This is an announcement for an upcoming general subprocessor addition. In keeping with our data processing agreements and obligations and commitment to transparency, FreedomPay is providing advance notice of an intended addition to FreedomPay's list of subprocessors.
Subprocessor Name: OpenAI OpCo LLC Processing Location: United States
Service Provided: OpenAI OpCo LLC provides the product known as "ChatGPT". FreedomPay is enabling the ability for ChatGPT to integrate with our Microsoft 365 environment to support internal productivity initiatives, document handling, and customer and tech support operations. To further clarify, OpenAI OpCo LLC and ChatGPT does not have access to the FreedomPay credit card gateway or FreedomPay production environment or have any impact on PCI DSS scope.
Nature and categories of data processed: In providing this service, OpenAI OpCo LLC has the ability to process personal data contained in the FreedomPay Microsoft 365 tenant, within the connected scope. This includes FreedomPay customer communications and any data contained therein.
Safeguards: OpenAI OpCo LLC processes this data as our processor and subprocessor under a data processing agreement incorporating the EU Standard Contractual Clauses and the UK addenda where applicable as the transfer mechanism. Access is delegated and read-only, data is encrypted in transit and at rest, and OpenAI OpCo LLC maintains independent security assurances (including various ISO/IEC certifications and an AICPA SOC report). OpenAI OpCo LLC does not use information provided by FreedomPay to train its models.
Planned Effective Date: October 19th, 2026 Objection Deadline: October 16th, 2026
If you have a reasonable data protection or data security concern about this change, please let us know prior to the deadline above at compliance@freedompay.com. If we do not hear from you by the objection deadline, the change will be deemed accepted and shall take effect. If a reasonable concern is raised about this incoming subprocessor, we will work with you in good faith to address it before proceeding. The current FreedomPay subprocessor page is available at: https://corporate.freedompay.com/subprocessors
Thank you for your continued trust. Please reach out to compliance@freedompay.com with any questions.
Posted Sep 15, 2026 - 18:13 EDT
This scheduled maintenance affects: Subprocessor List.