Sub-processor register

Version 1.0.1 · 9 November 2026

Version 1.0.1 (2026-11-09) · Processor: Advanced Technologies LTD (Mauritius) · Contact: privacy@synapdash.com. Built from the code (outbound hosts in apps/api, apps/control-plane, apps/mobile) and kept in sync with it. Transfers outside Mauritius follow section 36 of the DPA 2017, and transfers of EU/UK data use the Standard Contractual Clauses or an adequacy decision (see the DPA §5). We accept each vendor's data processing terms before data reaches it.

How to read it. SynapDash is a platform, and many integrations run only when a customer turns them on (customer-directed). The customer chooses the vendor and usually brings their own account or key. Under the DPA those vendors are the customer's own processors or independent controllers, not ours. They are still listed here so that customers know where data can go. The Default column says whether a standard SynapDash plan sends data there without any customer action.

Columns:

  • Data: the categories that leave SynapDash.
  • Trigger: the code path or setting that sends it.
  • Default: ✅ always on for that feature · ⚙️ only after the customer enables it or brings a key · 🌑 dark feature, not live · 📝 planned, not in code yet.

1. Hosting and infrastructure

Vendor Purpose Data Region Default Notes
Hetzner Online GmbH Production platform hosting (API, web, database, agents) and the CI server All customer data at rest and in processing EU (Germany, Finland) ✅ Client instances (fleet, Phase 3) will run on the hosts the fleet assigns. Region promise = decision D-6
OVH SAS Development server and consolidated web hosting. Encrypted backups of migrated servers Customer data only on hosted client websites and in backups EU (OVH European data centres) ✅ (operator) No SynapDash tenant data is planned to live on the dev server
Microsoft (OneDrive) Encrypted off-site backup copy (operator path, decision 14) Encrypted backup archives. Microsoft holds no key EU / per the Microsoft 365 tenant ✅ (operator) Backups are encrypted before upload
GitHub, Inc. Source code, CI orchestration No customer personal data (code and CI logs only) US ✅ Supplier, not a sub-processor of customer data. CI uses synthetic data

2. AI model providers

A conversation turn is sent to the provider that the agent, the customer's plan or the customer's own subscription or key selects. Prompts can contain anything a user types, plus memory and context the agent injects. Passwords and secrets typed in chat are replaced by vault placeholders before any provider call when the chat secret vault is on (CHAT_SECRET_GUARD_ENABLED, docs/modules/secret-vault.md).

Vendor Purpose Data Region Default Notes
Anthropic PBC LLM inference (Claude, through the Claude Code CLI or the API) Prompts, conversation context, tool results, files the user shares US ✅ Customers can bring their own subscription or key (decision 1). Their own account terms then apply
OpenAI, L.L.C. LLM inference (API, Codex CLI), speech-to-text (Whisper), text-to-speech (tts-1), image generation and editing Prompts, audio of voice notes, text to synthesise, images US ✅ Same bring-your-own option
Groq, Inc. Fast inference (contact-memory summaries, classifiers), speech-to-text Prompts, conversation excerpts, voice-note audio US ✅ Contact-memory falls back to Anthropic when Groq is rate-limited
OpenRouter, Inc. Routes requests to third-party models Prompts and context US, plus the model host OpenRouter selects ⚙️ The underlying model host is a further sub-processor of OpenRouter. Restrict to providers with zero-retention terms before offering it to customers
Google LLC (Gemini API) Image generation and editing, multimodal Prompts, images US / global ⚙️
Stability AI Ltd Image generation (optional backend) Prompts, images UK / US ⚙️
ElevenLabs, Inc. Text-to-speech, music generation Text, lyrics, prompts US / EU ⚙️
Suno, through sunoapi.org (third-party API) Music generation Prompts, lyrics not published by the reseller ⚙️ Reseller API. Check its terms before offering it to customers

3. Messaging and channels

Vendor Purpose Data Region Default Notes
Meta Platforms (WhatsApp Business Cloud API) WhatsApp channel, target default for client instances (decision 2) Phone numbers, messages, media, delivery status global ⚙️ The customer connects their own WhatsApp Business number through Embedded Signup
WhatsApp (Baileys / WhatsApp Web, Meta) Legacy WhatsApp channel (owner use) Same as above global ⚙️ Unofficial protocol: risk notice shown, can be switched off fleet-wide
Telegram, Discord, Slack Optional channels Messages and identifiers in those channels global ⚙️ customer-directed
Amazon (Alexa) Voice channel skill Voice-turn text and the Alexa user id (hashed at the control plane) US / EU 🌑 docs/plugins/alexa/
Expo (650 Industries), then Apple APNs / Google FCM Mobile push notifications Push token, notification title and preview US 🌑 (MOBILE_PUSH_ENABLED) Previews follow the quiet-hours and privacy settings
Email relay (SMTP, operator-configured) Sign-in links, OTP, notifications Email address, message body depends on the relay chosen ✅ Name the relay here once it is chosen
Resend, Inc. Transactional email for some plugins Email address, message body US ⚙️

4. Customer-directed data integrations

The customer connects their own account. SynapDash reads and writes only what the granted scopes allow, and the vendor is the customer's provider.

Vendor Purpose Data Default
Google (Gmail, Calendar, OAuth) Email and calendar plugins Email, events, contacts the scopes allow ⚙️ / 🌑 (calendar)
Microsoft (Graph, Outlook) Email and calendar plugins Same ⚙️ / 🌑 (calendar)
Spotify Playlist drafts (owner-confirmed) Playlist metadata ⚙️
Home Assistant (customer's own server) Smart home Device states, commands 🌑 (HOME_ENABLED)
Index Éducation (Pronote) School data for families Grades, timetables of the customer's children ⚙️

5. Web tools and safety services

Vendor Purpose Data Default
Brave Search, SearchApi.io, SerpApi, DuckDuckGo Web and travel search on the user's request Search queries ⚙️
Travelpayouts / Aviasales Travel price lookups Route and date queries 🌑 (TRAVEL_PRICES_ENABLED)
OpenStreetMap (Nominatim) Geocoding of shared locations Coordinates or place names ⚙️
abuse.ch (URLhaus) URL reputation (feed download, lookups stay local) None (feed download) 🌑
Google Safe Browsing URL reputation, only with a key URLs being checked 🌑
OSV.dev (Google) Dependency vulnerability lookups (agent tool) Package names and versions only ⚙️
Weights & Biases RL training tool (operator only) Training metadata ⚙️ operator

The agentic browser runs on a self-hosted browserless sandbox. Pages are fetched from SynapDash infrastructure, and no third-party browser service is involved.

6. Payments (planned — decisions 3, 3b, 3c)

Vendor Purpose Data Default
Peach Payments Card processing (Mauritian entity, local cards) Billing name, email, amount. Card data stays with Peach (hosted fields) 📝
Stripe, Inc. Card processing (international or non-Mauritian entity) Same. Card data stays with Stripe 📝
PayPal Wallet payments, billing plans Same 📝

Stablecoin and SynapCoin rails are self-operated adapters. AfDEX Pay is internal only and never appears in customer copy.

Change log

Version Date Change
v0.1 2026-11-09 First inventory from the code (lane E, P5-min)
v1.0 2026-11-09 Final (decision 17): processor Advanced Technologies LTD, hosting regions, transfer basis
v1.0.1 2026-11-09 Contact address updated