Last updated: 6 May 2026
In cases where a NetZero entity acts as a data processor, NetZero may rely on the following sub-processors to process personal data.
| Sub-processor | Legal entity country | Data hosting region |
|---|---|---|
| AvePoint Inc. | United States | European Union |
| Celonis Inc. | United States | European Union, United States |
| DocuSign International (EMEA) Limited | Ireland | European Union |
| Jotform Ltd. | United Kingdom | European Union |
| Microsoft France SAS | France | European Union |
| NetZero Brasil Biochar Ltda. | Brazil | N/A |
| NetZero SAS | France | N/A |
| Palantir Technologies Inc. | United States | European Union |
| Totvs S.A. | Brazil | Brazil |
Each sub-processor listed above engages its own sub-processors. These onward sub-processors are disclosed in each sub-processor's own published documentation.
Where personal data originating in the European Economic Area is transferred outside the EEA, NetZero relies on appropriate transfer mechanisms under Chapter V GDPR, including European Commission Standard Contractual Clauses (Implementing Decision 2021/914) and, where applicable, EU-US Data Privacy Framework certification.
Where personal data originating in Brazil is transferred outside Brazil, NetZero relies on transfer mechanisms recognised under LGPD Article 33, including the Standard Contractual Clauses approved by ANPD under Resolution CD/ANPD No. 19/2024.
NetZero updates this list from time to time to reflect changes in its sub-processors.
Questions about subprocessors may be directed to privacy@netzero.green.