Sub-processor Schedule — Version 1.0

1. Authorisation model

The Renew Gas Cert Data Processing Schedule v1.1 uses general written authorisation for sub-processors.

Before adding or materially replacing a sub-processor that will process customer-controlled personal data, EvenAI will provide reasonable advance notice and an opportunity to object on reasonable data-protection grounds, subject to the urgent security, legal or service-continuity exception described in the Data Processing Schedule.

2. Current sub-processors

Cloudflare, Inc.

Function: application runtime and database/storage through Cloudflare Workers and D1.

Customer-controlled data potentially processed: tenant users; client/contact information; site/address information; certificate/renewal records; reminder preferences and communication-status metadata; tenant/internal identifiers.

Current D1 hosting position: the production database has no jurisdiction restriction and is running in Cloudflare's ENAM — Eastern North America region, with read replication disabled. Renew does not claim UK or EU D1 residency.

Plus Five Five, Inc. (Resend)

Function: managed transactional and renewal-reminder email.

Customer-controlled data potentially processed: recipient email/name; certificate/compliance type; site name; expiry date; sender branding and message content.

Resend's published processing information states that its primary processing operations take place in the United States.

Meta / WhatsApp Business Cloud API — conditional

Function if enabled: optional WhatsApp reminder delivery.

Data potentially processed if enabled: WhatsApp number; customer name; certificate/compliance type; site name; expiry date.

WhatsApp is disabled/fail-closed for participant 1. No participant 1 reminder data is intended to flow to Meta unless the separate Meta account, entity, terms and transfer verification is completed before enablement.

3. Stripe

Stripe handles subscribing business/admin account and payment/subscription information. The current Renew architecture does not send participant end-client certificate/site/reminder records to Stripe, so Stripe is disclosed in the Privacy Notice for provider-controller account/billing processing rather than listed as a sub-processor of end-client renewal records.

4. Changes

When a sub-processor is added or materially replaced, EvenAI will follow the notice and objection process in the Data Processing Schedule and preserve the historical schedule/version that applied to earlier acceptance records.