ewpireLegal
Sub-processors
Last updated 2 November 2026
How to read this list
This list sets out the third parties that receive personal data when ewpire delivers the Service, in three groups: providers that process data for ewpire; the providers of AI models; and companies that act on their own account. A request to an AI model goes only to the API aggregator that handles it and the provider of the model used.
Providers that process data for ewpire
| Provider | What it does | Where | Transfer mechanism |
|---|---|---|---|
| Cloudflare, Inc. | Network protection and content delivery for ewpire.com; object storage for uploaded files, generated media and database backups; hosting of sites published from Code; bot check on sign-in where enabled; page-view measurement, only if you accept Analytics | Global network; object storage not limited to the EU; operator in the US | Data Privacy Framework adequacy decision where the provider is certified; Standard Contractual Clauses where its data-processing terms include them |
| Hetzner Online GmbH | Server that runs ewpire's application and database | Finland (EU) | None needed (EU) |
| Resend, Inc. | Service e-mail (sign-in codes, receipts, notices) and product news you opted into | US | Data Privacy Framework adequacy decision where the provider is certified; Standard Contractual Clauses where its data-processing terms include them |
| Functional Software, Inc. (Sentry) | Error monitoring: error events with technical context, which may include an IP address and never include request content | EU region (Germany); operator in the US | Stored in the EU; for any access from the US, as for Resend |
| PostHog, Inc. | Product analytics, only if you accept the Analytics category | EU region; operator in the US | Stored in the EU; for any access from the US, as for Resend |
| Zone Media OÜ | Mailbox that holds messages you send to hello@ewpire.com and privacy@ewpire.com | Estonia (EU) | None needed (EU) |
AI model access
These providers receive the content a request needs: the prompt and its conversation, attached files or their extracted text, reference images, code files, and a project-context summary only where you switch it on. They receive it to produce the result and handle it under their own terms. ewpire reaches models through API aggregators, which forward each request to the model's developer or to a hosting provider serving that model. For each request ewpire chooses the route, and a request to a model may be served by another provider of the same model. Where a route supports it, the request carries an instruction to use only providers that do not train on inputs, according to the aggregator's records of their terms. Recipients set their own retention periods, which ewpire does not control: some keep generated media for about 14 days and logs that can include the text of a request for about two months, and others keep content for a shorter or a longer time. Not every recipient in this section is covered by an adequacy decision or by Standard Contractual Clauses; transfers are described in the Privacy Policy, Section 6, and privacy@ewpire.com answers how a transfer to a particular recipient is made.
The API aggregators are described here by role and region; ewpire gives their names and addresses without undue delay to anyone who asks privacy@ewpire.com, and every change notice names the provider concerned.
| Provider | What it does | Where |
|---|---|---|
| API aggregators (names on request) | Carry chat, code, image, video, music, Consensus, AI Visibility and API requests. Forward each request to the model's developer or to a hosting provider serving it. | US; may process in other countries outside the EEA |
Model developers. Each model's developer is shown in the catalog at ewpire.com/models, which is the current list. A request goes only to the developer of the model used, or to a hosting provider serving that model, through the aggregator that handles it.
Auto developers (models Auto may choose): Anthropic, OpenAI, Google and xAI (United States). Requests reach them through the API aggregators above. We give 30 days' notice before adding a developer to this list.
Third-party access. The Suno music models are marked third-party access in the catalog. They come through an API aggregator and not from Suno itself, and ewpire is not affiliated with Suno, Inc. Suno and the aggregator that reaches it are not ewpire's processors for these models: they handle your content as independent controllers under their own terms, may process it outside the EEA, and may keep or use it; Suno's terms allow it to use prompts and lyrics to improve its models. These models are used only after you accept the notice shown before first use; do not include personal or confidential information in requests to them. For business accounts these models are outside the Data Processing Agreement (Section 5.3). They are never selected by Auto.
Labs established in China. China has no EU adequacy decision. At the date of this list the catalog has models of these developers established in China: Alibaba (Qwen), ByteDance, DeepSeek, Moonshot AI and Z.ai. They are used only when you select them; Auto does not select them.
Companies that act on their own account
These companies are not ewpire's processors: each decides for itself how it uses the data it receives, under its own terms.
| Company | What it receives | Where |
|---|---|---|
| Stripe Payments Europe Limited and affiliated Stripe entities | Payment details for top-ups and invoices | Ireland; US |
| GitHub, Inc. | Only if you connect GitHub to push a Code project: the code you push and your authorisation | US |
Not active
Listed in advance; each is added to the active list, with the notice below, before it is used.
- Google (sign-in).
Change notice
ewpire gives notice before adding or replacing a provider that processes data for it, an API aggregator, or an Auto developer: at least 30 days for a provider outside the EEA or an addition to the Auto developers, and at least 14 days for a provider in the EEA or a like-for-like replacement. A business customer may object under the Data Processing Agreement (Section 4.2); if the objection is not resolved, it may close its account and ewpire refunds the Credits it purchased and has not used. A model you select yourself needs no advance notice: its developer is shown in the catalog before you select it.