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Sub-processors · Art. 28 GDPR · Updated 15 October 2026

Who processes data on our behalf

Six third parties touch VINCHY data today. Each one is listed here with what it does, which data it sees, where that happens and on what legal basis it may leave the EU. This page is the authoritative list referenced by our data processing agreement (AVV/DPA); when it changes, the date above changes with it.

Maintained by DreamSoft AI Studio (SIGOO GmbH) · verified 15 October 2026 · the dated version of this page is the one referenced in your AVV
/// The list

Sub-processors as of 15 October 2026

Order follows the data flow: storage, API, AI, email, SMS, analytics. “Transfer basis” names what allows data to leave the EU where it does; “none required” means it does not leave.

ProviderPurposeData categoriesLocationTransfer basis
Supabase, Inc.
San Francisco, USA · EU hosting
Database and storage (PostgreSQL) for all application recordsAudit chain, approvals, agent registry, conversations, account dataFrankfurt am Main, Germany — AWS eu-central-1Hosting: none required (EU). Support access: EU Standard Contractual Clauses (Art. 46(2)(c) GDPR; Supabase DPA)
Vercel, Inc.
San Francisco, USA · EU functions
Hosting: serverless API functions, static pages, TLSRequest data in transit; no records storedFunctions: Frankfurt (fra1). Static pages and TLS: nearest edgeFunctions: none required (fra1). Edge delivery and support: EU-US Data Privacy Framework, alternatively Standard Contractual Clauses (Vercel DPA)
Mistral AI SAS
Paris, France
AI inference: policy screening, assistant, voice (Voxtral STT/TTS), document reading (OCR)Prompt text, audio clips, document images sent for one requestEU / EFTA data centres via regional endpoint api.eu.mistral.ai (Azure SE/NO, Google Cloud NL/BE, Mistral Compute FR, CoreWeave EEA)None required; Mistral Data Processing Addendum; Zero Data Retention enabled for our organisation on all five endpoints (confirmed in writing 15 Oct 2026); API data excluded from training
Plus Five Five, Inc. (Resend)
San Francisco, USA
Email delivery: approval notifications, invitations, confirmation links — and emails that agents send to third parties after approvalRecipient address, subject, email bodySending via Ireland (region eu-west-1; sending domain vinchy.ai verified there). Message content, logs and account data are stored in the United StatesEU-US Data Privacy Framework, alternatively Standard Contractual Clauses (Resend DPA)
Twilio, Inc.
San Francisco, USA
SMS — reminders and messages that agents send to third parties after approval, only after the recipient’s double opt-inPhone number, message textUnited StatesEU-US Data Privacy Framework, alternatively Standard Contractual Clauses (Twilio DPA)
Google Ireland Ltd.
Dublin, Ireland (Google LLC, USA)
Website analytics (GA4) on public marketing pages only, loaded only after cookie consent; the application carries no analyticsPseudonymous usage data, truncated IPEU / United StatesConsent (Art. 6(1)(a) GDPR); Google Ads Data Processing Terms incl. SCCs / DPF

EU-US Data Privacy Framework status checked on 18 Oct 2026 (dataprivacyframework.gov): Vercel, Inc., Twilio Inc. and Plus Five Five, Inc. (Resend) active. Supabase is not certified; its support access rests on the Standard Contractual Clauses. If a certification lapses, that transfer rests on the EU Standard Contractual Clauses (Art. 46(2)(c) GDPR).

Retired: OpenAI (voice preview) — removed 14 October 2026; no VINCHY data has been sent to OpenAI since.

A sub-processor list is a promise.
A dated one is a record.

How changes work

Before a new sub-processor receives any customer data, this page is updated and the date at the top changes. Customers with a signed AVV are notified by email to their account address and may object within 30 days under the AVV. We do not add sub-processors silently.

What you can request

Our data processing agreement (AVV, Art. 28 GDPR) with this list as its annex, the provider DPAs we rely on, and a dated PDF export of this page. Write to hallo@sigoo.de; the team that runs VINCHY answers, not a call centre.

/// FAQ

Sub-processors — frequently asked questions

Who is the operator of VINCHY?

VINCHY is built and operated by DreamSoft AI Studio, the AI studio of SIGOO GmbH — a German software and design house building systems for companies and public institutions since 2012. SIGOO GmbH is the legal entity and contracting party (see the Legal Notice). Data processing questions go to hallo@sigoo.de.

Why are US companies on the list if the data stays in the EU?

Because honesty beats a clean-looking list. Supabase, Vercel and Resend process VINCHY data inside the EU, but they are US-headquartered and their staff could in principle access systems for support. We name that and rely on their DPAs with Standard Contractual Clauses for exactly that case.

Which data actually leaves the EU?

Records (database), server functions and AI inference stay in the EU. These leave it: email via Resend (message content, logs and account data are stored in the USA), SMS via Twilio (USA), consent-gated website analytics (GA4) and — for static pages and support only — Vercel’s edge network. The transfer basis for each is in the table above. See Where your data lives for the component map.

Does any sub-processor train AI models on our data?

No. VINCHY never trains models on customer data. At Mistral AI Zero Data Retention is enabled for our organisation on the EU endpoint (confirmed in writing on 15 October 2026), the training opt-out is set, Labs models are disabled, and pay-as-you-go API data is excluded from training under Mistral's Commercial Terms. No other listed provider receives prompts or documents.

Can I get this in writing?

Yes. Request the AVV (Art. 28 GDPR) with this list as Annex 3 at hallo@sigoo.de. The dated version of this page is the binding list.

Need the AVV?

Request the data processing agreement with this list as its annex. We answer within two working days.

Request the AVV