Sub-Processor List

Introduction

This document lists the third-party sub-processors that THEAX LTD (trading as Axel Up, A.X.E.L, and AXEL.TRADE) uses to provide A.X.E.L Portal services. These companies may process your personal data as part of delivering our services.

We work only with reputable providers who maintain appropriate data protection standards and comply with applicable privacy laws including UK GDPR.

Current Sub-Processors

The following table shows all third-party processors currently used in our services:

Recipients That Are Not Sub-Processors

We also exchange data with the following. They are not sub-processors, because they do not process data on our instructions — each is an independent controller of the data it receives or publishes.

• HM Revenue & Customs (HMRC). The recipient of tax submissions you choose to make: Self Assessment, VAT, CIS, and corporation tax returns. HMRC determines its own handling and retention of what you file
• Xero (Xero Limited) and QuickBooks (Intuit Inc.). Accounting software you can choose to connect. When you do, we read your chart of accounts and reports from it to fill in your figures; each is an independent controller of the data you keep with them. Disconnect them at any time from your account
• Companies House. The source of the public register data we look up when you file a corporation tax return, including your company profile and, if you use the import, your last filed accounts. It is also the recipient of the accounts you choose to file through A.X.E.L Filing, which it publishes on the public register

A.X.E.L Filing and AI

No AI sub-processor touches corporation tax filing data. The A.X.E.L Filing path — the tax computation, the accounts, the computations, and the submission — uses none of the AI providers listed above. Your company's financial figures are not sent to any AI or machine learning service, and are not used to train any model.

The AI sub-processors listed above serve other A.X.E.L Portal features, such as voice capture, lead scoring, and expense categorisation.

Data Transfer Safeguards

Where personal data is transferred to sub-processors located outside the UK/EU, we ensure appropriate safeguards are in place:

Adequacy Decisions

Some transfers rely on adequacy decisions where the UK has determined that the destination country provides adequate data protection.

Standard Contractual Clauses

For transfers to countries without adequacy decisions, we use Standard Contractual Clauses (SCCs) approved by UK and EU authorities to ensure your data receives equivalent protection.

Additional Safeguards

• Technical measures such as encryption in transit and at rest
• Contractual restrictions on data usage and sharing
• Regular audits and compliance assessments
• Transparency reports from major processors

Sub-Processor Selection

We carefully evaluate all sub-processors based on:

• Data protection compliance: GDPR, UK GDPR, and other applicable regulations
• Security measures: Technical and organizational safeguards
• Contractual protections: Data processing agreements and liability terms
• Industry reputation: Track record and certifications
• Geographic considerations: Data residency and transfer requirements

Changes to Sub-Processors

Notification Process

We will notify you of changes to our sub-processor list by:

• Updating this page with at least 30 days' advance notice
• Sending email notifications for significant changes
• Publishing update announcements in your account dashboard

Right to Object

You have the right to object to the appointment of a new sub-processor. If you object:

• Notify us in writing within 30 days of the announcement
• We will work with you to address your concerns
• If we cannot reach a resolution, you may terminate your agreement without penalty

Sub-Processor Compliance

All sub-processors are required to:

• Process personal data only as instructed by us
• Implement appropriate technical and organizational security measures
• Maintain confidentiality of personal data
• Assist with data subject rights requests
• Notify us of any data breaches without undue delay
• Delete or return personal data when instructed

Your Rights

Regarding sub-processor arrangements, you have the right to:

• Object to new sub-processors as described above
• Request information about specific sub-processing arrangements
• Exercise your data subject rights regardless of where your data is processed
• Receive copies of relevant data processing agreements upon request

Contact Information

For questions about sub-processors or to exercise your rights:

• General inquiries: info@axel.trade
• Data protection matters: privacy@axel.trade
• Sub-processor objections: Include "Sub-Processor Objection" in the subject line