Subprocessors
Last updated: 20 April 2026
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. Supports Schedule 1 activities (c) and (e). |
| 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
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