Legal document
Subprocessors
The outside services that touch customer data on our behalf, what each one is for, and how you hear about a change before it happens.
Draft - pending legal review. This text was written by the product team, not by a lawyer, and it is published for comment while the company behind the product is being set up. It is not part of any contract until we say so in writing, and it will change after the legal review.
Square brackets mark a detail that is not decided yet. We would rather leave the gap visible than fill it with something that is not true.
1. What a subprocessor is
We are the processor for customer data. Anything we use that touches that data to do its job - the servers it runs on, the service that sends email, the model that reads an invoice - is a subprocessor. Article 28 of the GDPR requires us to name them, to bind them to the same duties in writing, and to remain responsible for what they do.
2. The list
The product is not launched yet and the operating company is not registered, so most of these are not contracted. A row that says to be announced before launch means exactly that: the choice has not been made. No name will appear below until a contract with that provider exists.
The table scrolls sideways on a narrow screen.
| Service | Provider | What reaches it | Where |
|---|---|---|---|
| Application hosting | to be announced before launch | Everything in the account: database, uploaded photographs and documents, backups | to be announced before launch |
| Transactional email | to be announced before launch | Name, email address and the text of account email: invitations, reminders, digests | to be announced before launch |
| AI gateway and models | to be announced before launch | Document images and text after masking, and the questions asked in the assistant | to be announced before launch |
| Payment provider | to be announced before launch | Billing contact and company details; card data is handled by the provider, not by us | to be announced before launch |
3. How changes are announced
- A new subprocessor is announced at least thirty days before it starts processing anything, by email to account administrators and by an update to this page with the date.
- A customer who objects on reasonable data protection grounds says so within those thirty days. We look for a way around it - a different provider, a different region, that feature switched off for that account.
- If there is no way around it, the customer can end the affected part of the subscription and get back what was paid for time not used. Nobody is locked into a supplier they do not accept.
4. Self-hosted installations
When the system runs on the customer's own server, this list mostly does not apply: the hosting, the database and the files are the customer's. The only outside service left is the AI gateway, and only while the AI features are switched on.
5. Questions
Anything about this list, including a copy of the contract terms we hold a subprocessor to, goes to [to be completed before launch].
Version 1.0, 18 September 2026. This page always shows the current version; earlier versions are kept and sent on request.
Questions about this document: [to be completed before launch].
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