AkilIQ Subprocessor Policy and List

Effective date: June 1, 2026
Last updated: [LAST UPDATED DATE]

This page identifies third parties that AkilIQ Inc., trading as AkilIQ, may engage to process Customer Personal Data when providing AkilIQ services.

Draft notice: Do not publish invented providers. Replace the placeholder register below with the actual production vendors and processing locations before launch.

1. What is a Subprocessor?

A Subprocessor is a third-party service provider engaged by AkilIQ that may Process Personal Data on behalf of an AkilIQ Customer in connection with the Services.

Not every vendor used by AkilIQ is necessarily a Subprocessor. This list should include providers that actually Process Customer Personal Data in a processor capacity.

2. Our Approach

When AkilIQ appoints a Subprocessor that Processes Customer Personal Data, we aim to:

• assess the provider’s security and privacy practices as appropriate to the risk;
• enter into appropriate contractual data-protection terms;
• limit Processing to what is necessary for the relevant service;
• use appropriate international-transfer safeguards where required;
• maintain a current Subprocessor register;
• remain responsible for Subprocessor obligations as required by applicable law and our DPA.

3. Current Subprocessors

Status: [TO BE COMPLETED BEFORE PRODUCTION USE]

Replace each placeholder with the actual vendor.

Delete rows for services AkilIQ does not use.

4. AI Providers

AI providers should only be listed if they may receive Customer Personal Data.

For each AI provider, AkilIQ should document:

• which AkilIQ features use the provider;
• what data can be transmitted;
• applicable retention settings;
• whether provider model training is disabled for AkilIQ business/API traffic;
• processing region where configurable;
• contractual data-protection terms;
• applicable transfer mechanism.

AkilIQ policy: Private Customer Data is not used to train shared or general-purpose AkilIQ AI models by default.

This statement must remain consistent with the configuration and contractual terms of every AI provider used.

5. Subprocessor Changes

AkilIQ may add or replace Subprocessors as the Services evolve.

Where required by the applicable DPA, AkilIQ will provide Customers with notice of material new Subprocessors before the new provider begins relevant Processing.

Notice method: [EMAIL / SUBPROCESSOR NOTIFICATION LIST / ACCOUNT NOTICE]
Notice period: [NUMBER OF DAYS]

Customers with applicable objection rights may submit a reasonable data-protection objection to:

[email protected]

within the period specified in the applicable DPA.

6. International Transfers

Where a Subprocessor receives protected Personal Data outside the country or region where it was collected, AkilIQ will use an appropriate transfer mechanism where required.

For European data, mechanisms may include:

• adequacy decisions;
• European Commission Standard Contractual Clauses;
• UK Addendum or IDTA where applicable;
• other legally recognized safeguards.

7. Infrastructure Options

Different AkilIQ deployment models may involve different Subprocessors.

For example:

• AkilIQ managed cloud may use AkilIQ-selected infrastructure providers;
• dedicated deployments may use a smaller or different provider set;
• customer-controlled database deployments may keep certain data within Customer infrastructure;
• on-premise deployments may significantly reduce the third-party providers involved in Customer Data Processing.

The applicable order form or enterprise agreement may provide deployment-specific details.

8. Subscribe to Changes

Customers may subscribe to Subprocessor change notifications at:

[SUBPROCESSOR NOTIFICATION SIGNUP URL]

If no automated subscription service is available, contact:

[email protected]

9. Contact

Questions about AkilIQ Subprocessors may be sent to:

AkilIQ Inc.
00100, Nairobi, Kenya
[email protected]