Version 1.0 · Last updated 18 September 2026
IT-Dev sp. z o.o., operating under the Engagy360 brand, uses a small number of providers to deliver the Engagy360 platform and the EngagyApp mobile application. Where those providers process personal data on behalf of our customers, they act as our subprocessors under the Engagy360 Data Processing Agreement (DPA), published at https://engagy360.com/dpa.
This page is the current list referred to in Section 6 of the DPA. In case of any discrepancy with Annex 3 of the DPA, this page prevails.
| Subprocessor | Role | Data processed | Location |
|---|---|---|---|
| Microsoft Ireland Operations Limited (Microsoft Azure) | Hosting of the platform and the mobile application, data storage, technical logs | All categories described in Annex 1, parts A and D of the DPA | European Union (West Europe) |
| Microsoft Ireland Operations Limited (Azure OpenAI Service) | AI features: draft information architecture, initial portal content, suggested notification text | Company information, source documents, website and article content submitted by the customer (Annex 1, part C of the DPA) | European Union (Sweden Central) |
| Twilio Inc. (Twilio Verify) | Sending SMS activation codes in EngagyApp, where a worker activates the app by that method | Phone number and one-time activation code | United States, under the EU-U.S. Data Privacy Framework |
Microsoft may access data from outside the European Union for support and security operations, under its own data processing terms, its EU Data Boundary commitments and, where applicable, the EU-U.S. Data Privacy Framework or the Standard Contractual Clauses.
Affiliates of IT-Dev sp. z o.o. process personal data on behalf of our customers only if they are listed above.
Before adding or replacing a subprocessor, we update this page and send a notice by email to the data protection contact each customer provides in its order, at least 30 days in advance. Where a replacement is urgently required for the continuity or security of the services, we may act immediately and notify no later than on the day of the change.
Customers may object on reasonable data protection grounds within the notice period. Section 6 of the DPA sets out how objections are handled and what happens if no solution is found.
| Version | In force from | Change |
|---|---|---|
| 1.0 | 18 September 2026 | First published |
Questions about this list: office@engagy360.com
Data protection contact: Grzegorz Łuszczyński, gluszczynski@it-dev.pl
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