GDPR Art. 28(2)

Sub-processors

The third parties Random Assistant engages to process Customer Data on the subscriber's behalf. We notify subscribers at least 30 days before adding or replacing an entry. The AI model providers reached through OpenRouter, with entity, location and transfer basis, are in DPA Annex III. Copies of the transfer safeguards: privacy@random-assistant.com.

Last updated: 27 October 2026

Current sub-processors

Our sub-processors

Nylas

Email and calendar connection for Google and Microsoft accounts

Where
EU (Ireland); backups may be stored in the United States, Canada, Australia and Brazil
Transfer basis
None needed for the EU region (Ireland). Backups and support access outside the EU: EU SCCs (Module 3) in the signed Nylas DPA; Nylas is also certified under the EU-US Data Privacy Framework; Canada has an adequacy decision

Hetzner Cloud

Hosting, database and backups

Where
EU (Germany, Finland)
Transfer basis
None needed (EU)

Cloudflare

CDN, firewall and TLS for our websites; requests are decrypted at the Cloudflare edge in transit, not stored

Where
Global edge network, inside or outside the EU (no Data Localization Suite)
Transfer basis
EU-US Data Privacy Framework (Cloudflare, Inc. certified); EU SCCs in the Cloudflare DPA

Stripe

Billing and card payments; payouts to partners (Stripe Connect)

Where
EU (Ireland): Stripe Payments Europe, Limited; Stripe, LLC also processes data in the United States
Transfer basis
EU-US Data Privacy Framework; EU SCCs in the Stripe DPA

AhaSend

Transactional email: account, signature and workflow notices

Where
EU (Netherlands; servers in the EEA)
Transfer basis
None needed (EEA); we send through the EU host send.ahasend.com

OpenRouter

AI model routing for chat, background tasks and dictation; keeps request metadata, not content. The model providers behind it are listed in DPA Annex III.

Where
EU data regions only: EU endpoint (eu.openrouter.ai) and our account guardrail allow EU data regions only; if no EU route is available, the request fails. OpenRouter, Inc. is a US company; account, billing and sign-in data and security logs may be processed in the United States under the EU SCCs
Transfer basis
EU SCCs in the OpenRouter DPA (Terms of Service §10.2)

Mistral AI

Live text while you dictate, where switched on (api.eu.mistral.ai). Mistral AI keeps that audio and text for up to 30 days for abuse monitoring and never uses them for training.

Where
EU (France); some of Mistral's own sub-processors may process data outside the EEA
Transfer basis
EU SCCs for Mistral's own sub-processors outside the EEA; none needed for the EU endpoint

Sentry

Error monitoring; reports carry no request bodies, cookies or user details, and email addresses, tokens and long numbers in error text are masked before a report is sent

Where
EU (Germany)
Transfer basis
EU SCCs in the Sentry DPA for access by Sentry, Inc. (US)

PostHog

Product analytics, cookieless

Where
EU (Germany)
Transfer basis
None needed for the EU cloud; EU-US Data Privacy Framework and EU SCCs in the signed PostHog DPA for access by PostHog Inc. (US)

Staan

Web search, where web research is on; only the query and a market code are sent

Where
EU (France). Only where Web research is on (off until you turn it on); when Staan's EU index lacks results, Staan may pass the query to its own search providers in the United States.
Transfer basis
None needed (EU). For the US fallback: your opt-in when you turn Web research on, after the notice shown on the switch (Art. 49(1)(a) GDPR).

Connected by you

Google (Workspace APIs)

Gmail and Calendar through Nylas; Tasks; Google Drive files you pick or Random saved (drive.file only)

Where
EU/US
Transfer basis
Under your own Google Workspace contract

Microsoft (Outlook / Calendar)

Outlook mail and calendar, through Nylas

Where
EU/US (Microsoft 365, per your tenant region)
Transfer basis
Under your own Microsoft 365 contract

HubSpot

CRM: read contacts and deals; write notes and tasks on your instruction

Where
EU/US (per your HubSpot account data region)
Transfer basis
Under your own HubSpot contract

Pipedrive

CRM: read contacts, deals and activities; write notes and tasks on your instruction

Where
EU/US (per your Pipedrive account region)
Transfer basis
Under your own Pipedrive contract

Attio

CRM: read contacts, companies and deals; write records and notes on your instruction

Where
EU/US (per your Attio account)
Transfer basis
Under your own Attio contract

RecruitCRM

Recruiting CRM: read candidate, job and pipeline data on your instruction

Where
US / global (per your RecruitCRM account)
Transfer basis
Under your own RecruitCRM contract

Amplemarket

Sales engagement: read prospect records and email sequences on your instruction

Where
US / EU (per your Amplemarket account)
Transfer basis
Under your own Amplemarket contract

Notion

Read pages and documents from your Notion workspace on your instruction

Where
US (Notion Labs, Inc.)
Transfer basis
Under your own Notion contract

Slack

Messages to or mentioning the Random bot, and commitments in the channels you switch on; Random posts approval cards (including a follow-up draft's text and recipient) into your direct messages with the bot, answers your /random commands privately (meetings, follow-ups, contacts) and adds status reactions; and sends the reminders and workflow notifications you set up as direct messages from the bot

Where
US (Salesforce / Slack; EU data residency available)
Transfer basis
Under your own Slack contract

Motion

Read tasks and calendar events from your Motion account on your instruction

Where
US
Transfer basis
Under your own Motion contract

Gamma

Create and read presentations in your Gamma account on your instruction

Where
US
Transfer basis
Under your own Gamma contract

Shopify

Read your store's products, orders, revenue and customer aggregates, and create or update discounts and products only after you approve each change. Connected with a custom app you create and install in your own Shopify store. Customer names, emails, phone numbers and street addresses are dropped on read and never stored.

Where
Global (Shopify infrastructure; no EU-only data residency offered)
Transfer basis
Under your own Shopify contract

Kickscale

Kickscale sends each analysed meeting to a webhook address unique to your workspace; Random keeps the transcript, encrypted, so you can read it in Meetings. We do not call Kickscale.

Where
EU (Austria)
Transfer basis
Under your own Kickscale contract

Programmatic access

The same list is available as JSON at /legal/processors.json.