Subprocessors
Last updated: July 2026
Update cadence & your objection right
We review this list quarterly. Before we engage a new Subprocessor, we specifically inform affected customers in writing — by email to the account's designated contacts, or by in-product notice — with notice deemed given when sent, and we post the change here in addition to (not instead of) that written notice. Customers have 30 days from the date notice is given to object on reasonable data-protection grounds; a timely objection suspends our use of the new Subprocessor for that customer pending resolution, per DPA §5.3.
Current Subprocessors
| Subprocessor | Purpose | Data accessed | Region | Notes |
|---|---|---|---|---|
| Cloudflare, Inc. | Edge, DNS, DDoS, WAF, Access gating, tunnel; marketing site on Cloudflare Pages | Network metadata; request bodies in transit, not at rest | US (global edge) | — |
| Fly.io, Inc. | Production application hosting + database (Fly Volume holds the SQLite file) | Tenant data in transit and at rest | US (`iad` / Ashburn, VA) | Launch gate: self-hosted pre-launch today; production hosting migrates to Fly.io before public launch. |
| Cloudflare R2 (via Litestream) | Continuous SQLite backup → point-in-time restore | Encrypted copies of the tenant database file | US (R2) | Launch gate: continuous backup replication begins with the Fly.io cutover, before public launch. |
| Anthropic, PBC (zero-retention) | LLM inference for drafting Written Information Security Programs (WISPs) | WISP-builder inputs (Customer's program description) | US | GLBA-sensitive — customer security-program content. A zero-data-retention arrangement will be verified in writing before first production processing. |
| Stripe, Inc. | Subscription billing | Billing contact + tokenized payment method | US | — |
| Resend Inc. | Transactional email | Recipient address + message content | US | — |
| Google LLC (Workspace) | Our internal business email | Our internal email only; not customer-product data | US | — |
Data Residency
Data at rest is stored in the United States. Fly.io production hosting and Cloudflare R2 backup replication are launch gates — required to be in place, U.S.-region-pinned, before public launch and before the first production customer.
Customers Outside the United States
We do not currently market to or onboard customers in jurisdictions that prohibit U.S. data processing under their data-protection law. Customers in the EU/EEA, UK, or Switzerland may onboard subject to the Standard Contractual Clauses ("SCCs") incorporated by reference into our DPA (together with the UK Addendum, for UK transfers).
Audit Rights
You may request a summary of our subprocessor-management practices by emailing [email protected]. SOC 2 Type I is planned; an auditor has not yet been engaged; our report will be available under NDA once complete. We do not permit direct audit of our Subprocessors; we share their relevant audit reports under NDA.
Contact Us
Ellis Intelligence LLC
Attn: Privacy & Security — SafeguardsMark
Email: [email protected]
This list is referenced by, and generated in accordance with, our Data Processing Addendum.