Sub-processor List

Sub-processors. A sub-processor is a third party that processes personal data on our behalf in order to deliver part of the Service. The table below identifies each provider we engage, what it does, the data involved, where it processes data and the transfer safeguard we rely on.

Relationship to the Data Processing Agreement. This list is the current version of Annex III to the Data Processing Agreement. Providers on it that process personal data on behalf of our customers are Sub-processors within the meaning of §6 of the Data Processing Agreement. The list also identifies providers we use for processing for which ManyPI is controller, such as our own analytics, our website and payments. Their inclusion does not change the allocation of roles under §1 of the Data Processing Agreement.

Conditional providers. Providers marked conditional are engaged only if you use the corresponding feature. For example, Microsoft is engaged for mailbox access only where a customer connects a Microsoft mailbox.

PostHog. PostHog receives consented browser analytics from the website and the app, including browser errors and masked session replay where enabled. It also receives separate server-side events and diagnostics from the app. Rejecting analytics in the cookie banner stops browser tracking. §12 of the Privacy Policy explains the legal basis for server-side telemetry and how to object to it.

Payments. New purchases are processed through Stripe Managed Payments. Stripe's affiliate Sold through Link, LLC is the merchant of record: it invoices in its own name and handles indirect tax, refunds, disputes and transaction support. Stripe and Sold through Link, LLC act as independent controllers for the sale, fraud prevention and tax, and Stripe also holds our customer and subscription records as our processor. Polar and Lemon Squeezy remain engaged only for the subscriptions they already bill. Since April 2026, Lemon Squeezy has been operated by the same company, Sold through Link, LLC, formerly Lemon Squeezy LLC. Payment providers receive billing data for which ManyPI is controller, not personal data that we process on behalf of customers under the Data Processing Agreement.

Primary locations. Your account data, CRM records, lead records and synchronised mail are stored on servers located in the European Union. Our primary storage and background infrastructure are located as follows:

1. •
   Primary database, authentication and file storage: European Union (Supabase, EU region).
2. •
   Background processing, email verification and the web research gateway: Germany and Finland (Hetzner Online GmbH).

No guarantee of processing only in the EEA. These are the locations of our primary storage and background infrastructure. They are not a guarantee that every service provider processes data only within the EEA: some providers are established outside the EEA, and some providers that store data in the EEA may access it from elsewhere.

PostHog. Product analytics and diagnostics are hosted in Germany (PostHog Cloud EU, Frankfurt). PostHog, Inc. is a US company, and international support or administrative access may occur. EU hosting does not remove the need for a transfer safeguard. The provider's data processing agreement and privacy notice are linked in the table in §1.

Transfers to third countries. We transfer personal data to a third country only where a specific function requires a provider established outside the EEA: principally AI inference, application hosting and content delivery, payment processing and the delivery of our own service email in the United States, and web data collection in Israel.

Safeguards. For each such transfer we rely on:

1. (a)
   for Israel, the adequacy decision of the European Commission;
2. (b)
   for providers in the United States, the EU-US Data Privacy Framework where the provider is certified under it and, in addition, the EU Standard Contractual Clauses in the provider's data processing terms; and
3. (c)
   for any other third country, the EU Standard Contractual Clauses or another appropriate safeguard under Article 46 GDPR.

Why we use both. Where a US provider is certified under the EU-US Data Privacy Framework, the Standard Contractual Clauses ensure that the transfer remains covered if the adequacy decision for the Framework ceases to apply.

Customers outside the EEA, the UK and Switzerland. The transfer mechanisms between you and ManyPI, including the Standard Contractual Clauses (Module Four) for customers established in a third country without adequate protection, and the arrangements for the United Kingdom and Switzerland, are set out in §11 of the Data Processing Agreement and its Annex IV.

Information on request. You may request information about the safeguard in place for any specific transfer at privacy@manypi.com.

Integrations you configure. The Service lets you connect third-party systems of your own choosing, either directly or through the Model Context Protocol. Currently available presets include:

1. •
   HubSpot
2. •
   Intercom
3. •
   Notion
4. •
   Linear
5. •
   Asana
6. •
   Atlassian (Jira, Confluence)
7. •
   GitHub
8. •
   Sentry
9. •
   Vercel
10. •
    Cloudflare
11. •
    Stripe
12. •
    PayPal
13. •
    Square
14. •
    Canva
15. •
    Figma
16. •
    Zapier
17. •
    and any custom MCP server you configure

Not ManyPI sub-processors. These providers are not ManyPI sub-processors. You choose them, you authorise the connection with your own credentials, and you decide what flows through it. You are responsible for having your own lawful basis, for any agreement with the provider that data protection law requires and for any transfer safeguard that a transfer outside the EEA requires. §6 of the Data Processing Agreement sets out this allocation.

Credentials. We hold the credential you supply so that the connection can operate. It is encrypted at the application layer and is never returned to the browser.

Providers not engaged. We do not engage the following providers:

1. •
   Crawlbase and Decodo: no integration exists. Web data collection is handled solely by Bright Data.
2. •
   Mailgun: no integration exists. Our own service email is delivered by Resend; outreach campaigns are sent from your own mailbox.
3. •
   Google Gemini and any other AI provider: OpenAI is our only AI provider. Google appears in the table in §1 solely for sign-in and, if you connect one, Gmail mailbox access.

No advertising pixels or third-party CAPTCHA. We do not use advertising or retargeting pixels, and we do not embed reCAPTCHA or a comparable third-party CAPTCHA; our CAPTCHA is self-hosted. PostHog is used for product analytics, error diagnostics and consented, masked session replay where enabled, as described in §1.

Notice of changes. We inform customers of any intended addition or replacement of a sub-processor at least thirty (30) days before the change takes effect, by updating this list and by email to everyone who has subscribed to change notifications under clause 5.3.

Urgent changes. Where a sub-processor must be replaced at short notice to address a security risk, or because it ceases to provide its service without adequate notice to us, we may make the change immediately and give notice as soon as possible afterwards. The right to object under clause 5.4 then runs from the date of that notice.

Subscribing to notifications. To subscribe, email privacy@manypi.com with the subject line "Subscribe: sub-processor changes" and the address you would like us to use. There is no charge, and we use the address solely for these notifications.

Right to object. If you are a customer and object to an intended change on reasonable grounds relating to data protection, write to legal@manypi.com within the notice period. If we neither withdraw the change nor offer a reasonable alternative, and your objection is not resolved, you may terminate the affected Paid Plan or the Agreement with immediate effect and without penalty, and we refund, on a pro-rata basis, any fees prepaid for the unused remainder of your Subscription Term.

Source of these rights. These rights are set out in §6 of the Data Processing Agreement, which prevails over this section in the event of a conflict.