Boardroom Answers · Security & Compliance · Compliance, Regulatory & Legal
Sub-processor Disclosure: Listing Every Third Party
The question a Chief Compliance Officer (CCO) asks: “Enumerate every third party that touches my data. Vendors always forget two — don't be that vendor.?”
The short answer
Ten sub-processors, all named in the DPA: Vercel, Supabase, Clerk, Anthropic, OpenAI, Lemon Squeezy, Stripe, Resend, Sentry, PostHog. Each gets the minimum data for its job — AI providers get redacted text, payment processors get cards we never see.
The full executive answer
Here is the complete sub-processor list, the same one that appears in our Data Processing Agreement — ten names, each with a purpose: Vercel (application hosting and delivery), Supabase (the Postgres database and file storage, running on AWS in Tokyo), Clerk (identity and sign-in), Anthropic and OpenAI (the two AI model providers — sent only sanitised, PII-redacted inputs, with no training on your data under our API terms), Lemon Squeezy and Stripe (payments — card data never touches our systems; it goes directly to them as PCI-certified processors), Resend (transactional email), Sentry (error monitoring, with data scrubbing configured), and PostHog (product analytics). That's the whole list. No shadow analytics, no data brokers, no offshore support tooling with database access.
How we manage them: every one is a major, security-certified provider — the deliberate strategy is to inherit certified infrastructure (Supabase's AES-256 encryption at rest, Vercel's SOC 2, Stripe's PCI-DSS Level 1) rather than build uncertifiable custom plumbing. Our ISO Statement of Applicability explicitly marks controls satisfied by sub-processors as "inherited," so the dependency is documented, not hidden. Data minimisation applies per processor: the AI providers get redacted text, not your database; the analytics layer gets usage events, not board content; the email provider gets addresses and notifications, not documents.
What the honest version includes: our formal vendor-review cadence — annually re-verifying each sub-processor's certifications and DPA terms on a schedule — is being formalised as part of SOC 2 readiness this year; today it's point-in-time diligence rather than a calendared programme. Contractually, our DPA includes the sub-processor list with a notice-and-objection mechanism for changes, which is the Article 28 standard your team will expect.
Grounded in: GDPR Art. 28(2)/(4) (sub-processor authorisation and flow-down); SOC 2 TSC CC9.2 (vendor risk); ISO 27001 A.5.19–A.5.22 (supplier relationships).
The natural next questions
Related governed answers
- If a regulator or opposing counsel demands the complete history of a decision made on your platform two years from now, what can you actually produce — and can anyone have edited it?
- We're a regulated institution — our vendors get screened and so do theirs. Do you have any sanctions or financial-crime exposure controls, or is that not your problem?
- You're hosting my European board's data in Japan. Walk me through your Article 44 transfer basis — and don't tell me "the cloud is global.?
Want this answered live, on your data?