Sub-processor register
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 |