Sub-processors — AccesPub portal and API
List in force from 21 October 2026 · Google description updated on 6 November 2026 (no change of providers) · English translation; the Spanish version prevails
These are the providers ab serveis uses to run the AccesPub portal and API and that may access the Client's personal data. All of them are bound by a data processing agreement with measures equivalent to those of the DPA. Any addition or replacement will be notified to each organisation's administrators at least 30 days in advance (Clause 7.7, Option 2).
Fly.io, Inc. (USA)
- Service: Hosting of the portal, the API, the database and backups
- Data accessed: All service data
- Processing location: Amsterdam data centre (Netherlands)
- Transfer safeguards: Data processing agreement signed with Fly.io, which includes the European Commission's standard contractual clauses; company participating in the EU-US Data Privacy Framework
Google (Google Cloud EMEA Ltd., Ireland, and Google LLC, USA)
- Service: AI (Gemini API, paid tier) for suggestions
- Data accessed: Only what each suggestion needs, and only when one is requested (by a user or by the batch suggestions the Client turns on). Alternative text: the image, the text around it in the book (at most about 300 characters before and 300 after, or its caption) and the language. Table caption: the table text and the text around it. Description and subjects: an excerpt of the book (≈4,000 characters) and the title
- Processing location: Google infrastructure; may include countries outside the EEA
- Transfer safeguards: Google Cloud Data Processing Addendum (includes standard contractual clauses); Google LLC participates in the EU-US Data Privacy Framework. Data are not used to train models; requests and responses are kept for a limited time (55 days, according to Google) only to detect abuse
Brevo (Sendinblue SAS, France)
- Service: Sending service emails (invitations, passwords, reminders, support)
- Data accessed: Users' names and emails. The emails are notices (invitations, passwords, batch reminders and notice of an answer to a request) and never include the content of books or requests
- Processing location: Mainly in the European Union; some of its sub-processors may process data outside the EEA
- Transfer safeguards: Brevo data processing agreement (Appendix 3 of its terms), with standard contractual clauses and, for the USA, the EU-US Data Privacy Framework
ab serveis's mailbox is not part of the processing: the notices it receives from the portal contain no Client data, which is only consulted inside the portal. Book files are never published or shared with anyone else. AI suggestions are requested only when a user asks for one or when the Client turns on batch suggestions for a batch or a title.