Sub-processors

Annex 3 to the data processing agreement. Version 3.2, 30 October 2026. We announce changes 30 days in advance (DPA section 5.2).

"Customer data" says whether the provider may process personal data that we process on behalf of a customer. Providers marked "no" serve only our own business (see the privacy policy). Where a customer's non-disclosure agreement restricts which tools we may use, we use only the tools approved there.

Safeguard for transfers outside the EEA: "DPF" is the EU-U.S. Data Privacy Framework (Art. 45 GDPR) for certified providers; "SCC" are the European Commission's Standard Contractual Clauses (Art. 46(2)(c) GDPR) in the provider's data processing terms.

Infrastructure

ProviderPurposeLocationSafeguardCustomer data
netcup GmbH, Karlsruhe, GermanyServer hosting: website, API, meeting transcription and speaker separation, encrypted backupsGermanyEUYes
Supabase, Inc., USADatabase of the 24/6 workspace and our customer recordsEU (AWS eu-north-1, Stockholm); support access from the USADPF or SCCYes
Scaleway SAS, Paris, FranceRented GPU server for open-source AI models, created on demand and deleted after useFranceEUYes
GitHub, Inc., USASource code repository and version historyUSADPF or SCCNo

AI models

ProviderPurposeLocationSafeguardCustomer data
Anthropic Ireland, Limited, with Anthropic, PBC, USAClaude models: summaries, analysis, drafting. Use for model training switched offUSASCCOnly where the customer has approved it
Google Ireland LimitedGemini within Google WorkspaceEU and USADPF or SCCOnly where the customer has approved it

Communication

ProviderPurposeLocationSafeguardCustomer data
Google Ireland LimitedGoogle Workspace: email, calendar, Meet video calls, documentsEU and USADPF or SCCYes
Resend, Inc., USATransactional email, including meeting notifications to our own mailbox (time, length, participant names; never the transcript)USADPF or SCCYes
Mailgun Technologies, Inc. (Sinch), USAReceiving and routing email sent to m246.org addressesUSADPF or SCCYes
Microsoft Ireland Operations LimitedAzure: email automationEU and USADPF or SCCNo
Slack Technologies, LLC, USAMessaging with customers who use SlackUSADPF or SCCYes, in shared channels
WhatsApp Ireland LimitedMessagingEU and USADPF or SCCNo
Cal.com, Inc., USABooking of callsUSASCCNo

Business tools

ProviderPurposeLocationSafeguardCustomer data
Notion Labs, Inc., USAInternal notes and documentationUSADPF or SCCNo
Granola, Inc., USAMeeting notes in calls we hold ourselves, with participants' consentUSASCCNo
Stripe Payments Europe, Limited, IrelandPayments and billingEU and USADPF or SCCNo
Trustpilot A/S, Copenhagen, DenmarkReview invitations to customersEUEUNo

Processed on our own devices, no provider involved

Meeting transcription with open-source speech recognition on our server and on our encrypted work laptop; open-source AI models run locally (LM Studio); code editing (VS Code).