Zeldoc's Subprocessor List
Zeldoc has a standard Data Processing Agreement (DPA) with each customer, incorporated into the Terms of Service, cf. Privacy Policy §5.3 and zeldoc.ai/dpa. This page publishes Zeldoc's current subprocessor list - name, service/purpose, data categories, location, transfer mechanism and retention status - pursuant to GDPR Art. 28(2). Customers are notified of new subprocessors at least 30 days in advance and may object on reasonable grounds.
1.Subprocessors (Zeldoc's infrastructure)
Zeldoc.ai ApS ("Zeldoc") uses subprocessors that process personal data on behalf of Zeldoc, cf. GDPR Art. 28(2) and (4). The subprocessors process only the user, administration and operations data necessary for the operation of the Platform (account/administration, operational, security and technical data, cf. the DPA, Appendix A.3(b), and Privacy Policy §3.1). Customer content (prompts, outputs) is not processed by the subprocessors unless otherwise stated in the table.
| Name | Country | Service/purpose | Processing at provider | Transfer mechanism | Retention |
|---|---|---|---|---|---|
| Hetzner Online GmbH | Germany | Hosting (fsn1) | Account/administration, operational, security and technical data only (databases, logs, backups, cache), cf. the DPA, Appendix A.3(b); not prompts/outputs | Not applicable (EU/EEA) | Per provider's policies |
| ScanNet/Zitcom (team.blue) | Denmark | Colocation of GPU servers | Physical access (access control, surveillance); memory-only inference without persistent content storage on the equipment, cf. DPA Clause 6 and Appendix C.2 | Not applicable (EU/EEA) | Per provider's policies |
| Cloudflare Inc. | USA | DNS, tunnel, WAF, TLS termination | Yes, in transit | EU-US Data Privacy Framework / SCC 2021/914, per provider's policies | Transient in-flight processing only; no persistent content storage |
| DNScale OÜ (Postscale) | Estonia (operations in the EU/EEA) | Transactional email, contact form | Personal data, not prompts | Not applicable (EU/EEA). Postscale's own network subprocessors (Tailscale, Vultr) may process data outside the EU, cf. Postscale's DPA §8 | Per provider's policies |
| Staan | EU | Web search | Search queries | Not applicable (EU/EEA) | Per provider's policies |
The list is updated continuously. Upon addition or replacement of subprocessors, customers are notified at least 30 days in advance via email and this page, cf. GDPR Art. 28(2). Customers may object on reasonable grounds; in case of disagreement, a right of termination is offered, cf. DPA Clause 7.3. Each subprocessor is bound in writing to no less protective terms, and Zeldoc remains liable, cf. GDPR Art. 28(2) and (4).
The search function sends search queries to Staan. When a search covers developer content (the IT category), the query is also sent to these public search services: GitHub, Stack Overflow, MDN, Arch Linux Wiki, PyPI, npm and crates.io.
Zeldoc processes customer content (prompts, documents, outputs) solely transiently during the AI inference itself and does not store it (Zero Data Retention), cf. DPA Clause 6 and Appendix C.2. Storage of chats, history, notes and knowledge bases takes place in the application layer chosen and operated by the Customer (e.g. Open WebUI, development clients or partner apps). Zeldoc neither hosts nor has access to this layer, cf. the DPA, Appendix A.3(c); the Customer is the data controller for this layer.
Zeldoc's own tools
The tools below are used by Zeldoc for its own operations, development, support and the website. The table shows what data each tool receives.
| Name | Country | Service/purpose | Sees customer content? | Transfer mechanism | Retention |
|---|---|---|---|---|---|
| Better Stack s.r.o. | Czech Republic | Uptime, status page | No | Not applicable (EU/EEA) | Per provider's policies |
| Plausible Insights OÜ | Estonia (data in Germany) | Visitor statistics for zeldoc.ai and docs.zeldoc.ai | No. Aggregated visitor statistics on the public websites only; no cookies, no persistent identifier, IP address not stored (one-way hash with a salt rotated every 24 hours) | Not applicable (EU/EEA) | Per the provider's policies |
| Discord Inc. | USA | Operational alerts (OpenSRE) / support | Automated operational alerts that can include excerpts of technical error logs; support conversations | EU-US Data Privacy Framework / SCC 2021/914, per provider's policies | Per provider's policies |
| Tailscale Inc. | Canada | Overlay network | No | SCC 2021/914, per provider's policies | Per provider's policies |
| 1Password (AgileBits) | Canada | Secrets management | No | SCC 2021/914, per provider's policies | Per provider's policies |
| GitHub Inc. | USA | Code, images, CI | No | EU-US Data Privacy Framework / SCC 2021/914, per provider's policies | Per provider's policies |
| Hugging Face Inc. | USA | Model weights | No | EU-US Data Privacy Framework / SCC 2021/914, per provider's policies | Per provider's policies |
| 37signals (Fizzy) | USA | Issue tracking | Only manually entered | EU-US Data Privacy Framework / SCC 2021/914, per provider's policies | Per provider's policies |
| Atlassian (Trello) | USA | Project management | Only manually entered | EU-US Data Privacy Framework / SCC 2021/914, per provider's policies | Per provider's policies |
2.AI model providers and external routing
The AI model providers below are independent controllers/processors and not subprocessors in Zeldoc's contract chain, cf. Privacy Policy §5.3 and §6. The Customer selects them via model choice in ZRouter; the contracting party is stated in brackets. Transfers to providers outside the EU/EEA only occur when the Customer actively selects such a model and are governed by SCC 2021/914 + a Transfer Impact Assessment (TIA), cf. Privacy Policy §6. Retention and model training follow each provider's own policies - reference is made to their public policies via the links below.
| Name (contracting party) | Status | Service/purpose | Data categories | Location | Transfer mechanism | Retention |
|---|---|---|---|---|---|---|
| OpenAI | In use | AI inference (frontier models) | Prompts, context for selected calls | USA | SCC 2021/914 + TIA | OpenAI privacy policy / Zero Data Retention documentation |
| Mistral AI | Listed, not in use | AI inference | Prompts, context for selected calls | EU | Not applicable (EU/EEA) | Mistral AI privacy policy |
| Anthropic (Claude) | In use | AI inference (frontier models) | Prompts, context for selected calls | USA | SCC 2021/914 + TIA | Anthropic privacy policy / Zero Data Retention |
| Google (Gemini) | In use | AI inference (frontier models) | Prompts, context for selected calls | USA | SCC 2021/914 + TIA | Google privacy policy |
| Microsoft (Azure AI Foundry) | Listed, not in use | AI inference (frontier models via Azure) | Prompts, context for selected calls | EU or USA (depends on selected region) | SCC 2021/914 + TIA when located outside EU/EEA | Microsoft privacy statement |
| Amazon Web Services (Bedrock) | Listed, not in use | AI inference (frontier models via Bedrock) | Prompts, context for selected calls | EU or USA (depends on selected region) | SCC 2021/914 + TIA when located outside EU/EEA | AWS privacy policy |
| Google (Vertex AI) | Listed, not in use | AI inference (frontier models via Vertex) | Prompts, context for selected calls | EU or USA (depends on selected region) | SCC 2021/914 + TIA when located outside EU/EEA | Google Cloud DPA |
Note: For Microsoft Azure AI Foundry, Amazon Bedrock and Google Vertex AI, the selected deployment region determines where inference is performed (EU or USA); the transfer mechanism follows from the selected region.
Routing via OpenRouter
OpenRouter is listed as a subprocessor for Zeldoc, cf. GDPR Art. 28, for routing external model inference, but is not in use today: external calls are sent directly to the selected model provider. If activated, OpenRouter acts as a subprocessor for the routing leg (Zeldoc to OpenRouter, USA), processing on Zeldoc's instructions under Zeldoc's agreement with OpenRouter (including SCC 2021/914 + TIA), and Zeldoc remains liable under GDPR Art. 28(2) and (4). The subsequent inference at the selected model provider falls outside Zeldoc's contract chain and follows the provider's own terms and policies - not Zeldoc's terms; the Customer is responsible for the legal basis, cf. Privacy Policy §6. Zeldoc cannot guarantee Zero Data Retention on the inference leg; the selected model provider's own retention policy applies.
| Name | Status | Service/purpose | Data categories | Location | Transfer mechanism | Retention |
|---|---|---|---|---|---|---|
| OpenRouter | Listed, not in use | Routing of external model inference (frontier models at the customer's choice) | Prompts and inference data for external calls | USA | SCC 2021/914 + TIA | Routing leg: per Zeldoc's agreement with OpenRouter (subprocessor). Inference leg: per the selected model provider's policies - not Zeldoc's terms |
The list of available model providers may change over time; the current portfolio is stated in ZControl and Privacy Policy §6.1.
3.EU data sovereignty and independence
The Platform's core operations (hosting at Hetzner and team.blue, AI inference on EU-hosted models) are resident in the EU/EEA. Network transit terminates TLS transiently at Cloudflare (USA) in flight, but no content is persistently stored outside the EU/EEA. The current delivery uses US and Canadian providers on the list for support functions (including Cloudflare for network and TLS termination, as well as email and development) and as independent recipients via model choice; in an alternative setup, core operations can be delivered without US companies. For providers outside the EU/EEA, SCC 2021/914 and/or the EU-US Data Privacy Framework apply as transfer mechanisms, cf. the tables above. Personal data is not persistently processed at these providers; they are used for support functions (web, email, development etc.) and see only user, administration and operations data, except transient in-flight transit via Cloudflare. For independent model providers (section 2), special rules apply, cf. Privacy Policy §6, as they act as independent controllers/processors and are not subprocessors.
4.Zeldoc's obligations
- Zeldoc enters into data processing agreements with all subprocessors, cf. GDPR Art. 28(2) and (4)
- Zeldoc ensures that subprocessors process personal data solely on Zeldoc's instructions
- Zeldoc ensures that subprocessors comply with GDPR's security requirements, cf. GDPR Art. 32
- Zeldoc notifies customers of new subprocessors at least 30 days in advance, cf. GDPR Art. 28(2)
- Zeldoc remains liable for the actions of subprocessors as for its own, cf. GDPR Art. 28(2) and (4)
5.Version history
| Version | Date | Change |
|---|---|---|
| 1.0 | 14 September 2026 | First publication of the named subprocessor list |
6.Contact
Questions about the subprocessor list or the Data Processing Agreement (DPA) can be directed to [email protected]. Zeldoc.ai ApS, CVR no. 46329902, Åboulevarden 69, 8000 Aarhus C, Denmark.