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Legal · Version 0.9.0-draft · Last updated 2026-10-02

Subprocessors

Service providers that process personal data on our behalf for the website/waitlist (and — once released — the mobile app). Generated from the vendor registry (src/lib/compliance/vendors.ts) so it cannot drift from code. Only assessed roles are publicly asserted.

Owner
Privacy
Status
DRAFT
Effective
2026-10-07
Next review
2026-12-01
Jurisdictions
Global

Draft for legal review

This document is an implementation draft written to match how the product actually behaves. It has not been reviewed by a qualified lawyer and must not be relied on as legal advice. Items marked [PLACEHOLDER] or LEGAL REVIEW REQUIRED are unresolved.

1. Current subprocessors (live table below)

Supabase — managed PostgreSQL + object storage — waitlist/contact/consent records — US (region to confirm) via AWS infra — DPA https://supabase.com/legal/dpa — mechanism SCCs/DPF VERIFY + TIA pending — retention per retention-matrix — deletion via service-role + backup lifecycle — CONTRACTED — last reviewed 2026-10-02 — LEGAL REVIEW REQUIRED.

Clerk — authentication/identity — email/name/ID/session — US — DPA https://clerk.com/legal/dpa — mechanism SCCs/DPF VERIFY + TIA pending — retention until account deletion — deletion via Clerk API — CONTRACTED — last reviewed 2026-10-02 — LEGAL REVIEW REQUIRED.

Hosting/CDN — transit metadata — Cloudflare (Workers + global edge; region list per Cloudflare) — DPA acceptance + TIA PENDING — not publicly asserted until assessed.

No email/CRM/support/analytics/marketing/AI provider is integrated. Adding one requires vendor review (data/purpose/role/country/subprocessors/DPA/security/transfer/retention/deletion/contract/last-reviewed/legal-review) before it processes data.

2. Role classification, contracts and transfers

Role is unclassified until a signed DPA establishes processor status — we do not publicly claim 'processor' without verification. Transfer mechanism + safeguards + assessment per transfer-register.md; adequacy/SCCs/IDTA/BCRs/consent/contract as applicable per jurisdiction (see Privacy Policy Section 15). Subprocessors of subprocessors (e.g. AWS for Supabase) are disclosed where the vendor discloses them.

3. Changes and notice

We update this list before a new provider processes data and, where required (enterprise/B2B, or where local law requires advance notice), give advance notice with an objection/termination path. Version 0.9.0-draft, last updated 2026-10-02. Full registry fields: vendor/service/data/purpose/role/country/subprocessors/DPA/security/transfer/retention/deletion/contract/last-reviewed/legal-review (see SubprocessorTable component).

Sources

This document is derived from the following entries in our legal source registry: EU-GDPR, UK-GDPR, IN-DPDP, BR-LGPD, INT-SCC. See compliance/legal-source-registry.md for the full citations and the date each source was last verified.

Current subprocessors

Service providers that process personal data on our behalf
ProviderServiceDataLocationRole
SupabaseManaged PostgreSQL database and object storageWaitlist signup data, Contact messages, Consent evidence recordsUnited States (project region to be confirmed)Under reviewTransfer review pending
ClerkAuthentication and identityEmail address, Name, Clerk user identifier, Session metadataUnited StatesUnder reviewTransfer review pending

We do not name a provider as a processor until its role and transfer mechanism have been verified. Where that review is pending it is shown above rather than assumed.