Sub-Processor List

1. About This Document

TL;DRThe live, authoritative list of every third party that touches your data. Updated whenever a processor is added, removed, or changed. 30-day advance notice for any material change.

In accordance with Article 28 of the EU General Data Protection Regulation (GDPR), this page lists every third-party sub-processor that Clario.ai engages to process personal data on behalf of our users. Each sub-processor is bound by a Data Processing Agreement (DPA) that imposes GDPR-compliant data-handling obligations.

This is the single source of truth: our Privacy Policy §4 and §12 both link here rather than duplicating the list, so it never drifts.

2. Current Sub-Processors

TL;DR10 processors across AI, Infrastructure, Analytics, Communications, and Payments. 6 in the EU; 4 in the US with SCCs.

3. International Data Transfers

TL;DRThe 4 US processors (OpenAI, Cohere, Stripe, Postmark) run under European Commission Standard Contractual Clauses + a Transfer Impact Assessment.

Where sub-processors are located outside the European Economic Area (EEA), data transfers are protected by Standard Contractual Clauses (SCCs) approved by the European Commission, in compliance with Chapter V of the GDPR. A Transfer Impact Assessment (TIA) summary is available on request from privacy@myclario.app.

4. Data Minimisation

TL;DREvery processor sees only the minimum it needs. Cohere gets snippets, not full documents. PostHog gets anonymised events. Stripe sees no card data on our servers.

We apply the principle of data minimisation under Art. 5(1)(c) GDPR. Each sub-processor receives only the minimum data necessary to perform its specific function:

• Cohere receives only short text snippets for re-ranking, never full documents.
• PostHog receives only anonymised usage events with personally identifiable fields stripped before transmission.
• Stripe handles payment instruments directly; we never store card numbers, CVV, or full bank credentials on our servers.
• Postmark receives only the recipient address + message body needed to deliver a specific transactional email; no bulk lists.
• Qdrant stores vector embeddings + a tenant identifier — not the original document text.

5. Your Right to Object

TL;DRDon't like a new processor? 30-day window to object. If we can't resolve, you can terminate + take a full export with you.

Material changes (new sub-processor, change of location, change of purpose) are announced to registered users by email at least 30 days before they take effect. If you object to a change, write to privacy@myclario.app within that 30-day window and we will work with you to find a resolution. If no resolution is possible, you may terminate your account and request deletion of all your data + a full export in accordance with our Privacy Policy §8 (GDPR rights).

6. Contact

TL;DRQuestions go to privacy@myclario.app. Postal address on the Imprint.

7. Change Log

TL;DREvery addition, removal, or change is recorded here. Material changes get 30-day email notice before taking effect.

• May 17, 2026 — v2.0. Added Postmark as a transactional-email sub-processor (closes the drift gap with Privacy §4.2). Added a Category column (AI / Infrastructure / Analytics / Communications / Payments). Effective + last-updated dates refreshed. Anchor-linked table of contents, TL;DR cards, reading-time estimate added — visual parity with Privacy v2.0 + Terms v2.0. Replaced placeholder postal address with link to /imprint as single source of truth. §7 Change Log section added.
• April 6, 2026 — v1.0. Initial GDPR Art. 28 sub-processor list.