Introduction

Subprocessors and data transfer safeguards

Duale AI lists the subprocessors that process personal data for its services and the transfer safeguards applied to each.

Lists subprocessors processing personal data for Duale AI services, with notice periods, transfer safeguards, and processing locations for each.

  • Duale AI gives 30 days notice for EEA subprocessors and 90 days for non-EEA additions.
  • International transfers rely on the Data Privacy Framework or 2021 standard contractual clauses.
  • Authentication runs internally on Hetzner infrastructure in Germany with no external identity provider.
  • Customers choose and contract directly with AI model providers; Duale AI does not impose them.
  • Duale AI uses no third-party audience measurement or monitoring service that collects personal data.

Summaries were generated by AI. Generative AI is experimental.

Introduction

This page lists the subprocessors that can process personal data to provide, host, or secure Duale AI services.

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.

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
Twilio Inc. (SendGrid)Transactional email deliveryEmail address, authentication message contentUnited StatesData Privacy Framework where it applies; 2021 standard contractual clauses with supplementary measures where required
  • Subprocessor
    Twilio Inc. (SendGrid)
    Service Provided
    Transactional email delivery
    Personal Data Concerned
    Email address, authentication message content
    Processing Location
    United States
    Transfer Safeguards
    Data Privacy Framework where it applies; 2021 standard contractual clauses with supplementary measures where required

Artificial Intelligence Services

The Customer chooses and contracts directly with its model providers. These providers are not subprocessors imposed by Duale AI.

Duale AI internally processes routing and contextual memory on Hetzner infrastructure in Germany. Duale AI does not reuse that data outside the Customer’s context, either to train a model or to produce statistics.

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
  • Subprocessor
    Stripe Payments Europe, Ltd.
    Service Provided
    Payment processing
    Personal Data Concerned
    Banking data, email address
    Processing Location
    Ireland / United States
    Transfer Safeguards
    European Union-United States Data Privacy Framework where applicable; 2021 standard contractual clauses and supplementary measures where required
  • Subprocessor
    Pennylane SAS
    Service Provided
    Invoicing and accounting
    Personal Data Concerned
    Billing name, billing address, invoice lines
    Processing Location
    France, European Economic Area
    Transfer Safeguards
    No transfer outside the European Economic Area for this processing
  • Subprocessor
    Loqate, a GBG company
    Service Provided
    Billing address validation and autocomplete
    Personal Data Concerned
    Address entered and the resolved address
    Processing Location
    United Kingdom
    Transfer Safeguards
    European Commission adequacy decision for the United Kingdom

Note: Duale AI does not store credit card numbers.

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

Communication and Support

SubprocessorService ProvidedPersonal Data ConcernedProcessing LocationTransfer Safeguards
Crisp IM SASCustomer support, chatEmail, name, ticket contentEuropean Economic AreaNo transfer outside the European Economic Area
  • Subprocessor
    Crisp IM SAS
    Service Provided
    Customer support, chat
    Personal Data Concerned
    Email, name, ticket content
    Processing Location
    European Economic Area
    Transfer Safeguards
    No transfer outside the European Economic Area

Third-party audience measurement and monitoring

Duale AI uses no third-party audience measurement or monitoring service that collects personal data. This does not cover the usage analytics Duale AI produces itself, on its own infrastructure.

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