Notification policy
Before we engage a new sub-processor that processes customer personal data, we give existing customers at least 30 days' written notice so they can review and object. If a customer objects on reasonable data-protection grounds and we can't accommodate, they can terminate the affected service scope.
Current sub-processors
| Vendor | Purpose | Region | Transfer mechanism |
|---|---|---|---|
| Amazon Web Services (AWS) Amazon Web Services EMEA SARL |
Underlying cloud compute (Lambda), object storage (S3), NoSQL database (DynamoDB), secrets (Secrets Manager), messaging queues (SQS), event bus (EventBridge), CDN (CloudFront), identity (Cognito). | EU — eu-central-1 (Frankfurt) |
DPA + Standard Contractual Clauses under the AWS master customer agreement. |
| Meta / WhatsApp Business Platform WhatsApp Ireland Limited |
Delivery of WhatsApp messages between candidates and the SmartHire service. Handles the underlying messaging protocol, encryption in transit, and delivery receipts. | Global — EU-region delivery where available; may transit Meta infrastructure elsewhere in transit | Meta Business Terms + WhatsApp Business Solution Terms + Meta Data Processing Terms (SCCs by reference). |
| AWS End User Messaging Social AWS socialmessaging service |
Outbound WhatsApp message delivery on AWS-managed WABA phone numbers. IAM-authenticated; no long-lived Meta access token stored. | EU — eu-central-1 |
Same DPA + SCCs as AWS above. |
| Amazon Bedrock AWS-hosted Anthropic Claude models |
LLM inference for screening conversations, structured extraction, scoring, summaries. Bedrock is stateless per call — prompts and candidate data are not used to train the underlying models per AWS policy. | EU — eu-central-1 |
Bedrock is an AWS service under the same DPA + SCCs. |
| Amazon Transcribe | Speech-to-text for candidate voice notes. Audio buffers are ephemeral inside the service; SmartHire stores the resulting text transcript only. | EU — eu-central-1 |
Same DPA + SCCs as AWS above. |
| Amazon Polly | Text-to-speech for optional voice-out replies to candidates. | EU — eu-central-1 |
Same DPA + SCCs as AWS above. |
| Amazon Cognito | Identity provider for SmartHire dashboard users (recruiters, admins, hiring managers, interviewers). Handles authentication, MFA, password reset, Google federation. | EU — eu-central-1 |
Same DPA + SCCs as AWS above. |
| Amazon SES Simple Email Service |
Transactional email — account verification, magic-link invitations to hiring managers, interview confirmations, weekly digests. | EU — eu-central-1 |
Same DPA + SCCs as AWS above. |
| Google LLC Calendar API + Sign-In |
Optional: Google Calendar integration for interview scheduling; Google Sign-In for dashboard authentication. Only used when the customer connects a Google account. | Global | Google Cloud DPA + SCCs, invoked only for customers who connect Google services. |
| PostHog PostHog Inc., EU-region deployment |
Product analytics and session replay for signed-in dashboard users (app.smarthire.chat). Served same-origin via /ingest/*; uses browser localStorage and sets no cookies. Session recordings mask every input field by default and are disabled on login and credential pages. Not applied to candidate WhatsApp interactions. |
EU — eu.i.posthog.com |
PostHog DPA + SCCs under PostHog's EU-region terms. |
| RecordX Interview recording & transcription |
Optional: interview-recording capture, transcription, and audio playback for interviews booked through SmartHire. Audio and transcripts can be purged on candidate erasure. | EU — eu-central-1 |
Operated under the same AWS DPA + SCCs. |
| Creem Payment processor — not yet active |
Billing and subscription payment processing. Not active in production as of this version — no live payment events flow to Creem. Will be enabled when the first paid plan ships. | Global | Creem's standard DPA / SCCs will govern when payments are enabled. |
Related sub-processors (customer-controlled)
These are only in scope for customers who choose to connect them:
- Microsoft (Outlook / Exchange calendar) — only when the customer connects Microsoft calendar. Governed by the customer's own Microsoft agreements.
- Comeet ATS and other applicant-tracking systems — only when the customer configures an ATS integration. SmartHire sends candidate data to the customer's ATS on their instructions; the ATS operates under the customer's own contract with that vendor.
What we do not use
- No third-party analytics on candidate-facing surfaces. Candidates interact over WhatsApp or at short-lived single-page endpoints (for example, offer signing) that run no trackers. Our dashboard analytics (PostHog) applies to signed-in customer users only.
- No advertising networks, ad SDKs, or profiling vendors.
- No third-party live-chat or heatmap tools on the marketing site's legal pages.
- No location-service providers, geo-IP databases, or address lookup services for candidate data.
How to subscribe to updates
Customers with an active account are notified automatically. If you'd like to receive change notices as a prospective customer or reviewer, email legal@smarthire.chat and we'll add you to the notification list.
- 2026-10-04 Added PostHog (EU-region product analytics on the signed-in dashboard, no cookies), RecordX (optional interview-audio recording and transcription, EU region), and Creem (payment processor, not yet active in production).
- 2026-07-20 Initial published list.