This is Annex 2 to the data-processing schedule, published at its own permanent URL under its own version identifier. It is the same list for every TIF Suite customer, whichever of our companies is the contracting entity. Changing an entry moves this list to a new version without moving the terms of use.
2026-08-31. It is versioned independently of TERMS_OF_USE_VERSION and compared by exact string equality only.Downloadable copy. This document must be provided in a form you can store and reproduce. A link to this page is not that; the PDF below is.
Download PDFThis list is published by TIF Synergy Ireland Limited (registered in Ireland, company registration number 821025, registered office 77 Camden Street Lower, D02 XE80, Dublin, Ireland) and by Blauw Belastingen B.V. (KVK 58905375, Oudezijds Achterburgwal 173, 1012 DJ Amsterdam, the Netherlands). It is Annex 2 to both entities’ data-processing schedules and is identical for both.
This annex has its own version identifier: SUBPROCESSOR_LIST_VERSION = 2026-08-31. It changes under clause DP6 and a change to it is not a change to the terms of use. Published at https://www.tifsynergy.com/legal/sub-processors/. Every superseded version stays available at https://www.tifsynergy.com/legal/sub-processors/ followed by that version's identifier.
This list is the same list for every TIF Suite customer, whichever of our companies is your contracting entity. The "engaged by" column says who engaged each entry. The data-processing schedule that applies to you says which of the entities named here is your processor and which are sub-processors, and in this annex "we" means whichever of our companies is your contracting entity under that schedule.
Column key. "Whose data" says which of the two roles the entry sits in. Your content means data you put into a tool, for which you are the controller and we are the processor: these are the entries your authorisation under clause DP6.1 covers. Account data means data about the people who use a tool, for which we are the controller: listed for transparency, not for your authorisation.
| # | Sub-processor | Legal entity | Engaged by | What it does | Whose data | Tools | Location and transfer basis |
|---|---|---|---|---|---|---|---|
| 1 | Microsoft Azure, compute and storage | Microsoft B.V., Evert van de Beekstraat 354, 1118 CZ Amsterdam, Netherlands. KvK 34061536 | Blauw Belastingen B.V. | Hosting: Container Apps, Blob, Files, Cosmos DB, PostgreSQL, Key Vault | Your content and account data | All four | West Europe, Netherlands. Microsoft personnel and Microsoft companies outside the EEA can reach this data, by the four routes at clause DP7.2: engineering remote access, security processing transferred to any Azure region worldwide, network transit and directory replication. Those transfers are made by Microsoft under the standard contractual clauses annexed to the Microsoft Products and Services Data Protection Addendum. Microsoft's EU Data Boundary commitments limit where processing is performed and are not themselves a transfer mechanism |
| 2 | Microsoft Entra External ID | Microsoft B.V. | Blauw Belastingen B.V. | Identity and sign-in | Account data | All four | Netherlands tenant. Microsoft's own access as row 1 and two of those routes are specific to this service: Microsoft processes sign-in data centrally across geographies for security purposes such as detecting an impossible journey between two sign-ins. It may also replicate limited directory data, including a username and an email address, outside the EU Data Boundary to provide the service |
| 3 | Azure OpenAI Service | Microsoft B.V. | Blauw Belastingen B.V. | Answer composition, embeddings, tag suggestion | Your content | TaxLex, TaxTag | TaxTag: West Europe, on a deployment confined to Microsoft's EU data zone. TaxLex: the accounts are in Sweden Central and West Europe, both in the EEA and answer composition runs on a deployment inside Microsoft's EU data zone by default. Two models a user can select in TaxLex, gpt-5.4-nano and gpt-5.4-pro, exist only as globally routed deployments, so Microsoft may process a request sent to either in any region in which the model is deployed, including outside the EEA. Content from documents in your library is never sent to either: where library content is in the material assembled to answer a question, TaxLex uses the EU deployment. Your question is also turned into a search vector by this same service before any model sees it. That step runs on the West Europe account, on a deployment confined to Microsoft's EU data zone, so it is the model you choose that decides whether a request leaves the EEA rather than this step. Where a TaxLex request is served from is not fixed in advance. Data stored at rest stays in the geography the resource is in whichever deployment type serves the request; only the place of processing changes. Transfers on this route are made by Microsoft under the standard contractual clauses annexed to the Microsoft Products and Services Data Protection Addendum. See clause DP7.3 and section 5A of our transfer impact assessment. Microsoft's acceptable use policy and its Enterprise AI Services Code of Conduct, which clause 6.5 of the terms requires you to keep to, are published at https://aka.ms/AI-CoC |
| 4 | Azure AI Document Intelligence | Microsoft B.V. | Blauw Belastingen B.V. | Reading uploaded documents | Your content | TaxLex, TaxTrack | West Europe. Microsoft's own access as row 1 |
| 5 | Azure AI Search | Microsoft B.V. | Blauw Belastingen B.V. | Search index behind TaxLex | Your content | TaxLex | West Europe. Microsoft's own access as row 1 |
| 6 | Azure Monitor, Application Insights and Log Analytics | Microsoft B.V. | Blauw Belastingen B.V. | Telemetry and a copy of the audit log | Account data | TaxLex, TaxTag, TaxTrack | West Europe. Microsoft's own access as row 1 |
| 7 | Azure Communication Services Email | Microsoft B.V. | Blauw Belastingen B.V. | Notification and questionnaire-invitation emails | Account data and the recipient's details | TaxTrack | Europe data location. Microsoft's own access as row 1 |
| 8 | Microsoft 365, being the email and productivity system our group uses to correspond with you | Microsoft B.V. | Blauw Belastingen B.V. | Correspondence with you about the tools, including support, data-subject requests we pass on to you and the notices we send you under clause DP6.4 | Your content and account data, both, because support correspondence about your problem routinely carries extracts of your content | All four | We do not state a data location for this service. That is a disclosure rather than an omission. A Microsoft 365 tenant's data location is a per-service setting that can differ between Exchange, SharePoint and Teams, so one country in this cell would flatten several answers into one. We tell you the current per-service locations on request. That is a commitment we give here rather than an invitation to ask. We do not print a location we have not read off the tenant. What is stated, because it is the part of this row a reader needs: Microsoft personnel and Microsoft companies outside the European Economic Area can reach data held in this service, as they can for the Microsoft services at rows 1 to 7, under the same Microsoft Products and Services Data Protection Addendum. A transfer out of the EEA on that route is made by Microsoft under the standard contractual clauses annexed to that addendum. The four routes set out at row 1 are written from Microsoft's Azure material, so they are not restated here as though they had been read for this service. This is the mailbox through which every human interaction about your content passes, so the access position is stated in its own right rather than left to be inferred from another row. |
| 9 | SendGrid | Twilio Inc. or SendGrid, Inc., both Delaware corporations. Twilio's data protection addendum names both as possible contracting parties. We do not state which of them holds the account, because the answer changes nothing you would rely on: Twilio Inc. is the organisation self-certified under the framework and the named data importer under the clauses on either footing. | Blauw Belastingen B.V. | Password-reset email and the Pillar Two alert digest | Account data only. No content you put into a tool ever passes through this route | TaxLex | United States. Twilio's addendum ranks two mechanisms rather than naming one. First the EU-US Data Privacy Framework, Twilio Inc. being the organisation self-certified under it. Second the standard contractual clauses, designated to apply automatically if that self-certification falls away. Twilio Inc. is the named data importer under those clauses whichever company holds the account, so the ranking is the same either way. The module of those clauses is stated in the data-processing schedule that applies to you |
| 10 | Blauw Belastingen B.V., trading as TIF Synergy | Blauw Belastingen B.V., a private limited company incorporated in the Netherlands, KvK 58905375, registered office in Amsterdam, Netherlands | TIF Synergy Ireland Limited | Development, hosting, operation and support of the tools. It engages the providers at rows 1 to 9 | Your content and account data, both | All four | Netherlands. Inside the European Economic Area, so not a transfer within Chapter V and no transfer mechanism is needed. See clause DP7.3 |
| Version | Date it applies from | What changed |
|---|---|---|
2026-08-28 | 28 August 2026 | First published version |
2026-08-31 | 31 August 2026 | Anthropic Ireland, Limited removed. It is no longer engaged, so under clause DP6.2 it is no longer on the current list. No entry was added, no other entry changed and the entries below it were renumbered to close the gap |