What this is. A subprocessor is a third party that handles any personal data on Nemora's behalf to deliver Willow. UK GDPR Article 28 requires us to disclose every subprocessor to our care-home customers, give them notice when the list changes, and bind every subprocessor to data protection obligations equivalent to those in our Data Processing Agreement.

Current subprocessors

Provider Service Data they may process Region
Cloudflare, Inc. Application backend (Workers + KV), CDN hosting, DDoS protection Family member name, email, push token; resident profile metadata; family messages; pending-call signalling; server access logs UK / EU edge where available; otherwise global edge
Google LLC (Firebase) Cloud Messaging (push notifications to Android), anonymous usage analytics FCM push token; aggregate analytics events (no personal data) EU and US data centres
Apple Inc. Apple Push Notification service (push to iOS, iPadOS) APNs push token Apple's global network
Agora.io, Inc. Real-time video and audio calling between family and resident Channel identifier; live audio/video stream in transit (not stored by Agora or Nemora) Global edge
Sentry / crash-reporting [remove if not used] Crash and error reporting Anonymised stack traces, app version, device model — no personal data EU

Public-archive content sources

Willow surfaces music, video and photography from public archives. These are not subprocessors — they don't see any user data — but we list them here for completeness because content from these sources is loaded directly into the resident's device when used:

How we choose subprocessors

Before adding a subprocessor we evaluate:

Every subprocessor signs (or accepts by reference) data-protection terms equivalent to those in our Data Processing Agreement.

Notice of changes

We will give care-home customers at least 30 days' notice before adding a new subprocessor or changing how an existing one is used in a material way. This page is the canonical record — its "Last updated" date at the top reflects the date of the most recent change.

If you would like to subscribe to email notifications of subprocessor changes, email info@nemorahealthcaresolutions.com with the subject "Subprocessor notifications".

Objections

If you are a care-home customer and you object to a new subprocessor on reasonable data-protection grounds, contact info@nemorahealthcaresolutions.com within the 30-day notice window. We will work with you in good faith to resolve the concern, which may include offering an alternative provider or, if no resolution is possible, providing a pro-rata refund of unused subscription fees.

Contact

Questions about subprocessors:
info@nemorahealthcaresolutions.com