Sub-Processor List

TheWILL.ai uses the following third-party sub-processors to provide our services. The services covered are every site the same operator runs: TheWILL.ai (estate planning), Expat183 (tracking the days you spend in each country) and Orchard72 (portfolio tracking); one list covers them all. This list is maintained in accordance with our obligations under GDPR Article 28 and is referenced from our Privacy Policy.

About our sub-processors: We use standard Data Processing Agreements (DPAs) provided by each vendor. These are large, established companies with robust data protection practices. Many of our sub-processors maintain independent security certifications (such as ISO 27001 or SOC 2); the certifications held by a specific sub-processor are available on request. International data transfers are protected by Standard Contractual Clauses (SCCs) with the UK International Data Transfer Addendum where applicable, and the EU-US Data Privacy Framework where vendors are certified.

Infrastructure & Platform Sub-Processors

Sub-Processor	Purpose	Data Processed	Location	Transfer Mechanism
Cloudflare, Inc.	CDN, R2 object storage, Workers (serverless compute), DNS, DDoS protection	All platform data in transit, stored documents and recordings, static assets	Stored data: European Union (Cloudflare R2 EU jurisdiction). CDN, DNS and DDoS protection: global edge network	SCCs + UK Addendum; EU-US DPF certified
MaxMind, Inc.	IP geolocation for regional pricing, EU VAT evidence, and device-trust scoring for login-activity security monitoring	IP addresses, IP-derived geographic location (country, region, and city). Local MaxMind GeoLite2-City database (no data transfer to MaxMind)	Local database (no transfer)	None (local DB lookup only)
netcup GmbH	Virtual server hosting for our self-hosted community forum (Discourse) at community.thewill.ai	Forum user accounts, posts and replies, session data, server access logs (including IP addresses)	Germany (EU)	Intra-EU (no transfer mechanism required); UK adequacy decision for UK data subjects

Consultation & Communication Sub-Processors

Sub-Processor	Purpose	Data Processed	Location	Transfer Mechanism
Daily.co (Daily, Inc.)	Video conferencing infrastructure for consultations	Video/audio streams, connection metadata, call duration	US (EU media servers available)	SCCs + UK Addendum
Deepgram, Inc.	Speech-to-text transcription of a consultation, used only where the consultation is recorded with the agreement of everyone taking part	Consultation audio and the transcript produced from it. Audio is processed solely to produce the transcript, is contractually not used to train the provider's models, and is deleted after processing	US	SCCs + UK Addendum
Brevo SAS	Transactional and marketing email delivery (primary provider). Also carries outbound will-file disclosure requests that a legal professional asks us to send to a firm outside the platform, and that firm's reply notifications	Email addresses, names, email content. For an outbound disclosure request this includes the correspondence details of a receiving firm that holds no account with us, and the details of a person who has died that the requesting professional supplies. The request itself never carries an attached file	EU (France)	Intra-EU (no transfer mechanism required)
Twilio SendGrid (Twilio Inc.)	Transactional email delivery: automatic failover used when our primary email provider is unavailable, so that account, security, and notification emails are delivered reliably	Email addresses, names, email content (including one-time verification codes and notification content). Where failover is in use this extends to outbound will-file disclosure requests, so the correspondence details of a receiving firm that holds no account with us may be processed in the United States under the transfer mechanism named alongside	United States	SCCs + UK Addendum; EU-US DPF certified
Google LLC (Firebase Cloud Messaging)	Delivery of push notifications to our iOS and Android apps (for example appointment updates and reminders, document expiry alerts and sign-in approvals). On iPhone, Google hands the notification to Apple's push notification service for delivery. You can turn push notifications off in your notification settings	Device push tokens, the notification title and short message, and a link to the relevant screen in the app. Appointment notification text is generic and never names the other person taking part	United States	SCCs + UK Addendum; EU-US DPF certified

AI & Processing Sub-Processors

Our own AI, on our own servers, is the default. Every AI task below starts on infrastructure we run ourselves. Your data never leaves our servers without your approval: there is no automatic fallback to a commercial provider, so if our own AI is unavailable we wait, retry, or tell you it failed rather than quietly sending your document somewhere else.

A provider in the table below receives your content in only two situations: where the task carries no personal data at all (anonymised drafting text, or a public ticker symbol), or where you have given explicit consent for one named document after seeing the result our own AI produced. That consent is recorded, covers that document only, and can be withheld with no loss of the feature.

Calendar Integration Sub-Processors

These providers process data only if you choose to connect your personal calendar (an optional feature you can disconnect at any time). When connected, we read busy/availability windows and write the appointments, will milestones and scheduled dates you create in TheWILL.ai to the calendar account you authorise. A generic CalDAV server you connect (for example Fastmail, Nextcloud, or a self-hosted server) is your own infrastructure, not a TheWILL.ai sub-processor: calendar data syncs directly between TheWILL.ai and the server you name.

Sub-Processor	Purpose	Data Processed	Location	Transfer Mechanism
Google LLC (Google Calendar)	Two-way calendar sync if you connect a Google Calendar account	Calendar event details (titles, times, descriptions, attendee names) for appointments, will milestones and scheduled dates; availability windows read for conflict checks	United States	SCCs + UK Addendum; EU-US DPF certified
Microsoft Corporation (Outlook Calendar)	Two-way calendar sync if you connect a Microsoft Outlook account	Calendar event details (titles, times, descriptions, attendee names) for appointments, will milestones and scheduled dates; availability windows read for conflict checks	United States	SCCs + UK Addendum; EU-US DPF certified
Zoho Corporation	Two-way calendar sync if you connect a Zoho Calendar account	Calendar event details (titles, times, descriptions, attendee names) for appointments, will milestones and scheduled dates; availability windows read for conflict checks	Data centre you select when connecting (United States, Europe, India or Australia)	SCCs + UK Addendum (not required where you select the EU data centre)
Yahoo Inc. (Yahoo Calendar)	Two-way calendar sync if you connect a Yahoo Calendar account	Calendar event details (titles, times, descriptions, attendee names) for appointments, will milestones and scheduled dates; availability windows read for conflict checks	United States	SCCs + UK Addendum
Apple Inc. (iCloud Calendar)	Two-way calendar sync if you connect an iCloud calendar with an app-specific password	Calendar event details (titles, times, descriptions, attendee names) for appointments, will milestones and scheduled dates; availability windows read for conflict checks	United States	SCCs + UK Addendum; EU-US DPF certified

Practice Integrations (Not Sub-Processors)

A legal professional can connect their practice's own Xero accounting, Clio practice management, Microsoft Outlook mail or Gmail account toTheWILL.ai. Those providers are not listed on this page because they are the practice's own suppliers, engaged under the practice's own terms, and we do not use them to process anyone's data for us. Each connection is read-only: it brings the practice's own records in for that practice alone to see and sends none of our users' data out, unlike calendar sync above, which writes to the provider and is therefore listed. A Clio connection copies the practice's Clio contacts and matters into its own clients and matters in TheWILL.ai and never writes anything back to Clio. These connections are being introduced and remain unavailable until they are switched on.

Analytics Sub-Processors

Sub-Processor	Purpose	Data Processed	Location	Transfer Mechanism
Google LLC (Google Analytics)	Analytics and website usage tracking (with user consent for analytics cookies)	IP address (anonymised), page views, session duration, browser/device information, conversion events	United States	EU-US Data Privacy Framework; SCCs + UK International Data Transfer Addendum

Market Data & News Sub-Processors

Sub-Processor	Purpose	Data Processed	Location	Transfer Mechanism
CityFALCON Limited	Premium market intelligence: financial news, sentiment, regulatory filings, insider transactions and investor-relations documents for the securities you hold or track	Public ticker symbols / security identifiers only (for example, AAPL). No personal data, account details or holding quantities are sent; none of the returned content is stored in our database	United Kingdom	UK-based processor, so no restricted international transfer; subject to a standard Data Processing Agreement

Payment & Financial Sub-Processors

Sub-Processor	Purpose	Data Processed	Location	Transfer Mechanism
Stripe, Inc.	Payment processing, subscription billing, invoicing, revenue share via Stripe Connect, automated VAT/GST calculation via Stripe Tax	Payment card details (PCI DSS compliant), billing addresses, transaction records, professional bank details, revenue share calculations, tax calculation data	US / EU (data stored in region of customer)	SCCs + UK Addendum; EU-US DPF certified
Apple Inc.	iOS in-app purchase processing for subscriptions and one-time products	Transaction receipts, subscription status, Apple account identifier, device identifiers	US	SCCs + UK Addendum; EU-US DPF certified
Google LLC (Google Play)	Android in-app purchase processing for subscriptions and one-time products	Purchase tokens, subscription status, Google account identifier, device identifiers	US	SCCs + UK Addendum; EU-US DPF certified

Professional-to-professional referral fees are settled directly between the two professionals off the platform; we do not hold or remit those funds, so no additional sub-processor is involved. The platform's own referral service fee is invoiced through Stripe (listed above), so the referral feature introduces no sub-processor beyond those already named on this page.

Security & Operations Sub-Processors

Sub-Processor	Purpose	Data Processed	Location	Transfer Mechanism
Infisical, Inc.	Secrets management (API keys, credentials)	Encrypted secrets only (no personal data)	EU	Intra-EU (no transfer mechanism required)
Twilio Inc.	SMS-based multi-factor authentication and phone-number verification via the Twilio Verify service, when you choose SMS as a second factor or verify a mobile number on your account; appointment text messages (reminders and reconfirmations) and receipt of STOP / START replies to them.	Mobile phone numbers; one-time verification codes (short-lived, expire within minutes); appointment message content and your replies; delivery status metadata (success, failure, carrier)	United States (global SMS carrier routing)	SCCs + UK Addendum; EU-US DPF certified. Verification codes are not retained by us once verified or expired; phone numbers are retained for the lifetime of the verified factor (see Privacy Policy retention schedule).
Telnyx LLC	The same SMS messages as Twilio (verification codes and appointment text messages) for destinations where Telnyx is our primary route, with Twilio as backup; receipt of STOP / START replies to appointment texts.	Mobile phone numbers; message content and your replies; delivery status metadata (success, failure, carrier)	United States (global SMS carrier routing)	SCCs + UK Addendum. A number that replies STOP is recorded by us only as a one-way fingerprint so that we stop texting it.

Error monitoring and performance tracking are handled by a self-hosted GlitchTip instance running on our own infrastructure. Error data is not transmitted to any third-party error-tracking provider.

Development & Support Tooling Sub-Processors

The following sub-processors support our in-app feedback tool, which is available only in our development and staging environments and is not enabled in production.

Sub-Processor	Purpose	Data Processed	Location	Transfer Mechanism
GitHub, Inc.	Issue tracking for in-app feedback. Each submission creates a GitHub issue so our team can triage and resolve it (development and staging only)	Feedback text, the reporter's email address, recent in-app activity logs, and any screenshots the reporter chooses to attach	United States	SCCs + UK Addendum; EU-US DPF certified. Feedback issues are retained for as long as needed to investigate and resolve the report and are not subject to an automatic deletion schedule.
Cloudflare, Inc. (R2 feedback-screenshot storage)	Hosting of screenshots attached to in-app feedback so they can be embedded in the corresponding GitHub issue (development and staging only)	Screenshot images attached by the reporter, which may contain whatever was visible on screen at the moment of capture	Western Europe (Cloudflare R2 location hint; not restricted to the EU jurisdiction)	SCCs + UK Addendum; EU-US DPF certified. Screenshots are served through a public storage URL and are not currently subject to an automatic deletion schedule; reporters are warned not to capture sensitive information into a feedback screenshot.

Changes to This List

We will update this sub-processor list when we add or remove sub-processors. Material changes will be communicated in accordance with our Privacy Policy. If you have concerns about a sub-processor, please contact us using the contact form available on our platform.