OttoLegal

Sub-processors

Draft — must be reviewed by a qualified lawyer in the EU before publishing.

Words in [SQUARE BRACKETS] are placeholders to fill in. Notes marked Review, Decision, Verify or Engineering are for the reviewing lawyer and for Max; remove every one of them before publishing.

Version: Draft 0.1 · 30 September 2026 · In force from [EFFECTIVE DATE]

These are the companies that process personal data for Otto when we work for our clients. Each one has signed data processing terms with us that give at least the protection of our Data Processing Agreement. This list is Annex III of that agreement.

Current list

Sub-processorWhat it does for OttoPersonal data it receivesWhereTransfer safeguard
Hetzner Online GmbH, GermanyHosts the Otto server; daily server snapshots; encrypted off-site backups (Storage Box)Everything Otto stores; backups are encrypted before they leave the serverGermany (Nuremberg and Falkenstein data centres) Verify: Storage Box locationInside the EU
Cloudflare, Inc., USADNS, encrypted connections, firewall and rate limits, delivery of our pages, our team's sign-in to the owner console (Cloudflare Access)Connection data of every visit, including IP addresses; our team's sign-in e-mail addressesGlobal network; company in the USAEU–US Data Privacy Framework; standard contractual clauses in Cloudflare's DPA
Google Ireland Limited, Ireland (with Google LLC, USA)Authentication: Sign in with Google for the Otto appThe sign-in happens on Google's page; Google tells Otto the user's e-mail address, name and Google account IDEU and USAEU–US Data Privacy Framework; standard contractual clauses Review: Google acts as an independent controller for the user's Google account
Anthropic, PBC, USAClaude AI models: strategy, captions, ad texts, briefs, summariesBrand profile, website text, the client's answers and instructions, drafts, performance summaries; this can include names quoted from the client's websiteUSAStandard contractual clauses Verify: DPF status, no training on API data, retention period
Leonardo Interactive Pty Ltd (Leonardo.ai), AustraliaImage generation as a fallback when Higgsfield is unavailable, including OpenAI's GPT Image models, to which Leonardo passes the promptImage prompts (descriptions of the brand, product and scene); reference images where usedVerify: processing location; OpenAI in the USAStandard contractual clauses Verify: generations private and not used for training
ElevenLabs, USA Verify: contracting entitySynthetic voice-over for reelsThe voice-over scriptUSA Verify: EU data residency optionVerify: DPF or standard contractual clauses
Higgsfield AI, USA Verify: contracting entityImage generation for posts, reel scenes and ads (OpenAI's GPT Image 2, to which Higgsfield passes the prompt); voice-over and video generation for some reelsImage prompts (descriptions of the brand, product and scene); reference images where used (e.g. the client's product photo); scripts and visual promptsUSA; OpenAI in the USA VerifyVerify: DPA with standard contractual clauses; generations private and not used for training
Telegram Verify: contracting entity, only for clients who choose TelegramDelivers approval cards, reports and alertsPost previews and captions, report text, the client's Telegram user IDVerifyReview: Telegram offers no data processing agreement; treat it as a channel the client chooses, or offer it outside the EU only
[EMAIL PROVIDER], from the launch of e-mail approvalsSends approval and report e-mailsRecipient e-mail address, message contentVerifyVerify
Stripe Payments Europe, Ltd., Ireland (with Stripe, Inc., USA)Payment processing for Otto's own subscriptions: the payment form inside Otto's Billing page, subscriptions, invoices and receipts, VAT calculation (Stripe Tax)Billing contacts of clients (name, e-mail, billing address, VAT ID), plan and payment history; card and bank details go to Stripe directly and never to OttoEU and USAEU–US Data Privacy Framework; standard contractual clauses in Stripe's DPA Review: Stripe is a processor for billing, invoicing and tax, and an independent controller for payment processing, fraud prevention and its legal duties (Stripe's DPA and privacy policy)

Engineering: until Otto moves to the Hetzner server (a pre-launch item in docs/HOSTING.md), production runs on an Amazon Web Services server shared with other projects. Move before the first EU client, or add AWS to this list with its region.

Services that are not our sub-processors

Changes to this list

We tell clients at least 30 days before a new sub-processor starts processing their personal data, by e-mail to the account address and by updating this page. A client can object within that time on reasonable data-protection grounds. If we cannot meet the objection, the client can end the affected service before the change and we refund fees paid for the time after it ends. In an emergency (for example to keep Otto running when a provider fails), we may make a change at shorter notice and tell clients at once.

To receive notices without being a client, or for questions, write to [PRIVACY EMAIL].

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