Version 1.0 — effective 10 September 2026
Sub-processors
This page lists the third parties that process personal data on MClimate's behalf when we provide the Cloud Services. It forms Annex 2 to our Data Processing Agreement and is incorporated into it by reference.
Where a sub-processor is established outside the European Economic Area, the transfer basis is stated. The Cloud Services themselves are hosted entirely within the EEA: all databases, backups and object storage are in AWS Europe (Frankfurt, eu-central-1), and the LoRaWAN Network Server instance operated by MClimate runs on The Things Stack Cloud eu1 in Ireland.
What this page covers, and what it does not
This page lists third parties that process personal data on a customer's behalf, where MClimate acts as processor in delivering the Cloud Services.
It does not list the suppliers MClimate uses to run its own business — accounting and invoicing, payment processing, sales and marketing, the webstore, and the administration of the commercial relationship itself. For that processing MClimate is the controller in its own right, it is not carried out on any customer's behalf, and it is described in our Privacy Policy instead.
Nor does it list a LoRaWAN Network Server that you operate or procure yourself — see the foot of this page.
How we notify changes
We give customers at least fifteen (15) days' notice before a new sub-processor begins processing customer personal data, by updating this page. Customers may object on reasonable data protection grounds within that period. Where an objection cannot be resolved, the customer may terminate the affected Cloud Services without penalty.
Exceptionally, where a sub-processor must be engaged immediately to preserve the security, integrity or continuity of the Cloud Services, we may do so and give notice as soon as practicable afterwards. The right to object and to terminate is unaffected.
To be notified of changes, contact privacy@mclimate.eu.
Established in the European Economic Area
No transfer mechanism is required for these sub-processors.
| Sub-processor | Purpose | Location |
| Amazon Web Services EMEA SARL | Cloud infrastructure hosting the Enterprise platform, including all databases, backups and object storage | AWS Europe (Frankfurt), eu-central-1 |
| The Things Industries B.V. | LoRaWAN Network Server instance operated by MClimate, where a building or device group is subscribed to it | The Things Stack Cloud eu1 — Ireland |
| KUDZU TECHNOLOGIES P.C. | LoRaWAN network analytics | EU |
| Odoo S.A. | Helpdesk. Support tickets can contain device identifiers, building and space labels, and user details submitted by the customer | EU |
| Google Cloud EMEA Limited | Google Workspace. Support correspondence and attachments can contain customer data | EEA |
| Cloud Office EOOD | Administers the Google Workspace tenant on MClimate's behalf, and therefore holds administrative access to the support mailboxes and files described above | Bulgaria / EEA |
Outside the EEA — transfer under an adequacy decision
| Sub-processor | Purpose | Transfer basis |
| monday.com Ltd | Product-returns tracking. Records are largely company-level, but customer correspondence may appear in attachments | EU adequacy decision for Israel (Commission Decision 2011/61/EU, reaffirmed by the European Commission in January 2024). No Standard Contractual Clauses are required |
Outside the EEA — transfer under Standard Contractual Clauses
| Sub-processor | Purpose | Transfer basis |
| Anthropic, PBC | AI assistance applied to support tickets and related records | Standard Contractual Clauses (Modules Two and Three) under Anthropic's Data Processing Addendum, together with the UK and Swiss addenda. Customer data is not used to train models |
| Fireflies.AI Corp. | Transcription of support and technical calls with customers | Standard Contractual Clauses (processor-to-processor) under Fireflies' Data Processing Addendum |
What is not a sub-processor
A LoRaWAN Network Server that you operate or procure yourself is not our sub-processor. Where you connect your own network server to the Cloud Services — whether operated by you, by a network operator such as Actility or Netmore, by your own The Things Network account, or on your own ChirpStack instance — that server is your infrastructure or your own processor, and it is outside this list. Only the network server instance operated by MClimate, listed above, is a sub-processor of ours.
The MClimate webstore is operated separately from the Cloud Services. Purchases made there are MClimate’s own customer relationship rather than processing on any customer’s behalf, so the webstore and its providers are covered by our Privacy Policy, not by this page.
Questions about this page: privacy@mclimate.eu