Last Update: July 2026
Cloud4Wi uses certain sub-processors to help provide its Services. A sub-processor is an entity engaged by Cloud4Wi that processes personal data on behalf of Cloud4Wi customers, in accordance with customer instructions as communicated by Cloud4Wi, and under a written contract with Cloud4Wi containing data protection obligations no less protective than those in the Data Processing Agreement (“DPA”).
This page is the list of sub-processors referred to in section 2.6 of the DPA and in Annex III to the Standard Contractual Clauses incorporated in Annex 3 of the DPA. Cloud4Wi gives at least thirty (30) days’ notice of any intended addition or replacement of a sub-processor, and customers may object on reasonable data protection grounds as set out in section 2.6 of the DPA. [To receive notice of changes, subscribe to this article using the Follow button, or contact privacy@cloud4wi.com.]
1. Cloud4Wi group entities
Which Cloud4Wi entity is your processor depends on which entity you have contracted with under the “Cloud4Wi Contracting Entity, Notices, Governing Law, and Venue” section of the Master Subscription Agreement. The other group entity acts as a sub-processor.
| Entity | Location | If you contract with Cloud4Wi Inc. | If you contract with Cloud4Wi SRL | Transfer safeguard |
| Cloud4Wi Inc. | United States | Processor | Sub-processor: platform operation, hosting (holder of the AWS account), technical support | Standard Contractual Clauses: Module Two in DPA Annex 3 where you contract with Cloud4Wi Inc.; Module Three under the Cloud4Wi intra-group data protection agreement where you contract with Cloud4Wi SRL |
| Cloud4Wi S.r.l. | Italy | Sub-processor: software development, maintenance and support | Processor | No third-country transfer |
Cloud4Wi Inc. also processes aggregated service telemetry as a controller in its own right, as described in section 2.2(b) of the DPA. That processing is not sub-processing and is not covered by this list.
2. Third-party sub-processors
| Sub-processor | Function | Types of personal data | Processing location | Transfer safeguard |
| Amazon Web Services, Inc. | Hosting; email service | Profile data, authentication data, activity data, location data of data subjects | Ireland (EEA), AWS Europe (Ireland) region. United States for the Cusna application layer | AWS DPA; EU-U.S. Data Privacy Framework certification |
| Zendesk, Inc. | Support ticketing | Contents of support requests, which may include end-user data shared by the customer | United States | Zendesk DPA incorporating Standard Contractual Clauses [and EU-U.S. Data Privacy Framework certification — confirm] |
| Twilio, Inc. | SMS delivery for captive-portal login, global destinations (optional, where enabled by the customer) | Phone number of data subjects | United States | Twilio DPA incorporating Standard Contractual Clauses [and EU-U.S. Data Privacy Framework certification — confirm] |
| Mobyt S.p.A. | SMS delivery for Italian destinations (optional) | Phone number of data subjects | Italy (EEA) | No third-country transfer |
| Celonis Inc. | Integration services (optional) | Profile and activity data of data subjects | Europe | Written sub-processing contract |
| Bubble Group, Inc. (Bubble.io) | Application platform for the Cusna MDU access solution (Cusna only) | Resident, user and administrator data of Cusna deployments | United States | Bubble DPA incorporating Standard Contractual Clauses |
| Dimension Data China/Hong Kong Ltd | Hosting (optional, for deployments in mainland China only) | Profile data, authentication data, activity data, location data of data subjects | China | [Confirm whether still active; if so, the applicable safeguard and PIPL position] |
| Google LLC [or Google Cloud EMEA Limited, if accessed through Vertex AI] | AI model (Gemini Flash-Lite) for the Hedy AI Assistant. Optional: used only where a customer administrator has enabled Hedy and accepted the Hedy AI Assistant Terms of Use | Prompts and responses of customer administrators, any data they submit in a prompt [and tenant data retrieved by Hedy to answer a prompt — confirm]. Not used by Google to train or improve its models | [United States / processing region as configured — confirm] | Google data processing terms for services where Google is a processor, incorporating Standard Contractual Clauses; Google LLC is certified under the EU-U.S. Data Privacy Framework |
3. Where customer data is stored
Customer Data for the Guest WiFi and Cloud NAC platform is stored in Amazon Web Services data centres in the AWS Europe (Ireland) region. There are two exceptions:
- Cusna MDU access solution. The Cusna application layer is hosted in the United States, on Amazon Web Services and on Bubble.io, so Cusna data is stored in the United States.
- Deployments in mainland China. Where a customer deploys the Services in mainland China, Customer Data is hosted by Dimension Data in China.
Cloud4Wi does not own the physical infrastructure, which is operated by Amazon Web Services. Access to the AWS account is held and controlled by Cloud4Wi Inc. Personnel of Cloud4Wi Inc. in the United States may access EEA-hosted Customer Data to provide, support and secure the Services. That access is a transfer of personal data to the United States, and is covered by the Standard Contractual Clauses described in Annex 3 of the DPA, together with the supplementary measures set out there.
4. Content delivery networks
Certain Cloud4Wi product components use content delivery networks (“CDNs”) to optimise content delivery. CDNs are distributed services that deliver content based on the geographic location of the person accessing it.
| Service using CDNs | CDN used | Location | Description |
| Cloud4Wi Splash Pages | Amazon CloudFront | Global | Web pages rendered by splashportal.cloud4wi.com, including page content, JavaScript and CSS, may be cached by Amazon to speed up delivery. Information transmitted across Amazon’s network may be accessed to enable these functions. Delivery uses HTTPS. |
5. Questions
You can request a copy of this list, or of the safeguards described on this page, at any time by contacting privacy@cloud4wi.com.