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Template to be reviewed by legal counsel before going to production.

This document is provided for informational purposes only. It contains fields to be completed (in square brackets) and must be adapted to your actual situation by a legal professional before any publication.

Register of Subprocessors

Last updated: [DATE DE MISE A JOUR]

This register lists the subprocessors that [RAISON SOCIALE] uses to provide the B2B prospecting service. It supplements the data processing agreement (DPA) and the privacy policy. The purposes, locations, and safeguards indicated are provided for informational purposes and must be verified and kept up to date.

List of subprocessors

SubprocessorPurposeLocationSafeguards
SupabaseDatabase and hosting of application data (accounts, prospects, exchanges)European Union / United States (depending on the project region)Provider DPA, standard contractual clauses (SCCs) for transfers outside the EU
RailwayHosting of the application (running the service, back end)United States / European Union (depending on the deployed region)Provider DPA, standard contractual clauses (SCCs)
Google (Gmail / Calendar API)Sending and reading emails, calendar access, only if the Client connects their Google accountEuropean Union / United StatesGoogle terms and DPA, standard contractual clauses (SCCs). Optional connection at the Client's initiative
AnthropicArtificial intelligence processing (drafting, analysis) via the Client's own API key (BYOK model)United StatesContract entered into directly between the Client and Anthropic; provider terms and DPA, standard contractual clauses (SCCs)
OpenAIArtificial intelligence processing (drafting, analysis) via the Client's own API key (BYOK model)United StatesContract entered into directly between the Client and OpenAI; provider terms and DPA, standard contractual clauses (SCCs)
ResendSending transactional emails (notifications, invitations, account security)United StatesProvider DPA, standard contractual clauses (SCCs)
StripePayment processing and subscription managementEuropean Union / United StatesProvider DPA, standard contractual clauses (SCCs), PCI-DSS compliance

Details on the BYOK model

Artificial intelligence processing (Anthropic, OpenAI) is performed using the Client's own API key. The Client contracts directly with the AI provider of their choice, accepts its terms, and bears its billing. The data submitted to the AI passes through the Client's account with that provider.

Updates

This register may change over time. Any substantial change to the list of subprocessors is communicated to clients in accordance with the DPA, and clients may object to a change on legitimate grounds. For any question, contact [EMAIL DPO].