Sub-processors
Effective 2026-10-15
This page lists the sub-processors that Aitonomy B.V. ("Aitonomy"), engages to process Customer Data and Customer Materials in connection with the Aitonomy platform and Aitonomy's services (together the "Services"). These third parties are sub-processors within the meaning of the GDPR. Words written with a capital that are not defined here have the meaning given in the SaaS Terms and Conditions, the Services Terms and Conditions and the Data Processing Agreement.
This list covers sub-processors that process Customer Data or Customer Materials in connection with the Services, including the providers of AI models that Aitonomy engages. The processing of the personal data of visitors to our website is described in our Privacy Statement.
Two ways an AI model is used
An AI model is used through the Services in one of two ways, which follows from the Customer's configuration (clause 3.2 of the SaaS Terms and Conditions):
A model provider engaged by Aitonomy. Aitonomy contracts with the provider, and the provider processes Customer Data as a sub-processor of Aitonomy. These providers are listed in the table below, with their location and transfer basis, and the Data Processing Agreement applies to them.
The Customer's own AI provider. Where the Services run on an AI subscription or AI service that the Customer contracts itself (a Customer AI Provider), that provider is not engaged by Aitonomy and is not a sub-processor of Aitonomy. It is therefore not listed below. The Customer's own contract with that provider governs its processing, including where the data is processed and whether it may be used for training, and the settings of that account are the Customer's responsibility.
How models are selected
This section concerns model providers engaged by Aitonomy. Aitonomy is model-independent. A model is selected for each task and recorded for each Agent, weighed on capability, cost and the jurisdictional requirements of the Customer's organisation. There is no single default model and no single model provider. Where processing or inference by such a provider takes place outside the European Economic Area, or where access from outside it is possible, the table below states this together with the transfer mechanism that applies.
Data residency and sovereignty are not the same thing, and we set them out separately because the difference decides which providers a Customer can accept:
Data residency. Where the data is physically processed and stored. Processing by Aitonomy takes place within the European Economic Area. For each sub-processor, the table below states where processing takes place and, where that is outside the European Economic Area or access from outside it is possible, the transfer mechanism that applies under Chapter V of the GDPR, such as an adequacy decision or the European Commission's standard contractual clauses.
Sovereignty. Which jurisdiction the provider itself is subject to. A provider based outside the European Economic Area remains subject to the law of its own jurisdiction even where it processes exclusively within the European Economic Area.
Both occur, and the table below states which applies to each provider:
A fully European chain. Both processing and inference with providers established in the European Economic Area. This is what we apply where a Customer is a critical entity or is otherwise subject to a hard jurisdictional requirement, and it can be agreed as a restriction in the Order Form.
A frontier model from outside the European Economic Area, served from European infrastructure. This is resident within the European Economic Area but the provider is not subject to European jurisdiction alone. Where this applies, the table below states the provider, the location and the transfer mechanism, and the model used for each Agent is recorded in the audit trail and available to the Customer on request.
Model providers are engaged per task, as the Customer's configuration determines; a Customer can restrict them to European providers only in the Order Form.
Jurisdiction and access by public authorities
Where the Service is hosted by Aitonomy, it runs on infrastructure of Scaleway SAS, a French company, in France and the Netherlands, subject to European Union law. Encrypted backup copies are held separately with Hetzner Online GmbH, a German company, in Germany, also subject to European Union law. If the Service has to be restored from those copies, in a disaster-recovery event or a scheduled recovery test, the restored Service may run temporarily on infrastructure of Hetzner Online GmbH in Germany. Where a provider listed below belongs to a group subject to the law of a country outside the European Economic Area, the table says so. Aitonomy does not disclose Customer Data to a public authority of a country outside the European Economic Area unless a legal basis under European Union or Member State law requires it, challenges a request it considers unlawful, and informs the Customer where it is permitted to do so. The technical measures that protect Customer Data, including encryption and access control, are set out in Schedule 1 to the Data Processing Agreement.
How the terms of these providers apply
Aitonomy engages these providers to deliver part of the Services. Their own terms apply to the part they provide, and a functional or technical limitation in those terms, such as supported features, usage limits or model behaviour, applies correspondingly to that part of the Services, as set out in clause 2.8 of the SaaS Terms and Conditions and clause 2.8 of the Services Terms and Conditions. This does not affect Aitonomy's own obligations on security, confidentiality, data protection and training. The table below links to those terms so the Customer can see what they contain.
One commitment overrides this: Aitonomy contracts a provider of AI models only where that provider's terms exclude the use of Customer Data to train or improve the provider's models, and verifies this before the provider is used. Where a provider's terms do not allow that, Aitonomy does not use that provider for Customer Data (clause 7.4 of the SaaS Terms and Conditions).
Where a sub-processor processes Personal Data, Aitonomy engages it under a data processing agreement with the obligations required by Article 28 of the GDPR, and, where processing or access takes place outside the European Economic Area, only with a valid transfer mechanism as stated in the table.
Current sub-processors
| Sub-processor | Purpose | Location | Jurisdiction and transfer basis | Their terms |
|---|---|---|---|---|
| Scaleway SAS | Cloud hosting and related services: hosting, storage and processing of Customer Data and Customer Materials for the Services, object storage for backups, and transactional email for forms and notifications. Also AI model serving, where the Customer's configuration uses a model served by Scaleway. | France (Paris); Netherlands (Amsterdam) | France, European Union. Within EEA | Contracts and data processing agreement |
| Hetzner Online GmbH | Off-site backup storage and recovery: storage of daily backups of the hosted Service's databases and configuration, kept separate from the hosting provider, and, in a disaster-recovery event or a scheduled recovery test, temporary hosting and processing of the Service restored from those backups. The backups are encrypted by Aitonomy before they leave its infrastructure, and Hetzner does not hold the key. A restored Service is protected by the measures set out in Schedule 1 to the Data Processing Agreement. | Germany (Falkenstein, Nuremberg) | Germany, European Union. Within EEA | Terms and conditions and data processing agreement |
| Amazon Web Services EMEA SARL, Bedrock | AI model provider engaged by Aitonomy (sub-processor). Processing of prompts and related inputs submitted to Agents in an EU region, where a task uses a model served on AWS Bedrock, which is how Aitonomy uses Claude, subject to any restriction recorded in the Order Form. | EU region (EEA), region-restricted | Luxembourg entity within a group subject to United States law. Within EEA, with standard contractual clauses for any access by the provider's non-EEA group. Resident in the EEA but not subject to European jurisdiction alone | Service terms and data protection |
| Mistral AI SAS | AI model provider engaged by Aitonomy (sub-processor). Processing of prompts and related inputs submitted to Agents, where a task uses a Mistral model that is not available through Scaleway. | France, European Union | France, European Union. Within EEA | Legal centre, including the commercial terms and the data processing addendum |
| TransIP B.V. | Email hosting for Aitonomy's business correspondence. Processes Customer Materials only to the extent the Customer sends them to Aitonomy by email. | Netherlands | Netherlands, European Union. Within EEA | Terms and privacy |
| Lettermint B.V. | Standby transactional email: delivery of email from forms and notifications, used only where the primary transactional email provider is unavailable. | Netherlands (EU infrastructure) | Netherlands, European Union. Within EEA | Terms of service and data processing agreement |
AI models and the providers behind them
The table above lists the parties that process Customer Data as sub-processors of Aitonomy. An AI model that runs through the Service is made available by one of those parties, and the model itself comes from a model provider whose terms apply to the use of that model, as set out above. Which model runs for which Agent is recorded in the audit trail and is available to the Customer on request. Models and providers may change over time; a change of sub-processor is notified under clause 5.3 of the Data Processing Agreement, so that the Customer can object on reasonable data protection grounds.
The party that serves the model is the Sub-processor. Where Aitonomy engages a model provider directly rather than through a party already listed, that provider is added to the table of current sub-processors, with its location and transfer basis, before any Customer Data is processed by it. A model provider that does not itself receive Customer Data is not a sub-processor of Aitonomy, and is listed here for transparency.
| Model provider | How the model is made available | Where processing takes place | Jurisdiction of the provider | Their terms | Status |
|---|---|---|---|---|---|
| Open-weight models served by Scaleway | Served by Scaleway on European infrastructure | France, Netherlands | France, European Union | Scaleway contracts | In use |
| Anthropic (Claude) | Served by Amazon Web Services on Amazon Bedrock in an EU region. The inputs are processed by Amazon Web Services, and model providers have no access to Bedrock logs, prompts or completions. Aitonomy does not engage Anthropic directly for Customer Data | EU region (EEA) on Bedrock | Anthropic PBC, United States; served by AWS EMEA SARL | Model terms via AWS Bedrock | In use, via Bedrock |
| Mistral AI | Directly with Mistral, for models that are not available through Scaleway | France, European Union | France, European Union | Legal centre, including the commercial terms and the data processing addendum | In use |
| OpenAI (ChatGPT and GPT models) | Not used in the Service at present. If a Customer chooses an OpenAI model, Aitonomy adds the serving party to the table above before use, with its location and transfer basis | Not applicable while unused; stated in this list before any use | United States; OpenAI Ireland Limited for customers in the EEA | Data processing addendum, sub-processor list and the trust portal | Not currently used |
Where the Customer uses its own AI subscription, such as its own ChatGPT or Claude account, that provider is a Customer AI Provider: the Customer contracts with it directly, it is not a sub-processor of Aitonomy, and it is not listed here.
Tools we host ourselves. Aitonomy also uses open-source software that it runs on its own infrastructure, for example for secrets management and for internal collaboration. Where Aitonomy operates such software itself and no third party has access to the data in it, that software is not a sub-processor and is not listed here. The infrastructure it runs on is listed above.
Updates
As our business develops, our sub-processors may change. Where a change is relevant, we will update this list and give notice to our customers as required under the Data Processing Agreement. A customer may object to an intended change on reasonable data protection grounds within fifteen (15) days of the notice, as set out in clause 5.3 of the Data Processing Agreement.
Aitonomy B.V. · KvK 42198573
Version 2026-10-15