The legal bit.
Last updated 14 September 2026. This page is Annex 3 to our Data Processing Terms.
To deliver our services we rely on a small number of third party platforms. Where those platforms process personal data on behalf of our clients, they are sub-processors under Article 28 of the UK GDPR. This page lists them, where they process data, and the legal mechanism that covers any transfer outside the United Kingdom.
Current sub-processors
| Sub-processor | Service provided | Processing location | Transfer safeguard |
|---|---|---|---|
| Microsoft Ireland Operations Ltd and Microsoft Corporation | Microsoft 365, Entra ID, Intune, Azure | United Kingdom, with support access from the EU and US | Microsoft Data Protection Addendum, EU SCCs with UK Addendum |
| SuperOps | Remote monitoring and management, service desk and ticketing | Europe | EU Standard Contractual Clauses with UK Addendum |
| Huntress Labs Inc | Managed endpoint detection and identity threat detection | United States | UK Extension to the EU-US Data Privacy Framework and EU Standard Contractual Clauses |
| ThreatLocker Inc | Application allowlisting and endpoint control | Europe | UK adequacy regulations; UK Extension to the EU-US Data Privacy Framework for any transfers to the United States |
| Keeper Security Inc | Encrypted credential vault | Europe | EU Standard Contractual Clauses with UK Addendum |
| Pax8 | Microsoft licence provisioning and billing. Business contact data only. | United States and other locations used by Pax8, its affiliates and sub-processors | EU Standard Contractual Clauses with UK Addendum |
Microsoft acts as a sub-processor to Fresh Tech and as a processor to each client in its own right under the Microsoft Customer Agreement. Nothing on this page limits a client's direct relationship with Microsoft.
How changes are notified
We give clients at least 30 days' notice before adding or replacing a sub-processor, as set out in clause 7 of our Data Processing Terms. Notice is given by email to each client's primary contact and recorded in the change log below.
If you would like to receive sub-processor notices at an additional address, email hello@fresh-tech.uk with the subject "Sub-processor notifications".
Change log
| Date | Change |
|---|---|
| 14 September 2026 | First published list. |