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Introduction

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

SubprocessorService ProvidedPersonal Data ConcernedProcessing LocationTransfer Safeguards
Hetzner Online GmbHHosting of Duale AI application infrastructureAccount, authentication and usage data, content needed for the service, technical logsGermany, European Economic AreaNo transfer outside the European Economic Area for this processing
Cloudflare, Inc.Website hosting, content delivery, network protection and domain name resolutionIP address, user agent, URL, request headers, traffic metadata, security logsCloudflare global networkData Privacy Framework where it applies; 2021 standard contractual clauses with supplementary measures where required
Quad9 FoundationDomain name resolution, with protection against known malicious sitesWeb addresses requested by the serviceSwitzerlandEuropean Commission adequacy decision for Switzerland
  • 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.

SubprocessorService ProvidedPersonal Data ConcernedProcessing LocationTransfer Safeguards
Cloudflare, Inc.Transactional email deliveryEmail address, authentication message contentCloudflare global networkData Privacy Framework where it applies; 2021 standard contractual clauses with supplementary measures where required
  • 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

SubprocessorService ProvidedPersonal Data ConcernedProcessing LocationTransfer Safeguards
Stripe Payments Europe, Ltd.Payment processingBanking data, email addressIreland / United StatesEuropean Union-United States Data Privacy Framework where applicable; 2021 standard contractual clauses and supplementary measures where required
Pennylane SASInvoicing and accountingBilling name, billing address, invoice linesFrance, European Economic AreaNo transfer outside the European Economic Area for this processing
Loqate, a GBG companyBilling address validation and autocompleteAddress entered and the resolved addressUnited KingdomEuropean Commission adequacy decision for the United Kingdom

Service Provided

Stripe Payments Europe, Ltd.Pennylane SASLoqate, a GBG company
Payment processingInvoicing and accountingBilling address validation and autocomplete

Personal Data Concerned

Stripe Payments Europe, Ltd.Pennylane SASLoqate, a GBG company
Banking data, email addressBilling name, billing address, invoice linesAddress entered and the resolved address

Processing Location

Stripe Payments Europe, Ltd.Pennylane SASLoqate, a GBG company
Ireland / United StatesFrance, European Economic AreaUnited Kingdom

Transfer Safeguards

Stripe Payments Europe, Ltd.Pennylane SASLoqate, a GBG company
European Union-United States Data Privacy Framework where applicable; 2021 standard contractual clauses and supplementary measures where requiredNo transfer outside the European Economic Area for this processingEuropean Commission adequacy decision for the United Kingdom

Note: Duale AI does not store credit card numbers.

Communication and Support

SubprocessorService ProvidedPersonal Data ConcernedProcessing LocationTransfer Safeguards
Crisp IM SASCustomer support and optional browser chatEmail, name, profile image, account identifier, messages, chat session identifier, IP address, user agent; with Behavior enabled, shared browser session identifier and browser fingerprintCustomer data stored in the European Union; network relays can process data outside the European Economic AreaChapter V safeguards and standard contractual clauses where applicable under Crisp’s disclosure (opens in a new tab)
  • 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 (opens in a new tab)

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.

RecipientPurposeData SentProcessing Location
Recherche d’entreprises, a French public administration serviceCompany identity lookupCompany name or identifierFrance, European Economic Area
VIES, operated by the European CommissionVAT number validationVAT number and its member stateEuropean Union
  • 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