Sub-processors — Markaloud

Sub-processors that see student work

Three providers, all under contract, none training on your data

Dictated audio and the transcript derived from it are personal data. Only these three see them.

Sub-processor	Purpose	Data it sees	Location	Trains on your data?	Retention
OpenAI, L.L.C.	Speech-to-text (Whisper) — converts the marker’s dictation to text	Audio recording and resulting transcript	United States	No. OpenAI’s Business Terms §4.2: “OpenAI will not use Customer Content to develop or improve the Services, unless Customer explicitly agrees to such use.” We have not opted in.	Up to 30 days for abuse monitoring, then deleted
AssemblyAI, Inc.	Speech-to-text for live transcript preview and for viva marking with speaker identification	Audio recording and resulting transcript	United States (EU region available)	No. Model-improvement training is disabled on our account.	See note below
Anthropic PBC	Structures the marker’s dictated comments against your rubric	Transcript text and the resulting feedback text	United States	No. Anthropic’s Commercial Terms: “Anthropic may not train models on Customer Content from Services.” We have not opted in.	30 days, then deleted

Note on AssemblyAI retention. Live transcript preview uses AssemblyAI’s streaming service, which retains neither audio nor transcript. For viva marking, the audio file is deleted automatically by AssemblyAI within 24–48 hours, and Markaloud issues a deletion request for the transcript as soon as the feedback has been generated — we do not rely on the provider’s default retention.

AssemblyAI implements deletion by removing the transcript content and retaining a record consisting only of an identifier, timestamps and status; the transcribed text, word-level data and audio reference are erased and cannot be recovered.

Sub-processors that do not see student work

Infrastructure, billing and email

Sub-processor	Purpose	Data it sees	Location
Civo Ltd	Application and database hosting; audio files at rest	All service data at rest	United Kingdom — Kao Data Harlow campus, Essex
Stripe Payments Europe, Ltd. / Stripe, Inc.	Subscription and credit-pack billing	Billing contact and payment data only. No student work, no feedback, no transcripts.	Ireland / United States
Resend, Inc.	Transactional email — password resets, receipts, notifications	Account holder’s name and email address only	United States — sending infrastructure in the EU (Ireland)

Your institution’s own systems are not sub-processors of ours. Where you use Canvas or Microsoft Entra SSO, those remain your systems under your own agreements; we send feedback to them at your instruction.

International transfers

Student work is stored in the United Kingdom

Transcription and feedback structuring are carried out by the three providers above, which process in the United States. These are restricted transfers under UK GDPR, and each is covered by the EU Standard Contractual Clauses as amended by the UK International Data Transfer Addendum, incorporated into that provider’s Data Processing Agreement:

OpenAI — Data Processing Addendum, UK Addendum clause
AssemblyAI — Data Processing Addendum, Exhibit D (International Data Transfer Addendum)
Anthropic — Data Processing Addendum, UK Addendum

We hold a Transfer Risk Assessment for each. Available to your DPO on request.

Security certifications

Held by our sub-processors

Sub-processor	Certifications
OpenAI	SOC 2 Type 2; ISO/IEC 27001:2022, 27017, 27018, 27701, 42001
AssemblyAI	SOC 2 Type 2
Anthropic	SOC 2 Type I and II; ISO/IEC 27001:2022; ISO/IEC 42001:2023
Civo	ISO/IEC 27001:2022 — certificate GB24111207, scope “Civo Public Cloud & AI”. The Harlow facility additionally holds ISO/IEC 27001, ISO 9001, 14001, 22301, 45001, 50001, SOC 2 Type 2, PCI DSS and Cyber Essentials Plus, and Uptime Institute M&O.
Stripe	PCI DSS Level 1; SOC 1 and SOC 2

What we don’t do

The commitments behind the table

We do not sell or share student data with anyone not listed here.
No sub-processor uses your students’ work to train AI models.
The AI never assigns a grade. The overall mark is computed arithmetically from criteria the marker has approved.
No feedback reaches a student until a marker has reviewed and approved it.
Marker-private notes are removed before any student-facing output is produced.

Three providers, all under contract, none training on your data

Infrastructure, billing and email

Student work is stored in the United Kingdom

Held by our sub-processors

The commitments behind the table

Changes to this list