Actual vendor register, services provided, data location, purpose, dates and notice of changes.
Notify Customer administrators of material new subprocessors where contract and law require and provide the applicable objection route.
| Role | Treatment |
|---|---|
| Noxtill subprocessor | Processes Customer Personal Data on Noxtill’s instructions; listed in DPA register. |
| Independent controller | Determines its own purposes for some data, e.g. Merchant of Record or platform provider in some flows. Disclose separately. |
| Customer-selected integration | Connected by customer; customer/provider terms may govern. Identify in Integrations UI. |
| Infrastructure provider | Cloud/database/storage/monitoring vendor; usually subprocessor where Customer Personal Data is involved. |
Noxtill should offer email/webhook subscription for subprocessor updates. The DPA should define a notice period and objection route for legitimate data-protection concerns.
An objection does not create a right to force Noxtill to operate without a technically necessary provider. Remedies may include reasonable alternatives or termination of the affected Service where required by the DPA.
