Hosting & Email	NL	None, EEA (data processing agreement art. 3.1)
Mailchimp	Marketing	US/EU	DPF + SCCs + EU option
Application Insights	Monitoring	EU	None (EU only)
Google Analytics	Monitoring	EU/US	DPF + SCCs
GitHub	Development	US/EU	DPF + SCCs
Azure Backup	Backup & DR	EU	None (EU only)

Subprocessor

⚠️ Submit Objection

If you object to a (new) subprocessor, you can contact us within 30 days of notification:

Email: privacy@id2bytes.com

Phone: +31 (0)6 52 21 51 59

Deadline: Within 30 days of notification of change

In case of a valid objection, parties will consult on alternatives. Possible alternatives include EU-only infrastructure, other subprocessors, or on-premise solutions.

📋 Change History

Version	Date	Changes
Annex B rev. 2026-08-11	11 augustus 2026	Removed: OpenAI, Anthropic, Cloudflare, Zendesk, HubSpot Added: Your Hosting B.V. (hosted mailboxes for a client domain) Reason: The list has been reconciled again against the suppliers currently in actual use. The removed parties are not used; Your Hosting was missing while ID2Bytes acts as processor for that service. This does not change the version number of the Data Processing Agreement (2026.1) - as of this revision, each annex carries its own revision date.
2025.2	22 november 2025	Removed: Amazon Web Services (AWS), Google Cloud Platform (GCP), Stripe Added: Mailchimp (email marketing) Reason: ID2Bytes uses exclusively Microsoft Azure for cloud infrastructure and Mollie for payments
2025.1	22 november 2025	Initial version with 13 subprocessors (cloud, AI, payment, communication, monitoring)

Version

Date

Changes

Annex B rev. 2026-08-11

11 augustus 2026

Removed: OpenAI, Anthropic, Cloudflare, Zendesk, HubSpot
Added: Your Hosting B.V. (hosted mailboxes for a client domain)
Reason: The list has been reconciled again against the suppliers currently in actual use. The removed parties are not used; Your Hosting was missing while ID2Bytes acts as processor for that service. This does not change the version number of the Data Processing Agreement (2026.1) - as of this revision, each annex carries its own revision date.

2025.2

22 november 2025

Removed: Amazon Web Services (AWS), Google Cloud Platform (GCP), Stripe
Added: Mailchimp (email marketing)
Reason: ID2Bytes uses exclusively Microsoft Azure for cloud infrastructure and Mollie for payments

2025.1

22 november 2025

Initial version with 13 subprocessors (cloud, AI, payment, communication, monitoring)

📢 Future Changes
All changes to this list will be communicated to clients 30 days in advance via email to the registered contact address. Clients have the right to object within this period in accordance with DPA Article 7.4.

📞 Contact

Questions about Subprocessors

Email: privacy@id2bytes.com

Phone: +31 (0)6 52 21 51 59

We will answer your questions within 10 business days.