Legal

Subprocessors

Ultron uses a small number of third-party services to deliver the platform. Each is engaged under data protection terms compatible with the GDPR. This page lists every subprocessor, where it is located, what category of personal data it touches, and what role it plays.

Updated today

Overview

A subprocessor is a third party we engage to process personal data on behalf of customers. We list each one publicly. We give at least thirty days advance notice before adding a new subprocessor that touches Customer Personal Data, and we let customers object on reasonable data protection grounds. The Data Processing Addendum describes the procedural detail.

Each table below lists the subprocessor, the country where data is primarily processed, the categories of data touched, and the function it performs. Country fields use the country of the operating entity rather than every datacentre location. Where the operating entity processes data outside the European Economic Area, transfers rely on the Standard Contractual Clauses and supplementary measures noted on the Security page.

Core platform

The infrastructure that hosts the application, the database, and the edge runtime.

SubprocessorCountryDataRole
Google Cloud (Cloud Run, Cloud Build, Artifact Registry)Ireland (eu-west / europe-west1)All Customer Personal Data in transit and at rest on the application tierHosts the Next.js application, builds images, stores artifacts
Cloudflare (Workers, R2, D1, Vectorize, Workers AI)United States, edge points globallyCached requests, R2-stored binary assets, D1 carousel engine state, Vectorize embeddingsProvides edge runtime, object storage, edge database, vector search, ancillary inference
Supabase (Postgres, Storage, Auth)Ireland (eu-west)Account data, content, embeddings, billing referencesPrimary database, file storage, authentication broker

Model providers

The vendors that run the foundation models behind the chat and skill loops.

SubprocessorCountryDataRole
AnthropicUnited StatesPrompts and conversation history sent for inference, tool results returned to the modelPrimary model provider for Haiku, Sonnet, Opus tiers
OpenAI (embeddings only)United StatesText passed to the embedding endpointGenerates 1536-dimensional vectors used for memory retrieval
Cloudflare Workers AIUnited StatesDefault lite-tier chat prompts, planner inputs, image-scoring inputs, classifier and docs-support inputsHosts and runs Kimi K2.6 (the default lite-tier model, authored by Moonshot AI), Gemma for planning, and LLaVA for image scoring. The model authors do not receive data directly; Cloudflare is the processor in this path
Note
We have a contractual no-training commitment with each model provider for Customer Personal Data submitted through the platform. None of the providers above are permitted to train foundation models on customer prompts, conversation history, or outputs.

Communications

Email delivery and notification providers.

SubprocessorCountryDataRole
BrevoFranceRecipient email addresses, message content, delivery metadataSends transactional email (account, lifecycle, share notifications) and customer outbound campaigns
Google (Gmail API, on customer consent)United StatesEmail content sent via the connected user's own Gmail accountSends and reads email on behalf of the connected user

Data ingestion

The actors and APIs that bring outside data into the workspace.

SubprocessorCountryDataRole
ApifyCzech RepublicSearch inputs, scraped results, webhook payloadsRuns the maps, jobs, and email-finder actors
ApolloUnited StatesLookups by name, email, domain, titlePeople and company enrichment
BrowserbaseUnited StatesURLs visited, content extracted via headless ChromiumResidential-proxy fallback for scraping
RedditUnited StatesSearch queries against Reddit JSON endpointsSource for the public Reddit research tool

Billing and tax

Payment processing and invoicing.

SubprocessorCountryDataRole
StripeIreland (EU operating entity)Cardholder name, billing address, last four digits of card, VAT identifier, invoice line itemsProcesses payments, hosts invoices, computes VAT
Note
Full card details never reach Ultron servers. Stripe tokenises the card at the customer's browser. We retain only the token and the safe display fields.

Support and observability

The tools we use to keep the lights on.

SubprocessorCountryDataRole
PostHogUnited States, EU hosting availablePseudonymised product analytics eventsProduct analytics and feature flag delivery
SentryUnited States, EU hosting availableError traces, user agent, masked user idError tracking

How changes are notified

We update this page when a subprocessor is added, removed, or replaced. Material additions are announced at least thirty days in advance with a banner inside the product and an email to the customers who subscribed to subprocessor notifications. To subscribe, write to privacy@51ultron.com.

How to object

Customers covered by the Data Processing Addendum can object to a new subprocessor on reasonable data protection grounds within the notice window. Send the objection and the grounds to privacy@51ultron.com. If we cannot resolve the objection, you may terminate the affected portion of the service and receive a prorated refund of any pre-paid fees for that portion.

Note
Publication-quality draft. The subprocessor list is accurate as of the last update; check the timestamp in the page header.