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Sub-processors & Data Flows

Last updated: November 2025

Max Raschke avatar
Written by Max Raschke
Updated this week

Why transparency matters

Our customers entrust us with their most valuable data – projects, tasks, teams, and ideas.

That’s why we believe you should always know who processes your data and where it happens.

All sub-processors are carefully vetted, contractually bound under Art. 28 GDPR, and regularly audited.

Our current sub-processors

Provider

Purpose

Location of processing

Safeguards

Microsoft Azure (Germany)

Hosting & infrastructure for awork

Germany (Frankfurt & Berlin)

DPA with Microsoft, ISO 27001 / SOC 2 / BSI C5 certified, encryption at rest & in transit

Microsoft Azure Front Door / CDN

Global content delivery for performance & protection

EU; technically short-term worldwide for non-EU access

Data residency guarantee, SCC/DPF safeguards, no content storage

Microsoft Azure OpenAI (EU)

Optional AI features (e.g. text generation & automation)

EU (Sweden Central)

No data transfer outside EU, no AI training on customer data, DPA with Microsoft

Twilio Segment

Event forwarding / technical analytics for support

EU / USA

DPA + SCC + DPF certification, data minimization, encrypted transfer

Intercom Inc.

In-app support, help center & system notifications

USA

DPA + SCC + DPF certification, ISO 27001 / SOC 2, TLS encryption

Birdie (Philo Labs, France)

Bug-reporting tool for issue tracking

France (EU)

DPA with EU-only processing, no third-country transfer, automatic deletion after 90 days

How we conduct audits and reviews

The audit approach depends on each sub-processor’s size and structure:

  • For large global cloud providers (e.g. Microsoft, Twilio, Intercom), traditional on-site audits aren’t feasible.

    We rely on:

    • regularly published third-party audit reports (e.g. SOC 2, ISO 27001, BSI C5

    • contractual transparency and audit clauses in their DPAs

    • independent certifications renewed annually

  • For smaller or EU-based sub-processors (e.g. Birdie), we perform our own checks – including document reviews, questionnaires, and security attestations under Art. 28 (3) h GDPR.

This hybrid model provides realistic, risk-based assurance without compromising data protection or service reliability.

Vetting & approval process

Before engaging a new sub-processor, we perform a Privacy & Security Assessment covering:

  • review of technical and organizational measures,

  • verification of legal safeguards (DPA, SCC or DPF),

  • joint approval by COO and CTO,

  • annual review and re-assessment.

We update our list regularly and notify customers at least 6 weeks in advance of any changes, with a right to object under Art. 28 (2) GDPR.

Why customers can’t opt out of existing sub-processors

We understand this is a sensitive topic – that’s why we want to be transparent about it.

Some providers (e.g. Microsoft Azure or Intercom) are integral to our technical infrastructure.

Excluding individual sub-processors would affect core functionality or overall system security.

Under GDPR, customers are notified of new sub-processors and have the right to object within a defined timeframe.

This right does not apply to existing sub-processors, as they form part of the agreed service scope.

When we add new sub-processors, this is typically to enable or enhance a specific feature.

These providers process only strictly limited data necessary for that feature to function – such as technical metadata or communication-related information.

Instead of an individual opt-out, awork provides customers with a special termination right if they fundamentally disagree with the use of a new sub-processor.

This ensures full transparency and freedom of choice without compromising technical or security integrity.

All our sub-processors – whether new or long-standing – adhere to the same strict security and privacy standards, verified through our Information Security Management System (ISMS).

Data flow at a glance

  • All customer data is stored in Germany (Azure Germany).

  • Support and communication data may flow through Intercom (USA) when using chat or help features.

  • Event data may be relayed via Twilio Segment to Intercom for context.

  • Bug reports are sent voluntarily via Birdie (France).

  • The AI feature (Azure OpenAI) is optional, EU-only, and never uses customer data for training.

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