Legal

Subprocessor Notice

Version 2.0  ·  Effective date: 23 August 2026

What this is: the third parties (Subprocessors) that Kyra.bot Ltd engages to help deliver KYRA, and which may process personal data on your behalf. We remain responsible for their compliance and we give advance notice of any changes (see “Changes & objections” below). This list forms part of our Data Processing Addendum.

Current subprocessors

SubprocessorPurposeCustomer Personal DataRegionTransfer basis
Microsoft AzureHosting, compute, Table and Blob storage, monitoring, Key Vault, container registry and appsPlatform and Customer Data according to featurePrimarily UK South; registry and ancillary services may use other regionsUK / EU Microsoft DPA; adequacy or SCCs / UK Addendum as applicable
Microsoft (Bot / Agents / Graph)Microsoft Teams communications; Microsoft 365 directory read and write operationsMessages, identities, tenant, directory, device, licence, sign-in and action dataCustomer Microsoft region; EU / UK / global service routingMicrosoft DPA and applicable transfer mechanism
Microsoft Azure OpenAIDefault AI inference and embeddings for platform processingInputs, support and knowledge-base content, and OutputUK South (data processed and stored in the UK)Microsoft DPA; data remains in the UK region
OpenAI (OpenAI Ireland Ltd / OpenAI, L.L.C.)Optional — only where an Enterprise tenant supplies its own OpenAI key (not used for default platform processing)Inputs, support and knowledge-base content, and generated OutputUS and configured / available regionsAdequacy where applicable and/or SCCs / UK Addendum / IDTA
Anthropic (Anthropic PBC)Optional AI inference and selected assistance featuresInputs, support and knowledge-base content, and OutputUS and other documented regionsSCCs / UK Addendum / IDTA as applicable
Microsoft Azure Communication ServicesPhone numbers, PSTN calls and SMSPhone numbers, messages, audio and transcripts, call metadataUK (UK numbers; UK data-location)Microsoft DPA; UK / EU data handling
Microsoft Azure AI (Voice Live)Real-time speech-to-text and text-to-speech for the voice assistantCaller audio, transcript and generated audioEU (Sweden Central)Microsoft DPA; data processed in the EU
Stripe (Stripe Payments Europe Ltd / Stripe Inc.)Subscription, invoicing and payment processingMSP billing, contact and payment metadata; no complete card details reach KYRAEU / USStripe DPA and applicable transfer mechanism
Slack (Slack Technologies LLC / Salesforce)Slack channel integration where enabledMessages, user and workspace identifiers, and interaction metadataUS / globalSlack / Salesforce DPA and applicable transfer mechanism
Brevo SASTransactional and customer emailRecipient address, name, and message or notification contentEU and documented infrastructureBrevo DPA and applicable transfer mechanism
Cloudflare Inc.DNS, CDN and security for the marketing websiteWebsite request metadata (marketing website)Global edgeCloudflare DPA and applicable transfer mechanism

Customer-selected systems

PSAs and documentation platforms connected under the Customer’s own contract — such as ConnectWise, HaloPSA, Jira Service Management, NinjaOne, IT Glue, Hudu and CIPP — are ordinarily recipients or processors selected by the Customer rather than KYRA-appointed Subprocessors. KYRA transmits data to them on Customer instruction; they are your processors, not KYRA’s Subprocessors. Where KYRA, rather than the Customer, contracts for such a service, it is treated as a KYRA-appointed Subprocessor and listed above.

AI provider gating

Which AI provider processes support content is controlled per tenant. By default this is Microsoft Azure OpenAI in the UK (UK South); Enterprise customers may pin a different provider or region, or bring their own key. See AI Transparency.

Changes & objections

KYRA will give at least 30 days’ prior notice of a new or replacement Subprocessor that processes Customer Personal Data, except an urgent security or continuity replacement, which will be notified as soon as reasonably practicable. Customers may object on reasonable, documented data-protection grounds under the DPA; where we cannot resolve an objection in good faith, you may terminate the affected service in line with your agreement.

Subscribe to notices through the MSP portal or your registered Account email. Contact [email protected] for evidence or objections.

Contact

Kyra.bot Ltd — company number 17408470 (registered in England & Wales)

66 Paul Street, London, EC2A 4NA, United Kingdom

Data-protection contact: [email protected]