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Legal / Version 2026-10-21-draft

Data Processing Addendum and Subprocessors

Draft for counsel review (2026-10-21). Before launch, confirm each provider's DPA is signed, its data region, and its retention and no-training terms for API data. Providers marked "planned" aren't in use yet.

Subprocessors

These service providers process personal information for us to run the Service. Each is bound by a contract that limits its use of the data to providing its service.

ProviderWhat it doesData it processesLocationStatus
[Hetzner Online]Hosting, database, backupsAll Service data (encrypted)[EU (Germany) or US]Planned
CloudflareDNS, TLS, network protectionIP addresses, request metadataGlobalPlanned
ClerkSign-in and multi-factor authenticationName, email, sign-in recordsUSIn use
PlaidBank and investment connectionsAccount and transaction dataUSIn use (sandbox)
[OpenAI]AI model for the advocateThe records and messages a task needsUSPlanned (production)
OpenRouter / TypeSafe (Jev)Classification of settlement matches and noticesMerchant names, program descriptions, notice textUSIn use (limited)
Kernel or E2BCloud browsers that visit company websites for youPages the advocate visits, forms it fillsUSPlanned
Postmark or Amazon SESSending email you approveRecipient, message, attachmentsUSPlanned
Expo, Apple (APNs), Google (FCM)Push notificationsDevice token, notification text (kept short, no account details)USPlanned
StripeSubscription and fee billingName, email, payment detailsUSPlanned
[Google Cloud KMS]Encryption key managementEncryption keys only[Region]Planned

We'll notify customers [30] days before adding or replacing a subprocessor.

Data Processing Addendum (outline)

For business customers (for example a credit union or employer offering Ombudly to members), a DPA will cover:

  1. Roles: the customer is the controller of member data it provides; Ombudly is a processor for that data and a controller for data members add themselves.
  2. Instructions: Ombudly processes only to provide the Service and as documented.
  3. Confidentiality of personnel; security measures (Annex: encryption, access control, MFA, logging, backups, incident response).
  4. Subprocessors: the list above, with notice and objection rights.
  5. Assistance with data subject requests, impact assessments and breach notification ([72] hours to the customer).
  6. Deletion or return of data at the end of the contract.
  7. Audits: SOC 2 report when available; otherwise questionnaires.
  8. International transfers: Standard Contractual Clauses (Module 2/3) and UK Addendum.