Sub-processors
Last updated: 1 August 2026. Revised to cover the Coach Companion. Supersedes the version last updated 20 April 2026. Rendered from the same source as Schedule 2 of the DPA. Plain language on How we protect your practice.
CoachNova engages the following sub-processors to assist in providing the Services described in our Data Processing Agreement. Each sub-processor is bound by data protection obligations substantially equivalent to those in our DPA. This list is rendered from the same source as Schedule 2 of the DPA.
We will notify subscribers at least 30 days before adding or replacing a sub-processor. To subscribe to updates of this list, email privacy@coachnova.ai with the subject line “Subscribe to sub-processor updates”.
Current Sub-processors
| Service | Legal Entity | Entity Country | Data Processing Region | Transfer Mechanism | Purpose |
|---|---|---|---|---|---|
| Amazon Web Services | Amazon Web Services EMEA SARL | Luxembourg | eu-west-1 (Ireland), eu-central-1 (Frankfurt) | N/A (EU processing) | Object storage for session recordings, transcripts, generated PDFs, and GDPR data exports. Supports Schedule 1 activities (a) and (d). |
| Vercel | Vercel, Inc. | US (Delaware) | US and EU edge | EU-US Data Privacy Framework + SCCs | Application hosting, serverless compute, and scheduled jobs. Supports Schedule 1 activities (f) and (g). |
| Neon | Neon, Inc. | US (Delaware) | EU | N/A (EU processing) | Primary PostgreSQL database and pgvector store for Coach Content metadata, messages, notes, and embeddings. Supports Schedule 1 activities (a) through (e). |
| Clerk | Clerk, Inc. | US (Delaware) | US | Standard Contractual Clauses | User authentication, session management, and OAuth for Coach and Coachee accounts. Supports Schedule 1 activity (f). |
| Recall.ai | Hyperdoc, Inc. (d/b/a Recall.ai) | US (Delaware) | EU | N/A (EU processing) | Meeting bot API for session recordings, transcripts, and metadata from video conferencing platforms. Supports Schedule 1 activities (a) and (b). |
| Anthropic | Anthropic, PBC | US (Delaware) | US | Standard Contractual Clauses + EU-US Data Privacy Framework | AI model services (Claude Sonnet and Haiku) for transcript analysis, notes generation, summaries, and suggested nudges for Coach review and approval, for real time Coach Companion conversation with Coachees, and for automated safety detection within those conversations. Supports Schedule 1 activities (c), (e), (f), (g) and (h). |
| Voyage AI | Voyage AI Innovations, Inc. | US (Delaware) | US | EU-US Data Privacy Framework + SCCs | Embedding model (voyage-3-lite) for semantic retrieval over Coach Content and Coachee Input. Supports Schedule 1 activities (c) and (d). |
| Twilio SendGrid | Twilio Inc. (US parent); Twilio Ireland Limited (EU counterparty) | US (Delaware) / Ireland | US (primary SendGrid infrastructure) | EU-US Data Privacy Framework + SCCs via Twilio Ireland Limited | Transactional email delivery, including AI-generated session notes, Coachee messages containing personal data, and platform notifications. Supports Schedule 1 activities (c) and (e). |
Data Transfer Safeguards
Where sub-processors are located outside the European Economic Area (EEA), we ensure appropriate safeguards are in place:
- Standard Contractual Clauses (SCCs): We use the EU Commission-approved SCCs (Module Three: processor to sub-processor) for transfers to non-adequate countries.
- EU-US Data Privacy Framework: Where applicable, we rely on sub-processor certifications under the EU-US DPF.
- Supplementary measures: We implement additional technical and organisational measures where necessary to ensure an essentially equivalent level of protection.
Updates and Notifications
We maintain this page with the current list of sub-processors. When we plan to add or replace a sub-processor, we:
- Update this page at least 30 days before the change takes effect;
- Notify subscribed coaches by email;
- Provide details of the new sub-processor's purpose, location, and transfer mechanism.
If you have objections to a new sub-processor, please review Section 4.2 of our Data Processing Agreement for the objection process.
Questions
If you have questions about our sub-processors or data processing practices, contact us:
Coach Nova Limited
71 Lower Baggot Street, Dublin 2, D02P593, Republic of Ireland
Privacy inquiries: privacy@coachnova.ai