Zoho publishes a sub-processor list, including AI sub-processors.
Zoho’s List of Sub-Processors describes third parties that may access or process service data, including a group of AI sub-processors that provide AI features in its products.
In April 2026, Zoho’s Terms & Conditions page added India-specific terms, with a named grievance officer and obligations for news publishers under India’s IT Rules. It says users outside India are covered by Zoho’s global terms.
What Zoho’s documents say about client data.
Quoted from the current version of each document. The right-hand column shows how many of the 75 vendors we monitor have a matching clause.
Sharing data with third parties
Addressed“A sub-processor is a third party data processor engaged by Zoho, who has or potentially will have access to or process Service Data (which may contain Personal Information).”
What changed, and when.
Notable changes since monitoring began in March 2026, newest first. Each is written from our automated comparison of the before and after versions, then reviewed by a person.
Added India-specific terms with a named grievance officer
Adds a grievance redressal section and obligations for news publishers under India’s IT Rules. Users outside India are covered by the global terms.
+ 7 other updates detected, such as formatting, page layout and wording changes.
- Oct 3, 2026: Encryption Whitepaper
- Oct 2, 2026: Compliance Center
- Sep 10, 2026: Compliance Center
- Sep 4, 2026: GDPR Compliance
- Sep 3, 2026: Privacy Commitment
- Sep 1, 2026: Privacy Policy 1
- Aug 6, 2026: Compliance Center
11 Zoho documents.
Sub-documents are other Zoho documents that its policies link to, such as addenda and product terms. We list the ones identified so far; there may be others.
Zoho terms: common questions.
Does Zoho publish a sub-processor list?
Yes. Zoho publishes a List of Sub-Processors, including AI sub-processors that provide AI features in its products. Legal Sentinel monitors it for changes.
When did Zoho last change its terms?
The most recent notable change was on April 19, 2026, when Zoho’s Terms & Conditions page added India-specific terms with a named grievance officer.