Sub-processors
This page lists the companies (sub-processors) that OnTheGoSystems Limited engages to process personal data on behalf of its clients. It is the subprocessor list that clause 6.4 of our Data Processing Annex refers to. The Data Processing Annex is Annex 1 of our Terms and Conditions.
For each sub-processor the list gives its registered seat, where it processes the data, and what it does for us. Each is bound by a written agreement with data protection obligations equivalent to the Data Processing Annex. Where a sub-processor processes personal data outside the European Economic Area, the United Kingdom or Switzerland, the transfer is made under clause 7 of the Data Processing Annex, with the EU Standard Contractual Clauses and their UK and Swiss addenda set out in Annex 1 of the Terms.
Your right to object
We announce an addition or replacement of a sub-processor on this page and by email at least fourteen (14) days before the new sub-processor is engaged. Under clause 6.4 of the Data Processing Annex, you may object to it on reasonable grounds related to data protection within those fourteen (14) days. If you raise a reasonable objection and we cannot reasonably accommodate it, either party may terminate the affected Services in accordance with the Agreement. To object, write to hello@wpml.org.
How we tell you about changes
Every change to this list is recorded, with its date, in the changelog at the end of this page. When we add or replace a sub-processor, we also send a notice to the clients who have an interest in our Data Processing Annex.
Current sub-processors
| Name (registered seat) | Processing location and transfers | What the sub-processor does |
|---|---|---|
| Amazon Web Services, Inc. (Seattle, Washington, US) | US (us-east-1). International transfers are conducted in accordance with clause 7 of the DPA (EU Standard Contractual Clauses). | Cloud hosting of the Services and their database, file storage for support uploads, transactional and newsletter email, message queues; our self-hosted team chat runs on this account; language models used to process and translate content submitted through the Services. |
| DeepL SE (Cologne, Germany) | EU (Germany). No international transfer. | Machine translation services used to process and translate content submitted through the Services. |
| Google LLC (Mountain View, California, US) | US. International transfers are conducted in accordance with clause 7 of the DPA (EU Standard Contractual Clauses). | Cloud infrastructure and artificial intelligence services: language models used to process and translate content submitted through the Services, the model that translates support messages between a client and a supporter, and the reporting of a new account's first order to Google Ads as an offline conversion (account identifier and order time, no message content). |
| Microsoft Corporation (Redmond, Washington, US) | US. International transfers are conducted in accordance with clause 7 of the DPA (EU Standard Contractual Clauses). | Cloud infrastructure and artificial intelligence services, including language models used to process and translate content submitted through the Services. |
| PayPal Hong Kong Limited (Hong Kong), with PayPal, Inc. (San Jose, California, US) | Hong Kong and US. International transfers are conducted in accordance with clause 7 of the DPA (EU Standard Contractual Clauses). | PayPal payments and billing agreements for your payments for the Services. |
| PostHog, Inc. (San Francisco, California, US) | US. International transfers are conducted in accordance with clause 7 of the DPA (EU Standard Contractual Clauses). | Product analytics and session replay in designated WPML administration interfaces, for troubleshooting, usability analysis, and product improvement. |
| Stripe Payments Europe, Limited, and Stripe Technology Europe, Limited (Dublin, Ireland) | Ireland / global. International transfers are conducted in accordance with clause 7 of the DPA (EU Standard Contractual Clauses). | Card payments and saved payment methods for your payments for the Services. We never see or store the card number. |
| Anthropic, PBC (San Francisco, California, US) | US. International transfers are conducted in accordance with clause 7 of the DPA (EU Standard Contractual Clauses). | Language models for Maiya conversations (the support assistant), for the review of support conversations, and for the company profile our client enricher writes about a client; and, through OpenRouter, language model processing for PTC. |
| Serper (serper.dev, US) | US. International transfers are conducted in accordance with clause 7 of the DPA (EU Standard Contractual Clauses). | A web search API: our client enricher's company and buyer name search. |
| JetBrains s.r.o. (Prague, Czechia), YouTrack | EU. No international transfer. | YouTrack, the issue tracker our developers work from: the ticket mirror carries client questions to it. |
| OpenRouter, Inc. (US) | US. International transfers are conducted in accordance with clause 7 of the DPA (EU Standard Contractual Clauses). | PTC, WPML's AI translation engine: routing of translation requests to the language model providers. |
| OpenAI, L.L.C. (San Francisco, California, US) | US. International transfers are conducted in accordance with clause 7 of the DPA (EU Standard Contractual Clauses). | PTC: language model processing of content submitted for translation, through OpenRouter. |
OnTheGoSystems Limited
22/F 3 Lockhart Road
Wanchai, Hong Kong
Data Protection Officer: Mercedes Barreda, hello@wpml.org
Changelog
| Date | Change |
|---|---|
| 27 October 2026 | This list is published on its own page and replaces Appendix 3 of the Data Processing Annex. Against the list in Appendix 3 of the Data Processing Agreement of 16 October 2026: OpenRouter, Inc. is added (PTC, WPML's AI translation engine, sends translation requests through it to the language model providers), and OpenAI, L.L.C. now serves PTC as one of those providers, through OpenRouter, instead of the support assistant's backup model, which is switched off. |