Sub-processors
Version 2026-10-21
Article 1. Purpose and scope
1.1. Purpose. This page identifies the sub-processors, within the meaning of Article 28(2) and (4) GDPR, that iAdvize engages to process personal data on behalf of its customers as part of the AI Shopping Assistant v3 pilot (the "Service"): dashboard, playground, REST API, MCP server and the assistant served to shoppers. It is the list referred to in Article 7.4 of the terms of use and in Article 7 of the DPA.
1.2. Content. Each entry states the service provided, the data processed and where the processing takes place. Processing located outside the European Union is listed in Article 6, and the applicable safeguards in Article 7.
1.3. Processing for which iAdvize is responsible. Some of these providers also process data for which iAdvize is the controller (audience measurement of its website, product emails). That processing is described in the privacy policy.
Article 2. Changes to the list
2.1. Notice. iAdvize informs the customer, by email to the administrators of its organization, of any new sub-processor at least thirty (30) days before the processing starts, unless a shorter period is required for security reasons or by law.
2.2. Objection. During that period, the customer may object to the new sub-processor, on reasonable data protection grounds, by email to privacy@iadvize.com. The parties then seek a solution in good faith; failing that, the customer may end the terms of use under their Article 10.3.
2.3. Updates. This page is the authoritative list in force. Any change updates its version date.
Article 3. Infrastructure and hosting
| Provider | Service | Data processed | Location |
|---|---|---|---|
| Vercel Inc. | Hosting and running the application (shopper chat surface, dashboard, APIs); storage of uploaded images (organization and site logos, favicons, assistant avatars, profile photo uploaded by a member of the customer's teams); routing of model calls through the AI Gateway; audience measurement of iAdvize's website and dashboard, and performance measurement of the pages served by the application, including the shopper chat surfaces, excluding the shopper notice | Data handled during a request, including conversation content in transit; the images above. For measurement: page address without parameters (route only, without site key, on a shopper surface), referring site, approximate location, device and browser type, performance timings. No cookie; no identifier kept beyond 24 hours | Frankfurt (Germany) for compute and storage; other components: Article 6 |
| Neon, LLC | The Service's database | Organizations, sites and the content of their pages, agents and versions, starter questions, conversations, ratings and labels, measurement events and page-view counts, orders sent by the store, evaluation scenarios and results, audit log, encrypted credentials of e-commerce connectors | Frankfurt (Germany) |
Article 4. AI model providers
4.1. Call chain. Model calls are routed through Vercel's AI Gateway, with Vercel's credentials, in zero-data-retention mode and pinned to the European Union; a call that cannot be served there fails rather than falling back to another region. Vercel is iAdvize's counterparty for inference; the providers below act as Vercel's sub-processors (Article 28(4) GDPR). Anthropic's Claude models are served by Amazon Bedrock or Google Cloud Vertex AI, depending on availability; Anthropic, which offers no European endpoint for these models, receives no calls.
| Provider | Service | Data processed | Location |
|---|---|---|---|
| OpenAI OpCo, LLC | Labeling of shopper and Playground conversations, excluding conversations whose shopper has objected to measurement; generation of starter questions, on request or when automatic generation is enabled (off by default) | Labeling: messages, tool results and the configuration of the agent (instructions, tools, site information, tone of voice). Starter questions: page content, site name, tone of voice and description | European Union (pinned) |
| Amazon Web Services, Inc. (Amazon Bedrock) | Claude models: the assistant's answers; internal text-generation processing (site analysis at onboarding, instruction generator, evaluation judge, product newsletter, check of suggested replies against the catalog, page classification) | Conversation: messages, previous answers, instructions and tool results. Other processing: site name and address, instructions, evaluation scenarios, iAdvize changelog; for classification, the page's address, titles, description and at most its first 1,500 characters | European Union (pinned) |
| Google LLC (Google Cloud Vertex AI) | Same processing as Amazon Bedrock, for the calls routed to it | Same data | European Union (pinned) |
4.2. Retention and training. Zero data retention and the prohibition on use for training are enabled on the AI Gateway and reasserted on every call. Any model provider may nevertheless retain, under its own rules and possibly outside the European Union, requests flagged by its abuse-detection systems.
Article 5. Support services
| Provider | Service | Data processed | Location |
|---|---|---|---|
| WorkOS Inc. | Identity and access management for the dashboard: sign-in, multi-factor authentication, sessions, roles, invitations, REST API keys, MCP client authorization | Email address, name, profile photo, language and time zone of members of the customer's teams, organization and role, IP address and browser of active sessions, API keys; where applicable, a copy of the configuration change log. No shopper data | United States |
| Parallel | Vercel sub-processor, called through the AI Gateway: web search for information about the customer's brand during the site analysis at onboarding or when site information is regenerated. Systematic processing, not optional | Site name and address, derived queries. Never conversation content | United States |
| Upstash Inc. | Running scheduled and background jobs: site analysis, agent evaluations, retention purge, conversation labeling, page reading, starter questions, store performance measurement, newsletters | Job payloads and intermediate results: identifiers, site name and address and generated information, an agent's configuration during an evaluation, newsletter drafts. Never conversation content or labels: the labeling job sends only identifiers and keeps only result codes | Frankfurt (Germany) |
| Resend Inc. | Sending emails to the customer's teams: sign-in, notifications, product newsletters | Recipients, subscription status, record of consent, message metadata and logs | Ireland, United States |
| Linkup | Web search and page fetching during a conversation, only for agents on which the customer has enabled it (off by default). Systematic, non-optional reading of the customer's site pages that refuse iAdvize's reader | Query derived from the conversation or target address; for a page of the customer's site, its public address only. Never a conversation | European Union (default region) |
Google LLC also receives, through the PageSpeed Insights and CrUX APIs, the public address of store pages in order to measure the effect of the iAdvize tag on their performance. No personal data is sent to it.
Article 6. Processing located outside the European Union
Data the Service stores durably is stored in Frankfurt. That location refers to where the application compute and storage run; it does not exclude the following flows, carried out or held outside the European Union:
- Model inference. The request goes through Vercel's gateway, which may process it in a region outside the European Union. Requests flagged by a model provider's abuse-detection systems may be retained outside the European Union.
- Site analysis at onboarding. Parallel processes the site's name and address and the derived queries in the United States.
- Identity of the customer's teams. WorkOS holds it in the United States, including the profile photo, together with the organization's name, its roles, its API keys and, where applicable, the copy of the configuration change log.
- Emails. Resend holds the recipient list, subscription status, record of consent and message metadata and logs in the United States.
- Session and authentication. Vercel's routing layer runs, on every request, in every region of its network.
- Control plane, backups and request logging. Vercel operates them globally, with no applicable regional setting.
- Uploaded images. Stored in Frankfurt, including the profile photo of a member of the customer's teams, they are served by a global content delivery network and cached at its points of presence.
- Audience and performance measurement. As Vercel publishes no storage region for this measurement, it may be processed in the United States. It produces only aggregated statistics, with no cookie and no identifier kept beyond 24 hours. On shopper chat surfaces, only performance timings are sent; the shopper notice sends nothing; no data is sent once a shopper has objected, and an objection signaled by the customer's consent management tool takes effect on the next page load.
- Linkup. For web search during conversations and for reading pages that refuse iAdvize's reader, Linkup may use its own providers outside the European Economic Area.
Article 7. Transfer safeguards
7.1. The transfers referred to in Article 6 are covered by the following safeguards, within the meaning of Articles 45 and 46 GDPR, as provided on the version date of this page by the providers' data processing agreements or notices.
| Provider | Safeguard |
|---|---|
| Vercel Inc. | Data Privacy Framework; standard contractual clauses and UK addendum in its data processing agreement |
| Amazon Web Services, Google Cloud, OpenAI OpCo, LLC, Parallel | Vercel sub-processors: transfers covered by Vercel's data processing agreement and by the safeguards Vercel must put in place with them (Article 28(4) GDPR) |
| Neon, LLC | Data Privacy Framework (Databricks certification); standard contractual clauses and UK addendum in the Databricks data processing agreement. Data stored in Frankfurt |
| WorkOS Inc. | Standard contractual clauses (controller to processor, and processor to processor) and UK addendum in its data processing agreement |
| Resend Inc. | Data Privacy Framework; standard contractual clauses and UK addendum in its data processing agreement |
| Upstash Inc. | Data Privacy Framework, with standard contractual clauses as a fallback |
| Linkup | Data processing agreement signed with iAdvize in October 2026; for its own providers outside the European Economic Area, standard contractual clauses (processor to processor) and UK addendum |
7.2. Where a transfer is no longer covered by the Data Privacy Framework, the standard contractual clauses in the same agreements apply.
Article 8. Systems outside this list
Third-party services the customer chooses and connects to the Service are not iAdvize sub-processors, in particular its e-commerce platform, including the public endpoints of its Shopify store connected by iAdvize on its instruction at onboarding, and its consent management tool. Those services process the customer's data under the agreements the customer has made with them.