Legal

Sub-Processor Registry

Last updated October 8, 2026

This registry lists the third-party service providers (sub-processors) that process personal information on behalf of Etcera, operated by Akimi Labs Ltd. It is maintained for transparency and for compliance with applicable privacy laws, including PIPEDA (Canada) and the CCPA/CPRA (California).

We use as few providers as the service allows. Each sees only what its job requires, and each is bound by a written data protection agreement. We do not use any provider that sells attention, behavioural prediction, or access to influence.

This registry supplements our Privacy Policy and works together with our Terms of Service.

Current sub-processors

1. OVHcloud (OVH Hosting Inc., Canada; OVH SAS group)

  • What they do: Run the AI models behind Etcera's assistant: replies, the extraction of entities and topics from your thoughts, the semantic index, and voice transcription (OVHcloud AI Endpoints)
  • What data they process: The text you write, the audio of what you say in a voice session, and the context the assistant is given from your record. The models return replies, transcripts, and derived connections.
  • Where your data is processed: European Union (OVHcloud datacentres in France). Nothing is stored there.
  • How long they keep it: Not beyond the request. OVHcloud keeps only what billing needs, which is the size of each request, not its content.
  • Do they train on your data: No. The contract states that OVHcloud has no knowledge of inputs and outputs, does not reuse them in any way, and does not back them up.
  • Privacy policy: ovhcloud.com/en-ca/personal-data-protection
  • Compliance: ISO 27001, SOC 2 Type II, and HDS certified service; GDPR compliant
  • Safeguards: Personal Information Protection Agreement (OVHcloud's Canadian data processing agreement) and the Specific Conditions for AI Endpoints, section 5 (inputs and outputs)
  • Last vendor review: October 2026

2. Cloudflare, Inc.

  • What they do: Carry your connection to our servers, protect them from attack, and relay voice media when you are away from our network
  • What data they process: Your IP address and connection details. Web traffic is decrypted at Cloudflare's edge and re-encrypted to our servers; voice media passes through the relay encrypted end to end and cannot be read there.
  • Where your data is processed: The Cloudflare location nearest to you
  • How long they keep it: Connection logs for a limited time, under Cloudflare's own policies. Cloudflare does not keep the content of what you write.
  • Do they train on your data: No
  • Privacy policy: cloudflare.com/privacypolicy
  • Compliance: ISO 27001, SOC 2 Type II; GDPR compliant
  • Safeguards: Cloudflare's data processing addendum
  • Last vendor review: October 2026 (initial listing)

3. Google LLC (Google Workspace)

  • What they do: Deliver the emails we send you: confirmation links, invitations, product updates, and support replies
  • What data they process: Your name, your email address, and the content of the emails we send you
  • Where your data is processed: Google's global infrastructure
  • How long they keep it: Sent mail stays in our mailbox under our retention schedule (Privacy Policy, section 5)
  • Do they train on your data: No. Google Workspace does not use customer data for advertising or to train generative AI models.
  • Privacy policy: policies.google.com/privacy
  • Compliance: ISO 27001, SOC 2 Type II; GDPR compliant
  • Safeguards: Google Workspace data processing addendum
  • Last vendor review: October 2026 (initial listing)

Planned

OVHcloud (hosting in Canada)

As we grow, we will store data on infrastructure leased from OVHcloud in Canada and operated by us. OVHcloud would then hold your stored data as well as process it, under the same Personal Information Protection Agreement. We will extend its entry above before that happens.

Stripe, Inc.

Stripe will process payments when Etcera Space subscriptions open. Until then, we collect no payment information. We will add Stripe to this registry, with the same details as above, before we charge anyone.

What we run ourselves

The following are not sub-processors. They run on servers we operate in Canada, our own today: the application and its databases, the service that holds your record, the knowledge graph, authentication, text-to-speech, and the voice media server.

Updates

This registry is updated whenever we add, remove, or change a sub-processor. We will notify you directly when a change materially affects how your personal information is processed.

Contact

The Privacy Policy has our mailing address.