Subprocessor list and transfer safeguards
Lists Duale AI's subprocessors with their services, processing locations, and transfer safeguards, and separates them from customer-selected recipients.
This page lists Duale AI subprocessors, their processing locations and transfer safeguards, and distinguishes them from customer-selected recipients and public services.
- Subprocessor changes and notification periods.
- International transfer safeguards.
- Infrastructure, hosting, authentication, payment, and communication subprocessors.
- Customer-selected model providers and MCP servers.
- Public administrative services and web research recipients.
Summaries were generated by AI.
Introduction
This page separates subprocessors that act on Duale AI’s instructions from customer-selected or independent recipients and services Duale AI operates internally.
Web research with personal data is not currently qualified. A Duale AI-selected proxy provider can relay Web research requests as a subprocessor. The active deployment value is not qualified in this publication, so this page does not identify its legal entity, processing location, or transfer safeguard. Do not use Web research to process personal data until Duale AI adds the active provider to this list.
Changes
Duale AI notifies you by email before it adds or replaces a subprocessor:
- 30 days ahead, if the subprocessor is in the European Economic Area;
- 90 days ahead, if it is outside the European Economic Area.
You have the right to object in writing within that period: contact+legal@mail.duale.ai
International Transfers
Transfers outside the European Economic Area rely on the Data Privacy Framework where it applies, or on the 2021 standard contractual clauses with supplementary measures where required.
Subprocessors used by Duale AI
Infrastructure, Hosting and Network Security
- Subprocessor
- Hetzner Online GmbH
- Service Provided
- Hosting of Duale AI application infrastructure
- Personal Data Concerned
- Account, authentication and usage data, content needed for the service, technical logs
- Processing Location
- Germany, European Economic Area
- Transfer Safeguards
- No transfer outside the European Economic Area for this processing
- Subprocessor
- Cloudflare, Inc.
- Service Provided
- Website hosting, content delivery, network protection and domain name resolution
- Personal Data Concerned
- IP address, user agent, URL, request headers, traffic metadata, security logs
- Processing Location
- Cloudflare global network
- Transfer Safeguards
- Data Privacy Framework where it applies; 2021 standard contractual clauses with supplementary measures where required
- Subprocessor
- Quad9 Foundation
- Service Provided
- Domain name resolution, with protection against known malicious sites
- Personal Data Concerned
- Web addresses requested by the service
- Processing Location
- Switzerland
- Transfer Safeguards
- European Commission adequacy decision for Switzerland
Authentication
Duale AI operates authentication internally, on Hetzner infrastructure in Germany. It uses no external identity provider.
Duale AI sends authentication email, such as a password reset or a one-time code, through the transactional email provider below.
- Subprocessor
- Cloudflare, Inc.
- Service Provided
- Transactional email delivery
- Personal Data Concerned
- Email address, authentication message content
- Processing Location
- Cloudflare global network
- Transfer Safeguards
- Data Privacy Framework where it applies; 2021 standard contractual clauses with supplementary measures where required
Payment and Billing
Service Provided
| Stripe Payments Europe, Ltd. | Pennylane SAS | Loqate, a GBG company |
|---|---|---|
| Payment processing | Invoicing and accounting | Billing address validation and autocomplete |
Personal Data Concerned
| Stripe Payments Europe, Ltd. | Pennylane SAS | Loqate, a GBG company |
|---|---|---|
| Banking data, email address | Billing name, billing address, invoice lines | Address entered and the resolved address |
Processing Location
| Stripe Payments Europe, Ltd. | Pennylane SAS | Loqate, a GBG company |
|---|---|---|
| Ireland / United States | France, European Economic Area | United Kingdom |
Transfer Safeguards
| Stripe Payments Europe, Ltd. | Pennylane SAS | Loqate, a GBG company |
|---|---|---|
| European Union-United States Data Privacy Framework where applicable; 2021 standard contractual clauses and supplementary measures where required | No transfer outside the European Economic Area for this processing | European Commission adequacy decision for the United Kingdom |
Note: Duale AI does not store credit card numbers.
Communication and Support
- Subprocessor
- Crisp IM SAS
- Service Provided
- Customer support and optional browser chat
- Personal Data Concerned
- Email, name, profile image, account identifier, messages, chat session identifier, IP address, user agent; with Behavior enabled, shared browser session identifier and browser fingerprint
- Processing Location
- Customer data stored in the European Union; network relays can process data outside the European Economic Area
- Transfer Safeguards
- Chapter V safeguards and standard contractual clauses where applicable under Crisp’s disclosure
The Customer support choice controls the browser chat integration. Crisp uses cookies to restore conversations and stores conversation data on its servers. Dashboard can supply a verified email address. See privacy choices.
Other recipients and processing boundaries
Artificial Intelligence Services
Customer-selected model providers. The Customer chooses and contracts directly with its model providers. These providers are not subprocessors imposed by Duale AI.
Duale AI assembles routing inputs and bounded Model Input Context, and stores task history, on Hetzner infrastructure in Germany. A runtime call sends the applicable Model Input Context to the model provider the Customer selected under its own contract. Duale AI does not reuse Customer content outside that Customer’s execution to train a model or produce statistics.
Customer-selected MCP servers
The Customer chooses and authorizes each remote MCP server and contracts for its processing. These servers are not subprocessors imposed by Duale AI. While a Connection is enabled, periodic catalog checks send its configured credential and request or network metadata to the selected server and receive Tool names, titles, descriptions, annotations, and schemas. A Tool Call separately sends the native Tool name, its arguments, request or network metadata, and the same configured credential. The server returns the Tool result. Duale AI sends neither the Agent Identity nor the end-user identity in those requests. The Customer must assess the server’s processing location and transfer safeguards before sending personal data.
Public Administrative Services
To validate a company identity and a VAT number, Duale AI queries two public administrative services. They act as recipients of the data Duale AI sends them, not as subprocessors acting on Duale AI’s instructions.
- Recipient
- Recherche d’entreprises, a French public administration service
- Purpose
- Company identity lookup
- Data Sent
- Company name or identifier
- Processing Location
- France, European Economic Area
- Recipient
- VIES, operated by the European Commission
- Purpose
- VAT number validation
- Data Sent
- VAT number and its member state
- Processing Location
- European Union
Web research recipients and proxy processing
Public search engines and destination websites receive the query, URL, request metadata, and any origin-specific session state needed for the Customer-requested retrieval. They are recipients rather than subprocessors imposed by Duale AI. The warning at the start of this page states the current proxy-provider qualification boundary.
Contact
- Questions: contact+privacy@mail.duale.ai
- Data processing agreement request: contact+dpa@mail.duale.ai