Annex B — Subprocessors and Restaurant-Selected Recipients
- Version
- 1.0
- Effective
- October 1, 2026
- SHA-256 of this text
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AIDA is a service of PalmDine AI - FZCO, a free zone company registered with the International Free Zone Authority (IFZA), Dubai, United Arab Emirates, licence number 62637 ("PalmDine"). PalmDine provides AIDA and is the contracting party to the AIDA Data Processing Addendum of which this annex forms part.
Document id annex-b-subprocessors, version 1.0. Effective date: the date stated in the Legal Center on publication. Annex B to the AIDA Data Processing Addendum (DPA clause 6); it serves as Annex III of the Standard Contractual Clauses. Changes to Part A are notified under DPA clause 6.2 and recorded in the Legal Center's version history. Current and past versions: https://www.myaidateam.com/legal/annex-b-subprocessors.
How to read this annex
- Part A lists subprocessors: providers PalmDine chooses and engages to deliver the Services. The DPA's general authorisation, 30-day change notice and objection right apply to them (DPA clause 6).
- Part B lists restaurant-selected recipients: systems the restaurant decides to connect for its own purposes, under its own contract with that provider. They are not PalmDine's subprocessors (DPA clause 6.7). PalmDine sends data to them because the restaurant instructs it to, by switching the connection on.
- Part C lists guest-chosen identity providers: sign-in services a guest chooses to use.
The distinction matters because it decides who must hold the contract and who answers for the recipient. PalmDine answers for Part A. The restaurant answers for Part B. A useful test: if the restaurant can switch the connection off and still use every AIDA Module, and the provider holds a contract with the restaurant, the provider is in Part B.
Part A — subprocessors
| # | Provider (legal entity) | Service used | Personal data processed | Location | Transfer safeguard | Data-processing terms |
|---|---|---|---|---|---|---|
| A1 | Google Cloud / Firebase — Google Cloud EMEA Limited (Ireland), or the Google entity named in PalmDine's Cloud billing account | Hosting (Cloud Run), Firestore, BigQuery, Cloud Storage, Secret Manager, Cloud Logging, Firebase Authentication, Firebase Functions | All categories in Annex A §5 | EU: Netherlands (europe-west4), Belgium (europe-west1), Germany (europe-west3, billing webhook only); US (us-central1) for the staff AI orchestrator and WhatsApp webhook; Google support access from Ireland, the US and other locations | SCCs incorporated in Google's Cloud Data Processing Addendum; Google LLC is certified under the EU-US Data Privacy Framework | Google Cloud Data Processing Addendum (cloud.google.com/terms/data-processing-addendum); Firebase Data Processing and Security Terms (firebase.google.com/terms/data-processing-terms) |
| A2 | Google — Vertex AI (Gemini models), same entity as A1 | AI host, AI waiter, staff AI, transcription, summaries, live voice and live-avatar video | Conversation content, voice audio in the request, menu and guest context sent to the model | Text: global endpoint (no fixed location). Live voice: eu by default; us or us-central1 only if PalmDine sets it for the platform | As A1 | Covered by the Cloud Data Processing Addendum; Google's service terms exclude the use of customer data to train Google's models |
| A3 | Google LLC — Gemini API (paid tier) | The same AI activities as A2, only where PalmDine routes a text activity to this service | As A2 | Single global service; no endpoint choice | As A1 | Gemini API Additional Terms of Service, paid tier (content is not used to improve Google's products) |
| A4 | Stripe — Stripe Payments Europe, Limited (Ireland) and Stripe, Inc. (US) | Stripe Connect platform: creating checkout sessions and saved-card customers on the restaurant's connected account; PalmDine's own subscription billing | Guest name, email, phone for saved cards; payment amounts, status, identifiers. Card data is entered on Stripe's pages only | Ireland, US | Stripe Data Processing Agreement with SCCs; Stripe is certified under the EU-US Data Privacy Framework | Stripe Data Processing Agreement (stripe.com/legal/dpa) |
| A5 | Square — Block, Inc. (US) | Payment gateway through PalmDine's Square developer application, and Square POS connection | Guest name and contact for Square customers; order and payment data; single-use card token (card fields are Square's own) | US | Square's data-processing terms with SCCs | Square Developer Terms of Service and Data Processing Terms (squareup.com/legal) |
| A6 | Resend, Inc. (US) | Transactional e-mail only: booking confirmations, reminders, receipts, sign-in codes, staff notices. No marketing e-mail is sent | Recipient name and email, message content, delivery events | US | SCCs in the Resend Data Processing Agreement | Resend Data Processing Agreement (resend.com/legal/dpa) |
| A7 | Twilio Inc. (US) | Phone numbers and inbound calls answered by the AI host (AIDA places no outbound calls); call media stream to the AI host. SMS is not used; no SMS sender is configured | Caller phone number, call audio in transit, call metadata | US | Twilio Data Protection Addendum with SCCs; Twilio Binding Corporate Rules; Twilio is certified under the EU-US Data Privacy Framework | Twilio Data Protection Addendum (twilio.com/legal/data-protection-addendum) |
| A8 | Meta — WhatsApp Business Platform (Cloud API); Meta Platforms Ireland Limited (Ireland) and Meta Platforms, Inc. (US) | Sending and receiving WhatsApp messages for the AI host, one-time codes, templates and staff report cards | Guest WhatsApp number, profile name, message content and media | Ireland, US | WhatsApp Business Data Processing Terms with SCCs | WhatsApp Business Solution Terms and Data Processing Terms (business.whatsapp.com/policy) |
No other provider processes Guest or staff personal data for PalmDine.
No subprocessor has accepted the Turkish Personal Data Protection Board's processor-to-processor standard contract (Annex C §1.10).
Part B — restaurant-selected recipients (not subprocessors)
The restaurant connects these systems in the console and has its own contract with each provider. Data flows because the restaurant switches the connection on. The restaurant is responsible for the lawfulness of the transfer and for its contract with the provider, including the legal entity it actually contracts with. PalmDine is responsible for sending only what the connection needs and for stopping when the restaurant switches it off.
| # | Recipient | What the restaurant uses it for | Data sent or received |
|---|---|---|---|
| B1 | SevenRooms (SevenRooms, Inc., US) | The restaurant's reservation and guest system. Where configured, SevenRooms is the source of truth for bookings and guest records, and a SevenRooms venue group shares one client record across its venues | Bookings, guest names, contacts, notes, tags |
| B2 | Simpra (Simpra Suite, Türkiye) | The restaurant's point-of-sale system | Orders, checks, payments, menu |
| B3 | Oracle MICROS Simphony (Oracle Corporation) | The restaurant's point-of-sale system | Orders, checks, payments, menu |
| B4 | Deliverect (Deliverect NV, Belgium) | The restaurant's ordering and delivery middleware | Orders, menu, guest name and contact on orders |
| B5 | Google Business Profile (Google LLC) | The restaurant's own Google listing; AIDA imports its reviews | Review text, reviewer display name, rating |
| B6 | Square seller account, Stripe connected account | The restaurant's own merchant account for guest payments (the restaurant is the merchant and holds the provider agreement) | Guest payment data |
| B7 | Google Maps Platform (Google LLC) | Directions for a guest who asks the AI host how to reach the venue. Under Google's Maps Platform terms Google is an independent controller of request data, so it is listed here rather than in Part A | The starting point the guest gives; the venue address |
Square and Stripe appear in both Part A and Part B on purpose. PalmDine engages them as platform or gateway to initiate guest charges and refunds on the restaurant's instructions (Part A). The restaurant's merchant relationship for guest payments is its own (Part B). PalmDine's own Stripe account, used only to invoice restaurants for the Fees, is PalmDine's controller processing (DPA clause 2.3(c)) and is outside this Annex.
The console's "Search on Google" button on a guest profile opens a Google search in the staff member's own browser; no data passes through PalmDine.
Part C — guest-chosen identity providers
| Provider | Use | Data |
|---|---|---|
| Google Sign-In (through Firebase Authentication) | Guest chooses to sign in with Google | Name, email, profile photo if the guest agrees |
| Facebook Login (Meta) | Guest chooses to sign in with Facebook on the booking site | Name, email, profile photo if the guest agrees |
The guest platform account is PalmDine's own controller processing (DPA clause 2.3(d)).