Last updated: 5 May 2026 Effective date: 5 May 2026 Version: 1.0
AXL EdTech Booster LLC ("AXL") engages third-party service providers, known as Sub-Processors, to support the delivery of the AXL educational SaaS platform (the "Services"). This page lists those Sub-Processors and is incorporated by reference into the AXL Data Processing Addendum (https://admin.accelonline.io/docs/dpa/en).
Sub-Processors are categorised as:
Customer Data is hosted in Amazon Web Services data centres in Frankfurt, Germany (eu-central-1) within the European Economic Area. Backups are retained in the same AWS region.
Operational and support access by AXL personnel and contractors is restricted to the United States, the United Kingdom and Canada (the latter two being subject to European Commission adequacy decisions).
AXL provides at least thirty (30) days' notice of changes to this list. To subscribe to email notifications of changes, write to privacy@axl.tech with subject line "Subprocessor Updates Subscription".
Customers may object to a new Sub-Processor on reasonable data-protection grounds within fifteen (15) days of notification, in accordance with the Data Processing Addendum.
These Sub-Processors are engaged for all customers as part of the standard operation of the Services.
| Sub-Processor | Service | Categories of data | Location |
|---|---|---|---|
| Amazon Web Services EMEA SARL | Cloud infrastructure: ECS (compute), S3 (object storage), CloudFront (CDN), SQS (queues), CloudWatch (logs), Lambda, Route 53, ECR, KMS, EC2 | All categories of Customer Data, in transit and at rest | Frankfurt, Germany (eu-central-1) |
| Amazon Web Services EMEA SARL — Amazon RDS | Managed PostgreSQL — primary operational database | All operational Customer Data: users, courses, orders, CRM, settings | Frankfurt, Germany (eu-central-1) |
| Amazon Web Services EMEA SARL — Amazon ElastiCache | Managed Redis — caching, sessions, pub/sub, queues | Session and cache data, event payloads | Frankfurt, Germany (eu-central-1) |
| New Relic, Inc. | Application performance and error monitoring | Logs, traces, request metadata, error data | United States |
The Sub-Processors in this section are engaged only when a customer activates the corresponding feature or integration. Where a customer does not activate a feature, the corresponding Sub-Processor does not Process that customer's data.
| Sub-Processor | Purpose | Location |
|---|---|---|
| ElasticEmail Inc. | Transactional and marketing email delivery and webhooks | United States |
| Mailgun Technologies, Inc. | Transactional email delivery and webhooks | United States |
| Customer-provided SMTP | Customer-configured email sending | As determined by Customer |
Engaged only when activated by the customer:
Stripe, Inc.; PayPal, Inc.; Midtrans; Fondy; Square, Inc.; Authorize.Net; MercadoPago; CyberSource; BitPay; EcPay; SmartGlocal; Mobbex; ProntoPaga.
Categories of data: payment metadata, payer/order references, payment status. Card data is handled by the relevant gateway and is not retained by AXL outside gateway-issued tokens or references.
| Sub-Processor | Purpose | Location |
|---|---|---|
| Kinescope | Video upload, processing, hosting, playback and deletion | European Union |
| Google LLC — Translate API | Automatic translation of customer-supplied text | United States |
| Google LLC — Fonts | Web font delivery | United States |
| Google LLC — Safe Browsing | Unsafe-link/domain checks | United States |
| Google LLC — Calendar / Meet | Calendar event creation with Google Meet conference link | United States |
| Zoom Communications, Inc. | Creation/management of Zoom meetings and retrieval of recording metadata | United States (default; Customer may select Zoom data-residency options) |
| Firebase Cloud Messaging (Google LLC) | Web/mobile push notifications | United States |
| Expo (Exponent, Inc.) | Mobile push notifications | United States |
Engaged only when activated by the customer:
Telegram FZ-LLC / Telegram Messenger Inc.; Viber Media S.à r.l.; Meta Platforms, Inc. (Facebook, Instagram, Messenger, Conversions API); WhatsApp; LINE Corporation.
Engaged only when configured by the customer:
Google LLC (Google Analytics); Meta Platforms, Inc. (Conversions API).
| Sub-Processor | Purpose |
|---|---|
| Oopspam | Spam detection on inbound data |
| ipapi.co | IP-based geolocation enrichment |
| ApiLayer (Exchange Rate API) | Currency-conversion lookups |
Where Customer Data is transferred to a Sub-Processor located outside the European Economic Area, AXL relies on:
For questions about this list or sub-processor changes, contact privacy@axl.tech.
For privacy or data-protection enquiries within the European Union, the EU Representative of AXL is Prighter Group, Schellinggasse 3/10, 1010 Vienna, Austria — https://app.prighter.com/portal/18576877104.