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Verification open

Public procurement evidence · reviewed 4 September 2026

Sealkeep Subprocessor Register — public verification view

Status: Verification open; not yet an approved contractual register
Reviewed: 2026-09-04
Scope: Spala-selected hosted Sealkeep services only

This view intentionally exposes the current verification gap. It must not be treated as a completed DPA annex until each provider's production use, legal entity, location, transfer mechanism, contract, and deletion terms are verified.

Provider/service categoryIntended purpose and dataApplies toCurrent state
Cloudflare / R2 and web deliveryEncrypted archive objects, object keys/checksums; web request metadata where enabledManaged storage and public websiteProduct and current operations identify these services; contracting entity, locations, transfer terms, and deletion evidence remain to verify
Google servicesOptional Google sign-in; GCS migration fallback; optional customer-selected Google Drive is excluded when contracted directly by customerSelected hosted featuresImplementation identifies these services; exact production scope, legal entity, access locations, and transfer terms remain to verify
Transactional emailAccount verification and operational email: address, template content, delivery eventsHosted accountsImplementation references Postmark; production account and contracting entity remain to verify
Hosted application/database platformAccount, device, operational, billing, encrypted metadata, and request-log dataHosted serviceProduction infrastructure provider and locations remain to verify
Payment providerSubscription, invoice, tax, and payment administration; Sealkeep should not receive full card dataPaid hosted serviceAdd only after production billing configuration is verified
External support systemContact details, cases, attachments, and customer-supplied diagnosticsSupport, if externally operatedAdd only if support is not handled solely in Spala-controlled systems
Monitoring/error serviceRequest metadata, pseudonymous identifiers, and diagnostics; no transcript plaintext by designHosted service, if enabledAdd only after production configuration is verified

Not Spala Subprocessors in fully self-hosted operation

A provider selected, contracted, and controlled directly by the customer is not appointed by Spala merely because Sealkeep interoperates with it. This commonly includes the customer's:

If Spala selects, contracts, or can instruct a provider on the customer's behalf, its role must be reassessed and the applicable register updated.

Change process proposed for the signed DPA

  1. Review a provider before it receives production Customer Personal Data.
  2. Record entity, purpose, data, locations, retention, security, onward processors,

and transfer mechanism.

  1. Execute applicable Article 28 flow-down terms before production use.
  2. Provide at least 30 days' notice before adding an applicable Subprocessor.
  3. Accept reasonable data-protection objections within the agreed review window.
  4. Date the register when a provider begins or ends production use.

Verification and objections: privacy@spala.ai