Sub-processors
The providers that process data on behalf of AIGiner, S.L.: what we use them for, where they operate and under which safeguard. This is the list the terms of each service and the data processing agreement refer to.
01. What this list is
A sub-processor is a provider that processes personal data on AIGiner's behalf in order to deliver a service: hosting the server, sending an email, charging an order. This page lists all of them, with the actual location of the processing and the safeguard that covers it.
When the list changes, it is updated here with the date. Anyone with a signed data processing agreement with us also receives the prior notice that agreement sets out, with the right to object within the period it fixes.
02. The sub-processors
| Provider | What it does | Where it processes the data | Safeguard |
|---|---|---|---|
| Contabo GmbH | Production server: the API, the database and the backups of Shara and of AIGiner's services. | Lauterbourg (France), European Union | Processor within the European Union. |
| Supabase | User authentication and customer database. | Ireland (eu-west-1), European Union | Data processing agreement; data hosted in the European Union. |
| Cloudflare | DNS, website publishing, protection against attacks, inbound email, the academy and message-inbox databases, and backups in storage under European Union jurisdiction. | European Union; network metadata also in the United States | Data processing agreement and Standard Contractual Clauses. |
| TensorX Ltd. (company no. 796387; Unit 25, Classon House, Dundrum Business Park, Dublin 14, Ireland) | Language-model inference: the website assistant, the phone assistant, message classification and the automated reviews of Web Check and Monitoring, plus Shara’s models. | Dublin and Helsinki, European Union | Data processing agreement (TensorX’s public DPA, incorporated into its Terms, September 2026), which prohibits processing data outside the European Economic Area or the United Kingdom without our prior written consent: there is no international transfer of the content of the requests (account data may pass through its sub-processors in the United States). It does not train models on the data and does not keep the requests. |
| ElevenLabs | Real-time voice, transcription and analysis of the phone assistant’s calls. By default it does not record the voice and keeps transcripts for 90 days; the client can agree another period or switch recording on. | United States | ElevenLabs data processing agreement and certification under the EU-US Data Privacy Framework; Standard Contractual Clauses as a fallback. |
| Resend | Outbound email: confirmations, reports and notices. | United States | Data processing agreement and Standard Contractual Clauses. |
| Stripe | Card payments, invoices and subscription portal. | Ireland and United States | Data processing agreement and Standard Contractual Clauses. AIGiner neither sees nor stores the card number. |
| Telegram | Shara's ticket-based support channel and internal notices. Notices from the aiginer.com forms carry no personal data at all. | Outside the European Economic Area (Telegram FZ-LLC, Dubai) | There is no processing agreement and no signed standard contractual clauses with Telegram. That is why internal notices carry no personal data. In Shara support, only what the user writes in their ticket goes through it. |
| Google LLC (Gmail) | Mailbox where we receive the email you send to any @aiginer.com address and from which we reply | United States and other countries outside the European Economic Area | Google processes that email under its terms of service, including outside the European Economic Area. |
| WhatsApp Ireland Limited (WhatsApp Business) | Receiving and answering the messages you send us on WhatsApp. | Ireland; may transfer data to Meta Platforms, Inc. in the United States | WhatsApp Business terms. The transfer to the United States relies on the EU-US Data Privacy Framework. |
| Holded | Invoicing and accounting. | Spain, European Union | Processor within the European Union. |
| Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) | Google Analytics 4: aggregate web analytics for aiginer.com (page views, origin, general device type). Only activated if the person accepts the "analytics" category in the cookie notice; otherwise the browser does not contact Google. No advertising, remarketing or Google Signals. It does not measure the contact cards, the screens after payment, the academy or the course. | Ireland, European Union; may transfer data to Google LLC in the United States | Google Ads Data Processing Terms (GDPR). The transfer to the United States relies on the EU-US Data Privacy Framework (Google LLC is certified) and on Standard Contractual Clauses. Legal basis: consent, withdrawable from the cookie manager. Retention: 2 months for event data and 14 months for data linked to a user. |
03. What does not leave the European Union
The content the agents and reviews process —what you write, the documents you upload, what is on your website— is processed on servers and inference located in the European Union. What does leave, and we say so, are seven processing activities: outgoing email (Resend), incoming email (Gmail), WhatsApp messages, network metadata (Cloudflare), payments (Stripe), Shara support (Telegram) and the voice of phone-assistant calls (ElevenLabs).
And one more, which only happens if you accept it: the analytics of aiginer.com with Google Analytics 4, which may involve a transfer to the United States. It does not affect the agents’ content or client data.
No sub-processor uses your data to train models, and neither do we. The inference provider does not keep the requests.
04. Change log
- 26 October 2026 · Safeguards corrected: Telegram has no signed standard contractual clauses, and Gmail (incoming email) and WhatsApp are listed.
- 24 October 2026 · Google Ireland Limited joins as a sub-processor: Google Analytics 4 on aiginer.com, only with consent to the analytics cookies.
- 30 September 2026 · the inference provider is now named: TensorX Ltd., Ireland.
- 30 September 2026 · ElevenLabs joins as a sub-processor: voice, transcription and analysis of the phone assistant’s calls.
- 22 September 2026 · first publication of the list.
- 3 September 2026 · n8n is no longer a sub-processor: the tool was switched off and will not be reintroduced.