Sub-Processors
Last Updated: October 3, 2026 · Propeter
Every third-party company Propeter engages to process hotel guest personal data on behalf of its hotel customers.
What Is a Sub-Processor?
A sub-processor is any third-party service provider that Propeter engages to process personal data on behalf of its hotel clients (the data controllers). Under GDPR Article 28, Propeter must disclose its sub-processors and impose equivalent data protection obligations on each one by written contract.
Propeter remains accountable to you, the data controller, for every sub-processor listed here. Sub-processors receive only the minimum data needed for their function and may not use it for their own purposes.
Current Approved Sub-Processors
Each sub-processor below is authorised under Annex 1 of the Propeter Data Processing Agreement and bound by a written data processing contract.
| Sub-processor | Purpose | Personal data processed | Location | Transfer mechanism |
|---|---|---|---|---|
| Twilio / SendGrid (sendgrid.com) | Transactional and marketing email delivered on the hotel controller’s instruction | Email addresses, email content, engagement metadata (opens, clicks) | United States | SCCs Module 2 (EU Commission Decision 2021/914) |
| Twilio Inc. (twilio.com) | SMS and WhatsApp messages (booking alerts, one-time passcodes, loyalty notifications) | Phone numbers, message content | United States | SCCs Module 2 |
| Google Firebase (firebase.google.com) | Push notifications and anonymised crash analytics for the Propeter guest app | Device tokens, notification content, anonymised app usage and crash data | United States / Global | SCCs Module 2; EU–US Data Privacy Framework |
| Windcave / Qvalent (windcave.com) | PCI DSS Level 1 certified payment processing for direct bookings | Transaction reference numbers only; Propeter does not store or access card numbers | Australia / New Zealand | APP 8 equivalent protections |
| Amazon Web Services (aws.amazon.com) | Primary cloud hosting, storage and compute | All personal data categories, encrypted at rest (AES-256) and in transit (TLS 1.3 minimum) | Asia Pacific (primary) / United States | SCCs Module 2; AWS DPA |
| mkng360.com | Marketing CRM and campaign delivery, only where the hotel controller enables the integration | Marketing contact data and campaign engagement data, as configured per controller | As configured per controller | DPA with mkng360.com |
Our Sub-Processor Commitments
Written contracts
Every sub-processor signs a data processing agreement with obligations at least equivalent to those in Propeter’s DPA with hotel clients.
30-day change notice
Propeter gives at least 30 days’ written notice before adding a sub-processor or materially changing an existing one.
Objection rights
Hotel clients may object to a new sub-processor within 14 days of notice on reasonable data protection grounds. Propeter will work to resolve objections before proceeding.
Data minimisation
Sub-processors receive only the personal data categories necessary for their specific function.
Lawful transfers
International transfers are covered by SCCs (Module 2), the EU–US Data Privacy Framework, the UK IDTA, or equivalent mechanisms for Australian data subjects.
Breach notification within 72 hours
If a breach involves sub-processor infrastructure, Propeter will notify affected hotel clients within 72 hours of becoming aware of it.
Data Transfer Mechanisms
Standard Contractual Clauses (SCCs), Module 2
The SCCs adopted in European Commission Decision 2021/914/EU govern transfers of EU personal data to Propeter sub-processors in the United States and other third countries. Governing law is Irish law; forum is the courts of Ireland.
EU–US Data Privacy Framework (DPF)
Where a US sub-processor participates in the DPF (as Google Firebase does), DPF certification is an additional transfer mechanism alongside SCCs.
Australian Privacy Principles (APP 8)
Personal data of Australian residents is disclosed to overseas sub-processors only where they maintain protections substantially equivalent to the APPs under the Privacy Act 1988 (Cth), or another APP 8.2 exception applies.
UK International Data Transfer Agreement (IDTA)
For UK data subjects, Propeter supplements SCCs with the ICO-approved UK IDTA. Hotel clients may request an executed IDTA from legal@propeter.com.
Frequently Asked Questions
What is the difference between Propeter as a processor and these sub-processors?
Your hotel (the controller) instructs Propeter (the processor) to process guest personal data. When Propeter engages a sub-processor, such as AWS for hosting or SendGrid for email, that sub-processor acts at Propeter’s direction, and Propeter remains contractually responsible to you for it.
Does Propeter train AI models on my guests’ personal data?
No. Propeter’s revenue management models are trained on aggregated, anonymised market patterns, not on individual guest personal data from any hotel client.
How do I object to a new sub-processor?
Send a written objection to legal@propeter.com within 14 days of the notice, on reasonable data protection grounds. If it cannot be resolved, you may terminate the affected services with 30 days’ notice, as set out in Section 4.4(c) of the DPA.
Is Propeter compliant with ISO 27001, ISO 9001, PCI DSS and SOC 2?
Yes. Propeter is ISO 27001, ISO 9001, PCI DSS and SOC 2 Type II compliant; the SOC 2 Type II report is available to customers under NDA. Customers can request the report from legal@propeter.com.
What happens to my guests’ data if I cancel?
Within 30 days of termination you may choose to receive all personal data in CSV or JSON, or have Propeter securely delete it within 90 days. Data that must be kept by law (for example, tax records) is held in isolation with no active processing.
Who do I contact?
legal@propeter.com, for sub-processor questions, executed DPAs, SCCs or Transfer Impact Assessment summaries. We respond to standard requests within 5 business days.