Sub-processors
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Version: v1.0

Effective date: [INSERT publication date]

About this list

This page lists every third party that processes personal data on behalf of Third Mind Kft. as part of the Accord Blueprint service. We call these parties "sub-processors."

A sub-processor is a service provider we use to deliver Accord Blueprint. They process personal data only on our written instructions, under a Data Processing Agreement (DPA) that meets the requirements of GDPR Article 28. We remain responsible to you for what they do.

This list is referenced from our Privacy Notice (3rdmind.co.uk/privacy) and our Terms & Conditions (3rdmind.co.uk/terms).

Controller details

ControllerThird Mind Kft.
Cégjegyzékszám01-09-451178
AdószámHU32952638
Székhely1112 Budapest, Nevegy utca 16., Hungary
Privacy contactprivacy@3rdmind.co.uk
Lead supervisory authorityNAIH (Hungary), naih.hu

Change notification

We will give at least 30 days' written notice before adding, removing or replacing any sub-processor that processes Blueprint participant data. Notice is posted on this page and emailed to the Primary Contact of each active engagement.

If you object to a new sub-processor for a documented data protection reason, contact privacy@3rdmind.co.uk within the 30-day notice period. We will work with you to find an alternative or, where no alternative is possible, terminate the affected engagement and refund pro rata.

Current sub-processors at a glance

Sub-processorRoleData locationTransfer basis
AWS (Europe) SARLCloud infrastructure + AI (Bedrock)EU - FrankfurtIntra-EU
AWS Simple Email ServiceTransactional emailEUIntra-EU
Wix.com LtdMarketing website hostingIsrael + EU DCsEU adequacy decision
Stripe Payments Europe LtdPayment processingEU (Ireland) - limited USEU operations + DPF (US)
KBOSS.hu Kft. (Számlázz.hu)Invoicing + NAV reportingHungary (EU)Intra-EU

Sub-processor detail

What is not on this list and why

Some parties handle Accord Blueprint data but are not sub-processors of Third Mind. We name them here for transparency.

Anthropic, PBC

Anthropic is the developer of the Claude language model used inside AWS Bedrock. We do not have a direct contractual relationship with Anthropic for the Accord Blueprint service. AWS (Europe) SARL holds the contract with Anthropic and provides the model to us as part of AWS Bedrock. Anthropic does not see your interview content directly; the model runs inside AWS infrastructure, and AWS Bedrock does not transmit customer inputs to Anthropic.

Your employer (the Customer organisation)

If you are a participant in an Accord Blueprint interview, your employer is a separate data controller, not a sub-processor of Third Mind. They receive the aggregated Blueprint Report from us and are responsible for their own use of it under their own data protection obligations.

Your VAT authority

For B2B EU sales, we report your VAT number on our quarterly EC Sales List filed with NAV (Hungary). For B2C cross-border sales we report through the EU One-Stop Shop scheme. These reports are made under a legal obligation, not under our processing instructions, so the receiving tax authorities are not our processors.

Raising a concern

If you have a question about a sub-processor, or you object to a notified change, contact our privacy team:

privacy@3rdmind.co.uk

We will respond within 5 business days.

Subscribe to change notifications

Material changes to this list (a new sub-processor, a removed sub-processor, or a change in location) are emailed to the Primary Contact of every active engagement. If you would like to receive notifications even when you do not have an active engagement, email subscribe-subprocessors@3rdmind.co.uk and we will add you to the notification list.

Lead supervisory authority

If you believe a sub-processor is being engaged in a way that breaches data protection law, you can complain to our lead supervisory authority:

Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH)

Address: 1055 Budapest, Falk Miksa utca 9–11.

Phone: +36 1 391 1400 · Email: ugyfelszolgalat@naih.hu · Web: naih.hu

UK customers may also complain to the UK Information Commissioner's Office at ico.org.uk.

End of Sub-processor List v1.0