Sub-processors
Version 1.1Effective 6 September 2026Subject to periodic review
Nia Impact SA (Pty) Ltd, trading as Nia Impact Invest ("Nia", "we"), operates the Nia LP Reporting Platform. To run the platform we rely on a small number of third-party service providers that process personal data on our behalf — our "sub-processors". Each one processes data only on our documented instructions and is bound by data-processing terms — a written agreement where the provider offers one; the status of each agreement is shown in the last column — and may only process data on our documented instructions, and is required to keep it confidential and secure. This page lists who they are, what they do for us, what data reaches them and where it is processed. It is the list referred to in our Privacy Policy and Data Processing Agreement.
We keep the list as short as we can. Information you upload — fund and portfolio-company reporting documents, KPI values, report narratives — reaches only the providers marked with a ● in the "Content" column. Everyone else sees account, contact or technical data only.
Current sub-processors
| Provider | What it does for us | Data it receives | Content? | Location / region | Safeguard |
|---|---|---|---|---|---|
| Vercel Inc. (USA) | Hosts the web application and runs its scheduled jobs | All web traffic: account and session data, uploads in transit, request logs | ● | Application runs in London (lhr1); Vercel's other services in the USA | Vercel DPA with EU Standard Contractual Clauses and UK Addendum; EU–US Data Privacy Framework |
| Neon, LLC (a Databricks company, USA) entity name to be confirmed | Hosts the platform database | Everything stored in the platform: user accounts, organisation records, submissions, reports, advisor conversations, audit logs | ● | AWS Europe (London) | Databricks DPA (SCCs) incorporated in the service terms; EU–US Data Privacy Framework (Neon, LLC) |
| Cloudflare, Inc. (USA) | Stores uploaded and generated files (object storage) and their backup copies | Uploaded documents, templates, generated reports, policy documents, profile pictures | ● | European Union jurisdiction | Cloudflare Customer DPA (SCCs Modules 2/3, UK Addendum); Data Privacy Framework |
| OpenRouter, Inc. (USA) | Gateway that routes the platform's AI requests to a model host | Prompts sent to the AI advisor and report tools, including excerpts of your documents; embedding inputs | ● | USA (gateway); OpenRouter does not store prompts — prompt logging is off by default and we do not switch it on | OpenRouter Data Processing Agreement (26 August 2026; SCCs Module 2, UK Addendum), incorporated in its Terms; routing restricted by us to zero-data-retention hosts that do not train on data |
| Amazon Web Services, Inc. — Amazon Bedrock (via OpenRouter) | Runs the AI models | Same as OpenRouter | ● | USA, EU (Ireland) or the host's global cross-region endpoint, chosen per request | Zero data retention: no prompt or response written to storage or shared with the model provider (AWS Bedrock policy) |
| Anthropic, PBC (via OpenRouter) | A permitted host for the Claude AI models under our routing rules. Today it receives no requests: the Claude models we use run on Amazon Bedrock and Google Vertex AI, because no zero-retention endpoint on Anthropic's own service is listed for them | Same as OpenRouter (none today) | ● | USA | Would only ever be used on zero-data-retention terms; Anthropic does not train on API data |
| Google LLC — Vertex AI (via OpenRouter) | Runs the AI models | Same as OpenRouter | ● | USA, EU or the host's global cross-region endpoint, chosen per request | Zero-data-retention endpoints only; Google does not use customer data to train models |
| Microsoft Corporation — Azure AI Foundry (via OpenRouter) | Runs AI models and creates text embeddings | Same as OpenRouter | ● | EU (Sweden) or global endpoints, chosen per request | Prompts not available to the model developer, not used for training (Microsoft data-privacy commitments) |
| OpenAI, L.L.C. (via OpenRouter) | Creates text embeddings for document search. Also a permitted host for AI models under our routing rules, but no model request is routed there today because no zero-retention endpoint on OpenAI's own service is listed for the models we use | Text passages from your documents (embedding inputs) | ● | USA | No training on API data; routed only under OpenRouter's no-data-collection policy |
| LlamaIndex, Inc. (LlamaCloud / LlamaParse, USA) | Converts uploaded documents into text and tables: PDF, image and scanned files, Word files with no readable text, and any PDF or Word data submission in which the Platform's own reader finds no reportable figures, are sent to the external parsing service; spreadsheets, CSV, Policy Hub documents and Advisor attachments are always read on the platform | The uploaded document itself | ● | EU (Frankfurt) endpoint | DPA (SCCs); documents used only to return results, never for training; caching disabled by us; deleted within 48 hours |
| Resend (Plus Five Five, Inc., USA) | Sends invitation, sign-in, password and notification emails | Recipient name and email address, email content | — | USA | DPA (SCCs, UK Addendum); EU–US Data Privacy Framework; logs kept 30 days |
| Functional Software, Inc. (Sentry) (USA) | Error monitoring | Error reports containing a user identifier, organisation identifier and technical details of the failed request | — | EU (Frankfurt) for event data; account metadata in the USA | DPA; EU–US Data Privacy Framework; SCCs as fallback; server-side data scrubbing |
| Gupshup Inc. (USA) | Delivers WhatsApp messages to and from the platform's advisor | Phone number, message text, links to files sent over WhatsApp | ● | USA, Europe and Asia | Provider's standard data-processing terms, accepted 4 September 2026 |
| Meta Platforms — WhatsApp LLC (USA) | The WhatsApp messaging network | Phone number and message content in transit | ● | USA | WhatsApp Business Data Processing Terms and Global Data Transfer Addendum, where those terms make WhatsApp a processor |
| GitHub, Inc. (a Microsoft company, USA) | Runs the off-site backup job for the database (used since 1 September 2026; not running on a schedule at present) | A complete compressed copy of the production database, present on the runner only for the duration of the job (protected by TLS in transit and encrypted at rest in the backup bucket; not separately encrypted on the runner) | ● | USA (Microsoft Azure) | GitHub Data Protection Agreement (SCCs, UK Addendum); EU–US Data Privacy Framework |
Google sign-in is not offered on the platform (no sign-in button is shown), so Google is not on this list.
Changes to this list
We will give you at least 30 days' notice by email to your organisation's administrators before we add or replace a sub-processor. You may object on reasonable data-protection grounds within that period; if we cannot address the objection we will work with you on a way to withdraw the affected service. For the AI model hosts, the commitment is our fixed host list — a change to the platform's own routing rules, which we control — not the gateway's notice: OpenRouter's agreement excludes AI model providers from its own 30-day sub-processor notice. Data-protection questions: sarah@niaimpactinvest.com.
Last updated: 6 September 2026.
Who we are and how to reach us
Nia Impact SA (Pty) Ltd (trading as Nia Impact Invest) · registration number 2023/912189/07
71 4th Street, Houghton, Gauteng, 2198, South Africa
Legal and privacy: sarah@niaimpactinvest.comSupport: hello@niaimpactinvest.com
Version history
- v1.1Across the legal set — Version 1.1, effective 6 September 2026: a wording and link tidy-up of version 1.0. Nothing is taken away and nothing new is asked of you; the only change to what the Terms require is one new commitment by Nia, in clause 21.1, which section 21.3 makes effective on publication, so no one is asked to accept again. Privacy Policy section 7: the GitHub row now says the database backup job is not running on a schedule at present, as sections 9 and 10 already said; the opening sentence of section 7 is reworded by one word. Privacy Policy sections 9 and 10: the database-backup sentences now say the off-site copies were taken from 1 to 3 September 2026 and the job is not running on a schedule; the promise itself is unchanged. Sub-processor list: Resend's legal entity is written as Plus Five Five, Inc. Terms 21.1: Nia still provides a copy of any earlier version on request, and now commits to 10 business days where the request is made in writing — the same turnaround as an export under 7.8. All documents: the legal hub and the versions page are linked from the site footer. The Cookie Notice, the AI-processing page and the German summaries carry no text change and are re-issued as 1.1 so the set shares one version.
- v1.0Version 1.0, effective 4 September 2026: the first published version, adopted by Nia Impact Invest. It supersedes the draft of 2 September 2026. Later revisions will be listed here with a summary of what changed.