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Subprocessors

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This document is a draft for review by counsel. It isn't in effect yet, and the highlighted [PLACEHOLDERS] are filled in before launch.

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Last updated: November 8, 2026.

Ask Lou LLC ("Closefinch", "we") uses these companies to provide the service. Each one processes Customer Personal Data only as the service needs. Each is bound by written terms that protect the data at least as well as our Data Processing Agreement. Each is covered by Standard Contractual Clauses (or the EU-US Data Privacy Framework) wherever data leaves the EU or UK.

We give at least 30 days' notice before adding or replacing a subprocessor: by email to each customer's owners, and on this page. A customer may object for reasonable data-protection reasons, as the DPA sets out.

Last updated: November 8, 2026

SubprocessorWhat it does for usData it processesLocationWhen it's used
Hetzner Online GmbHHosting: servers, database, backupsAll Customer Data (encrypted at rest: the database disk with LUKS2, backups with OpenPGP; connected-account tokens additionally encrypted by us)GermanyAlways
Cloudflare, Inc.Network edge for the API: TLS, DDoS protection, web application firewallTraffic to the API in transit, including the calls the web app forwardsGlobal edge networkAlways
Vercel Inc.Hosting the web app and the marketing siteTraffic to the site and the app in transit (page requests, and the API calls the app forwards); no database accessGlobal edge network; the app's functions run in GermanyAlways
Anthropic, PBCAI models (Claude) for summaries, drafting, field filling, agents and answers; and our own operator support tooling: reading redacted feedback and error reports to diagnose and fix problems [COUNSEL REVIEW: added for the ops inbox, OPS-AUTOFIX]The text the task needs (for example an email thread, a transcript, record fields). For support tooling: the feedback text and error reports, with email addresses, phone numbers, card numbers and secrets masked first; the reporter is never namedUnited StatesWhen an AI feature runs. Not used for model training (commercial terms) and kept only as Anthropic's API terms allow. An organization can bring its own Anthropic key, in which case its own agreement with Anthropic applies. Support tooling: when one of our operators diagnoses a reported problem
Voyage AI, Inc.Text embeddings for semantic searchKnowledge base and document textUnited StatesOnly when semantic search is on (Settings → AI; owners can turn it off, which deletes stored vectors)
Recall.ai, Inc.Meeting recorder botMeeting audio, video and participant names during the meeting; media kept 7 days (30 for meetings with clips)United States (EU region for EU deployments)Only when an organization turns on the recorder and a person has consented to its use
AssemblyAI, Inc.Transcription of uploaded recordings and in-person audioAudio; transcripts deleted at AssemblyAI once we've copied themUnited States (EU endpoint for EU deployments)Only when a recording is uploaded or captured in person
Daytona Platforms, Inc.Sandbox for agent code stepsThe inputs an organization's own published code step receivesUnited States / EUOnly when an organization publishes an agent with a code step
Resend (Plus Five Five, Inc.)Sending service email (sign-in links, invitations, digests, alerts)Recipient address, message contentUnited StatesAlways
Postmark (ActiveCampaign, LLC)Receiving email sent to agent inboxesInbound messages to an agent's addressUnited StatesOnly when an organization uses an agent inbox
ElevenLabs, Inc.Text-to-speech for an AI phone agent's voice and persona previewsThe text the agent speaksUnited StatesOnly when an organization off the trial picks an ElevenLabs voice without bringing its own key
Cartesia, Inc.Text-to-speech (an alternative)The text the agent speaksUnited StatesAs for ElevenLabs, with a Cartesia voice
Paddle.com Market LimitedMerchant of record: checkout, invoicing, sales tax and VATBilling contact, payment details (held by Paddle, never by us), plan and usage totalsUnited Kingdom / EUWhen an organization buys a paid plan

Providers you connect with your own account

These run only when an organization connects its own account, with its own key. They process what the organization sends them on its instructions, under its own agreement with the provider. They're listed so you know where that data goes.

ProviderWhat it doesData it receivesWhen it's used
ElevenLabs, Inc.Text-to-speech and voice cloningThe text to speak; for a clone, the teammate's own consent recordingVoice clones, AI voice notes in a teammate's own voice, and hold and voicemail clips: only with the organization's own ElevenLabs key
Cartesia, Inc.Text-to-speech and voice cloning (an alternative)As for ElevenLabsAs for ElevenLabs, with the organization's own Cartesia key
HeyGen (HeyGen Technology Inc.)AI video of a teammate from their own photoThe teammate's own photo; the audio in their own cloned voice, which HeyGen fetches and keeps (the script may name a prospect's first name and company, and any other words the teammate writes); HeyGen keeps the audio and the rendered video until they're deleted, which happens when consent is withdrawnOnly with the organization's own HeyGen account, after the teammate's written consent
Tavus, Inc.AI video from a replica trained on a teammate's own videoThe training video and the script (which may name a prospect's first name and company, and any other words the teammate writes); Tavus keeps the replica and videos until they're deleted, which happens when consent is withdrawnOnly with the organization's own Tavus account, after the teammate's written consent
ScreenshotOneScreenshots of public web pagesThe page addressOnly with the organization's own ScreenshotOne account
AgentMail, Inc.Agent mailboxes: sending and receiving email for an organization's AI agents at their own addressesAgent mailbox messages (recipient and sender addresses, message content), bounce and complaint reportsOnly with the organization's own AgentMail account (off by default; United States, or the EU region when the organization chooses it). Sign-in, invitation and notification email never goes through it
Telnyx, Inc.Calls and texts, and browser audio for the dialerCall audio, phone numbers, message textOnly with the organization's own Telnyx account

The platform's own ElevenLabs or Cartesia key is used only for an AI phone agent's voice and persona previews, and only when the organization hasn't brought its own. That case is listed in the table above.

Services that act on a customer's own instructions with the customer's own accounts aren't our subprocessors. The customer's agreements with those providers apply, for example Google Workspace, Microsoft 365, Slack, Zoom, HubSpot or Salesforce when the customer connects them.

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