Legal information

Sub-processor List

Список обработчиков данныхVersion of [effective date]

Draft. Takes effect after review by a lawyer.

This English version is legally binding together with the Russian version. If they differ, the Russian version prevails.

1.What this list is

1.1.Sub-processors are companies that process personal data on our behalf so that Headora can work: they store data, deliver e-mails, run requests to AI models and take payments.

1.2.We work with sub-processors under their data processing terms (including Standard Contractual Clauses where provided). Sub-processors that create video and photo effects store the files they receive under their own policy — see the table.

2.Categories of sub-processors

CategoryPurposeDataLocation
Hosting, databases and file storageService servers; storing accounts, chats, memory and filesAll Service dataEU (Frankfurt, Germany)
Content delivery network and protection (CDN, DNS)Fast site delivery, attack protection, country detectionIP address, technical request dataGlobal network
AI model developersAnswers, images, videos, documentsRequests, context, memory, files, photos, hashed IDUnited States and other countries
Technical partner for access to AI modelsPassing requests to text and image models; requests go only to developers whose terms say they do not store them or train on themRequests, context, memory, files, photos, hashed IDUnited States
Image and video generation partnersVideo, trends and scenes from photosPhotos, task description; stored under their own policyUnited States and other countries
Memory vectorisation (through the technical partner)Search in project memoryText of memory factsUnited States
Web searchAnswers with search, if you turn it onSearch queryUnited States
E-mail deliverySign-in codes, service e-mailsE-mail address, message textUnited States
Google and Apple sign-inVerifying sign-in, if you choose this methodSign-in token, e-mail, nameUnited States
Push notificationsDelivering notifications to your deviceDevice token, notification textUnited States
Payment partnersTaking paymentsOrder number, amount, currency; card details are entered on the partner’s sideKazakhstan, Kyrgyzstan

Company names — [founder decision: publish a named list].

3.Changes to this list

3.1.We update this list when we add or change sub-processors. The date of the update is shown at the top of the page.

3.2.Questions: support@headora.ai.