GreenTrust

Sub-processor List

Last updated: October 5, 2026 · Version 1.2

1. Overview

In accordance with Article 28 of the General Data Protection Regulation (GDPR), GreenTrust Engineering Consulting ("Data Controller") maintains a list of sub-processors engaged in the processing of personal data through the GreenTrust EUDR platform.

Section 2 lists the sub-processors that process personal data for the platform. Section 3 lists the other parties that receive personal data from the platform's servers or from users' browsers, and the external data services the platform queries. For each one we state the data it receives and where it is located.

2. Current Sub-processors

Sub-processor Purpose Data Processed Location DPA Status
Auth0 (Okta)*.eu.auth0.com User authentication, identity management, role-based access control Email, name, password (Auth0 stores only a hash of it), login metadata, IP address, user agent EU (Frankfurt); Okta, Inc. is based in the United States Covered by Okta DPA
Appwrite Cloudfra.cloud.appwrite.io Database hosting, document storage, file storage All platform data: operator profiles, supplier data, geolocation, documents, audit logs EU (Frankfurt) Covered by Appwrite DPA
Hetzner Online GmbH Application server hosting (Docker containers), server logs, daily backup archives All data the application processes; web-server and application logs; the daily backup archives EU Covered by Hetzner DPA
Sendinblue SAS (Brevo)smtp-relay.brevo.com Delivery of the platform's notification e-mails (account, approval, submission, document, DDS and support notifications) Recipient e-mail address and the content of the message, which can include names, company names, DDS references, file names and support-ticket subjects EU; Sendinblue SAS is based in France To be confirmed
Google LLC (Gemini API)generativelanguage.googleapis.com AI assistant in the operator and supplier dashboards, when the assistant is enabled The text a user types into the assistant, up to 10 previous messages of the same conversation and the interface language. No other platform data is added. United States To be confirmed

The platform can be configured to use OpenAI, L.L.C. (api.openai.com) or Anthropic, PBC (api.anthropic.com), both in the United States, instead of Google for the AI assistant. Such a change is a change of sub-processor (Section 4).

3. Other Recipients and External Services

The parties below receive personal data from the platform's servers or from users' browsers, or are queried by the platform without personal data.

Recipient Purpose Data Received Sent From Location
World Resources Institute: Global Forest Watch Data API and LandMark data-api.globalforestwatch.orggis.wri.org Deforestation, forest-cover and indigenous and community land checks of plots (EUDR risk assessment) The outline of a plot (polygon or point) with a buffer around it, and date ranges. No names, e-mail addresses or account data. Platform servers United States
World Resources Institute: Global Forest Watch map tiles tiles.globalforestwatch.org Deforestation-alert overlay (GLAD/RADD integrated alerts) on the assessment map of GreenTrust administrators IP address, user agent, referring page, map area viewed GreenTrust administrators' browsers United States
Esri, Inc. (ArcGIS Online)server.arcgisonline.com Satellite map imagery IP address, user agent, referring page, map area viewed Users' browsers United States
OpenStreetMap Foundationtile.openstreetmap.org "Streets" map tiles of the supplier form's plot map and of the administrators' assessment map IP address, user agent, referring page, map area viewed Suppliers' and GreenTrust administrators' browsers United Kingdom
VITO NV (Terrascope)services.terrascope.be ESA WorldCover land-cover overlay on the assessment map of GreenTrust administrators IP address, user agent, referring page, map area viewed GreenTrust administrators' browsers EU (Belgium)
European Commission: EU Information System for due diligence statements (TRACES)eudr.webcloud.ec.europa.euacceptance.eudr.webcloud.ec.europa.eu Filing operators' due diligence statements under Regulation (EU) 2023/1115. Direct filing from the platform is not switched on yet. The statement: operator identity and contact details, commodities and quantities, geolocation of the plots. Producer names only if the platform is set to include them (off by default). Platform servers EU
Esri, Inc. (ArcGIS Living Atlas: Sentinel-2 10 m land cover time series of Impact Observatory, Microsoft and Esri)ic.imagery1.arcgis.com Land-use history check of plots (EUDR risk assessment): the land cover of 2019-2020 and of the latest years The bounds of fixed map squares of 0.1 degree (about 11 km) in which plots lie, the same for every plot in a square; never a plot outline or point. No personal data. Platform servers United States
World Bank (World Bank Open Data API)api.worldbank.org Country governance indicators for the EUDR country risk assessment Country codes only. No personal data. Platform servers United States

Map positions of suppliers and operator headquarters are worked out on the platform's own servers from an offline copy of the GeoNames dataset; no external geocoding service is used.

4. Changes to Sub-processors

GreenTrust will notify data subjects and operators of any changes to the sub-processor list at least 30 days before a new sub-processor begins processing personal data. Notifications will be provided via email to registered operators and by updating this page.

If you object to the use of a new sub-processor, you may contact us within the 30-day notice period at the address below.

5. Safeguards

6. Contact

For questions about our sub-processors or to request a copy of an applicable DPA, contact:
GreenTrust Engineering Consulting
Email: dpo@greentrust.eu
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