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Clause50EU AI Act evidence — starting with Article 50.EU AI Act evidence, starting with Article 50
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Subprocessors

Version 2026-10-subprocessors-4 · Effective 2026-10-12

The third parties Clause50 uses to help provide the service.

Subprocessors

These are the third parties we currently use, or plan to use, to provide the service.

SubprocessorPurposeData categoriesData locationTransfer basisStatus
VercelApplication hosting / edgeAll request data in transit; platform request logsFunctions pinned to fra1 (Frankfurt, EU)Contracting entity Vercel Inc. is US-established (Delaware); its DPA states its primary processing facilities are in the United States — covered by EU Standard Contractual Clauses (2021, Modules One–Three) and the UK IDTA, binding automatically on acceptance of Vercel's TermsActive subprocessor
Supabase (managed PostgreSQL)Primary databaseAccount, system, evidence, and artifact metadataAWS eu-central-1 (Frankfurt, EU)Contracting entity Supabase, Inc. is US-established. Its DPA is incorporated by reference into Supabase's Terms of Service (no separate signature required) — the specific ex-EEA transfer mechanism has not been independently verified from that textActive subprocessor
Cloudflare R2 (object storage)Evidence and artifact object storageUploaded evidence bytes; generated documentsCloudflare EU jurisdiction — objects are stored and served only from EU data centres, a hard placement guaranteeContracting entity Cloudflare, Inc. is US-established; its DPA covers any ex-EEA transfer of account/billing metadata (distinct from the R2 object bytes themselves) via EU SCCs or Cloudflare's EU-U.S. Data Privacy Framework certificationActive subprocessor
ResendTransactional email (sign-in links, alert digests, one-off free-scan results)Recipient email address; message contentSending region eu-west-1 (Ireland, EU)Contracting entity Plus Five Five, Inc. (San Francisco) is US-established and its DPA §6.1 states its primary processing occurs in the United States — covered by EU Standard Contractual Clauses (Module Two) and Resend's EU-U.S. Data Privacy Framework certificationActive subprocessor — DPA incorporated by reference on account creation (Resend's Terms of Service), no separate signature required
Gotenberg (hosted on Render)DOCX → PDF conversion of generated artifactsFull document bytes, transiently, during conversionWorkload runs in Render's Frankfurt (EU Central) regionContracting entity Render Services, Inc. (San Francisco) is US-established and its DPA §6.1 states its primary processing occurs in the United States — covered by the EU-U.S. Data Privacy Framework, with EU Standard Contractual Clauses as the contractual fallbackActive subprocessor — third-party-hosted, so document bytes leave our own infrastructure during conversion
Google (sign-in with Google)Optional sign-in: lets you authenticate with your Google account instead of an emailed link. Used only if you choose that buttonThat you signed in to Clause50 and when. We receive back your Google profile: verified email address, name and profile pictureDetermined by Google; Clause50 does not control where Google processes sign-in dataGoogle LLC is US-established; for sign-in data it relies on its own transfer mechanisms (EU Standard Contractual Clauses and its EU-U.S. Data Privacy Framework certification), which we have not independently verified from Google's current terms. Google acts under its own terms and privacy policy for the sign-in itselfActive — optional. Sign-in by emailed link is always available without Google
Polar Software, Inc.Payment processing and merchant of record (checkout, invoicing, VAT/tax remittance, chargebacks)Billing/payment details, name, email, billing address, purchase historyProcesses payments globally, including for EU customersUS-establishedActive subprocessor and merchant of record for paid plans
StripePayment processing infrastructure underlying Polar (sub-subprocessor — we have no direct relationship with Stripe)Billing/payment details, processed on Polar's behalfGlobal, on Polar's behalf — we have no direct relationship with Stripe to confirm furtherUS-establishedActive sub-subprocessor (via Polar)
AnthropicAI-assisted drafting: optional, switched on per system by the customer; drafts text and suggests follow-up questions from the answers recorded for that systemThe drafting answers recorded for that system (business and technical descriptions of the AI system, free text); the system and organisation nameNot stated in Anthropic's DPA; Clause50 does not request EU-only processing, so treat it as processing outside the EEA, including the United StatesContracting entity Anthropic, PBC is US-established; its DPA is incorporated into its Commercial Terms and incorporates EU Standard Contractual Clauses (Modules Two and Three). Anthropic may not train models on this content; it deletes inputs and outputs within 30 days by default, longer only if flagged for a usage-policy violationPlanned: used today only in a trial on Clause50's own test data. We will update this row and notify customers with a signed DPA before any customer's data is sent

Customer-directed integrations — not our subprocessors

GitHub, OpenAI, and Anthropic as connectors are not Clause50 subprocessors. When you connect one of these, you supply your own credential and we read data back from your own account on your instruction — the relationship is between you and that vendor, not us. Anthropic is listed above separately, for a different purpose: the optional AI-assisted drafting feature, where Clause50 itself sends data to it.

Changes to this list

We will update this page, and notify customers with a signed DPA, before adding a new subprocessor — not after.