Subprocessors

Last updated: May 31, 2026

Document owner: Vendor Risk Management Lead and Data Protection Officer delegate Review cadence: Monthly verification; quarterly formal review; ad hoc on vendor onboarding/offboarding Effective date: 2026-05-31 Processor legal entity: EthicPages, Inc. Registered address: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ Primary contact: ethicpages+contact@invictosoft.com

1. Purpose of this page

This page identifies third-party subprocessors authorized by EthicPages, Inc. ("EthicPages," "we," "us") to process personal data on behalf of customers in connection with our services. It is designed for procurement, legal, and security review workflows and should be read with our Data Processing Agreement, Privacy Policy, and Terms of Service.

A subprocessor is a third party engaged by EthicPages to process customer personal data for service delivery, support, security, billing, communication, or related operational needs.

2. Subprocessor governance model

EthicPages applies a risk-based vendor governance process before onboarding any subprocessor and throughout the vendor lifecycle.

2.1 Governance controls

Control domain	EthicPages approach
Due diligence	Security, privacy, legal, and operational review before onboarding
Contracting	Written agreements with confidentiality and data protection obligations
Access management	Least-privilege scoping of vendor access and credentials
Regional review	Assessment of data residency and cross-border transfer impacts
Ongoing monitoring	Periodic reassessment and event-driven review on material changes
Offboarding	Access revocation and data handling closure procedures

3. Current subprocessors

The following providers are currently authorized subprocessors for customer data processing in connection with EthicPages operations.

3.1 Core subprocessor inventory

Subprocessor	Purpose	Processing location(s)	Data processed	Service category
Neon	Managed PostgreSQL infrastructure for persistent application data storage	Primarily United States (region by deployment)	Account metadata, workspace content, policy drafts, operational metadata	Database infrastructure
Stripe	Payment processing, invoicing, subscription lifecycle handling, fraud controls	United States and other regions operated by Stripe	Billing identifiers, customer email, invoice/payment metadata, limited transaction details	Billing and payments
OpenRouter	AI model routing and inference for customer-initiated document generation workflows	United States and other provider-supported regions	Prompt content, generated text, model metadata, request/response telemetry	AI processing
Resend	Transactional email delivery (verification, billing notices, account/security communications)	United States and other regions operated by provider	Recipient email, template variables, delivery metadata	Communications
Vercel	Application hosting, content delivery, deployment runtime, and edge/network delivery	United States and global edge network locations	Request logs, application responses, operational telemetry, hosted content artifacts	Hosting and delivery

3.2 Processing purpose detail

Subprocessor	Detailed purpose	Why required for service
Neon	Secure relational storage and retrieval of tenant/workspace records	Core data persistence for account and document workflows
Stripe	Charging subscriptions and managing invoicing/refund rails	Required to process paid plans: $17/month, $132/year, $750 one-time, $1,200 lifetime
OpenRouter	Routing model requests for AI-assisted legal content generation	Enables optional AI drafting features requested by customer users
Resend	Delivering service-critical transactional emails	Required for account verification, reset, billing, and incident notices
Vercel	Running production app, APIs, and static/edge delivery	Required for secure, performant customer access to the platform

3.3 Data category detail by subprocessor

Subprocessor	Identity/contact data	Account/workspace data	Billing data	Content/prompt data	Logs/telemetry
Neon	Yes	Yes	Limited metadata only	Yes	Limited
Stripe	Yes	Limited	Yes	No	Yes
OpenRouter	Limited (as present in prompts)	Limited	No	Yes	Yes
Resend	Yes	Limited template context	No	Limited message content	Yes
Vercel	Limited request metadata	Limited runtime data	No	Hosted content	Yes

4. Geographic processing and transfer safeguards

EthicPages and its subprocessors may process data in the United States and other jurisdictions relevant to service architecture. Where required, we implement lawful transfer mechanisms, including Standard Contractual Clauses and supplementary safeguards.

4.1 Transfer safeguards matrix

Safeguard	Application
SCCs/UK addendum	Applied for restricted transfers when adequacy is unavailable
Contractual privacy clauses	Included in vendor agreements
Security controls	Encryption in transit and role-based access controls
Data minimization	Processing scoped to service-delivery purposes
Vendor reassessment	Triggered by regulatory or architecture change

For details, see Data Processing Agreement.

5. Change notification process

EthicPages maintains a formal process for adding, replacing, or materially changing subprocessors.

5.1 Notification lifecycle

Stage	Commitment
Planned change identified	Internal legal/privacy/security review is initiated
Customer notification	Active customers receive advance notice of material subprocessor change
Objection period	Customers may raise reasonable data protection objections within 15 days
Resolution handling	Parties work in good faith to address concern through safeguards or alternatives
Finalization	If unresolved and legally required, customer may terminate impacted service scope

5.2 What qualifies as a material change

Material changes may include:

onboarding a new subprocessor with access to customer personal data;
replacing a listed subprocessor for an existing processing function;
significant change to processing purpose, data category scope, or transfer geography.

Routine internal vendor maintenance that does not materially alter data processing risk may be documented without a formal objection workflow.

6. Customer objection process

Customers may object to a new subprocessor on reasonable data protection grounds by submitting written notice to ethicpages+contact@invictosoft.com within the stated objection window.

6.1 Objection submission checklist

Required item	Description
Customer identity	Legal entity name and workspace/account identifier
Affected change	Subprocessor name and change notice reference
Ground for objection	Specific legal/privacy/security concerns
Requested remedy	Proposed mitigation or alternative approach

EthicPages will evaluate objections in good faith and communicate available mitigations. Where no reasonable resolution is possible, customer remedies follow the Data Processing Agreement.

7. Security and compliance expectations for subprocessors

Each subprocessor is expected to maintain controls appropriate to its role and data access scope, including confidentiality obligations, access restrictions, and incident response capabilities.

7.1 Minimum operational expectations

Expectation	Description
Confidentiality commitments	Contractual confidentiality covering personnel and subcontractors
Security baseline	Controls proportionate to processing risk and service criticality
Breach communication	Prompt notification to EthicPages for incidents affecting customer data
Data handling boundaries	Processing only for authorized service purposes
Access limitation	Restricted and auditable access paths

8. Relationship to customer obligations

This page is intended to support customer legal and procurement review. Customers remain responsible for:

assessing whether the listed subprocessors meet their own internal policy requirements;
determining whether additional contractual controls are needed;
configuring product use to minimize unnecessary personal data exposure;
avoiding submission of sensitive data not required for service use.

9. Historical records and versioning

EthicPages maintains records of subprocessor list revisions for auditability and legal reference. The effective date and last-updated value identify the currently active version.

9.1 Record retention overview

Record type	Retention approach
Active subprocessor list	Continuously maintained
Change notices	Retained according to legal and compliance needs
Objection correspondence	Retained with contract and compliance records

10. Frequently reviewed procurement questions

10.1 Does EthicPages sell customer personal data?

No. EthicPages does not sell customer personal data.

10.2 Are subprocessors allowed to use customer data for their own unrelated purposes?

Subprocessors are engaged to provide services to EthicPages and are contractually restricted to authorized processing purposes.

10.3 Can customers receive notice before new subprocessors are added?

Yes. Material changes are notified with an objection process as described above.

10.4 Where can transfer safeguards be reviewed?

See Data Processing Agreement for transfer mechanisms and legal safeguards.

11. Contact for vendor and subprocessor inquiries

For due diligence requests, legal review packets, or subprocessor objections, contact:

Email: ethicpages+contact@invictosoft.com
Postal: EthicPages, Inc., 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ

11.1 Inquiry routing table

Inquiry type	Subject line recommendation
Subprocessor objection	"Subprocessor Objection"
Vendor diligence request	"Vendor Review Request"
Transfer mechanism request	"SCC / Transfer Mechanism Request"
Incident-related vendor concern	"Vendor Security Inquiry"