Subprocessors and Recipients
The companies and services that process personal data for LeraLink, or receive data from it, with what they receive and where.
AuthorLeraLink Team
Last updated: 12 November 2026
1. About this register
This register is kept by SSStudio, trading as LeraLink, The Hague, the Netherlands (Chamber of Commerce (KvK) 98779885, VAT identification number NL005352396B67). Postal address on request: legal@lera.link.
It lists:
- Subprocessors (section 2): companies that SSStudio engages to process personal data on behalf of its customers, under the Data Processing Agreement (GDPR art. 28(2) and 28(4)). The same companies also process data for which SSStudio is itself the controller, as described in the Privacy Statement.
- Independent controllers (section 3): companies that receive personal data in connection with LeraLink but decide for themselves how they process it.
- Other recipients (section 4): public services that receive search terms or a web address when an author looks up a source.
Where data is stored and processed is explained in Where Your Data Is Stored. In short: data is stored in the European Union; it is processed on Cloudflare's global network.
2. Subprocessors
| Provider (legal entity) | Service | Personal data involved | Location of processing and storage | Transfer safeguard | Used since |
|---|---|---|---|---|---|
| Cloudflare, Inc. (United States) | Hosting and runtime of the whole service; databases; file storage (images, audio, documents, export packages, backups); configuration storage; job queues; coordination of collaborative editing; the PDF publication renderer; AI inference on Workers AI; search index; anonymous reading statistics; DNS; network security; Cloudflare Access. | All personal data in the service: accounts, profiles, memberships, roles, contributions, comments, annotations, editorial records, newsletter and event data, sessions (IP address and browser description only as keyed hashes), audit record. For AI inference: the text sent for the task, never restricted Pieces. For Cloudflare Access: administrators' email addresses. | Stored in Cloudflare's EU jurisdiction since 3 November 2026: databases, files, backups, configuration, job queues. Not held in the EU: the search index (installations under the EU only AI policy are left out); temporary caches of configuration and public pages; anonymous reading statistics. Processing: Cloudflare's global network, usually the data centre nearest the reader, including Workers AI. | Transfer basis: details are available on request (legal@lera.link). | EU storage since 3 November 2026 |
| Resend (United States) | Delivery of email: sign-in codes, account and editorial notifications, publication emails and newsletters. | Recipient email address and name; sender address of the installation; subject and content of the email; delivery status (delivered, bounced, complained); for newsletters, whether a message was opened and which links were followed, to measure reach. | Email sent from Resend's Ireland region (EU). Resend is a US company; account and delivery records may be held in or accessed from the United States. | Transfer basis: details are available on request (legal@lera.link). | Start date: available on request. |
| OpenAI | AI model for translation, suggested search-engine (SEO) fields and descriptions of concepts and people in published text, only where the installation's AI policy allows it. | The text sent for the task, which may contain names and other personal data that appear in it. Never restricted Pieces. No account information. Under OpenAI's published terms for the API, data sent is not used for training and may be kept for a limited period to detect abuse. | Outside the European Union. Details are available on request (legal@lera.link). | Transfer basis: details are available on request (legal@lera.link). | Start date: available on request. |
| Gemini API, paid tier: model for generating feature images, only where the installation's AI policy allows it. | The image description derived from the Piece and the installation's image instructions, which may contain personal data if the text does. Never restricted Pieces. No account information. Under Google's published terms for the paid Gemini API, data sent is not used for training and may be kept for a limited period to detect abuse. | Outside the European Union, in locations of Google's infrastructure. Details are available on request (legal@lera.link). | Transfer basis: details are available on request (legal@lera.link). | Start date: available on request. | |
| GitHub, Inc. (a Microsoft company, United States) | Runs maintenance operations on GitHub Actions: restore rehearsals, data migrations and the masked staging copy of SSStudio's own Hub, during which backup data is processed in memory for the duration of the run. Also hosts the source code, the internal monitor and the status page status.lera.link (no customer data). | During maintenance runs: the contents of a database backup, which can include all personal data in the service. Afterwards GitHub keeps the masked Hub copy, for one day, and the logs of the run. | GitHub-hosted runners, which may be outside the European Union. Details are available on request (legal@lera.link). | Transfer basis: details are available on request (legal@lera.link). | Start date: available on request. |
| Perplexity AI, Inc. (United States) | Web search lookup when an author looks up a source, only where web search lookup is enabled for the installation. | Only the search terms the author types, which may include a name. No account information. Web search lookup is also subject to the installation's AI policy. | Outside the European Union. Details are available on request (legal@lera.link). | Transfer basis: details are available on request (legal@lera.link). | Start date: available on request. |
2.1 Notes on the table
- AI policies. Which AI providers can receive an installation's data depends on the AI policy the installation is under: Standard, EU only, Open models only, or No external AI. Under No external AI, only models on Cloudflare's network are used, and OpenAI and Google receive nothing from that installation. The policy is enforced in the platform's model router, with no fallback around it. Each task tries its models in a fixed order set by the platform; an installation's administrators can see that order, with each provider, on the page 'AI in this installation'. See How LeraLink Uses AI.
- Other AI providers. The platform administrator can add other AI providers. None is in the default chains today. A provider is added to this register, with notice (section 5), before it receives personal data.
- Perplexity. Perplexity is listed as a subprocessor as a precaution, because it receives search terms in the course of the service. If its terms for the service used make it an independent controller of the queries it receives, it will be moved to section 4 and this register will say so.
- Cloudflare Images. The platform can store images in Cloudflare Images, which is not in the EU jurisdiction. No upload path uses it, and on 3 November 2026 production held no file there. If that changes, this register will say so first.
- Old copies. Copies of the data from before the move to the EU jurisdiction are kept, unwritten, until 3 December 2026 and are then deleted.
3. Independent controllers
| Provider | What it does | Personal data involved | Role |
|---|---|---|---|
| Mollie B.V. (Netherlands) | Payment of invoices, where an invoice is paid through a Mollie payment link. | Name, email address, payment details and transaction data of the person who pays. | Mollie acts as an independent controller for payment processing under its own terms and privacy statement. It is not SSStudio's subprocessor and receives no data from installations. |
4. Other recipients
When an author looks up a source while writing, the search terms the author types are sent to the following public services. No account information, no installation data and no text of a Piece other than the search terms or the web address are sent. These services are not subprocessors: they provide public information under their own terms and decide for themselves how they handle the requests they receive.
| Recipient | Service | What it receives |
|---|---|---|
| Crossref | Metadata of scholarly publications | Search terms |
| DataCite | Metadata of research datasets and other works with a DOI | Search terms |
| OpenAlex (OurResearch) | Index of scholarly works and authors | Search terms |
| Open Library (Internet Archive) | Book catalogue | Search terms |
| Google Books (Google LLC) | Book catalogue | Search terms |
| Wikidata (Wikimedia Foundation) | Open knowledge base | Search terms |
| Wikimedia Commons (Wikimedia Foundation) | Open media repository | Search terms |
| Wayback Machine (Internet Archive) | When a link in an imported work no longer works, LeraLink asks whether an archived copy exists | The web address only |
| The website at an address the author enters | When an author cites a web page, LeraLink fetches that page once to read its title, description and publisher | The web address only |
Lookups are sent from LeraLink's servers, not from the author's browser, so these services see the network address of LeraLink's servers and not that of the author. A request may carry SSStudio's own contact address, which some of these services ask for; never the author's.
5. How changes are announced
- At least 30 days before a new or replacement subprocessor starts processing personal data, we publish a Subprocessor Change Notice in Updates → Announcements on hub.lera.link and email the owners of every installation.
- A customer may object to a new subprocessor under the Data Processing Agreement, by writing to privacy@lera.link. The Change Notification Policy describes what happens next.
- In an emergency, where a subprocessor must be replaced at short notice to keep the service secure or available, we may make the change with shorter notice and tell customers without delay.
- Changes to section 4 (other recipients) are published in this register and in Announcements.
- Earlier versions of this register are available on request.
6. Contact
Questions about this register: privacy@lera.link.