Effective Date: September 21, 2026 for any Account created on or after that date. For an Account existing on that date, this document takes effect thirty (30) days after itogai gives notice under the Customer Terms of Service. This document is new, so no prior version is displaced and none governs in its place. Last Modified: September 21, 2026 Document Version: APR-2026-09-21 v5.0
This register lists every third-party model provider Itogai LLC (“itogai”) engages, what each one does, and the training position verified for that provider individually. It is incorporated by reference into the Customer Terms of Service, the Privacy Policy and the Data Processing Agreement.
1. The commitment, and why it is stated per provider
The engagement rule. itogai engages a model provider only where that provider commits that itogai’s Customer Data will not be used to train the provider’s general-purpose models. That is a rule about who itogai will engage, and it is stated once, here.
The verified position. What each engaged provider has actually committed to, and the date itogai last verified it, is stated per provider in Section 3. itogai never states the position itself as a single claim across providers, because it rests on a separate instrument with each one and those instruments differ. The rule above says who itogai will engage. Section 3 says what each engaged provider has committed to, and when itogai last checked.
What follows from the rule. No itogai document makes a training claim about a provider this register does not carry. A provider that will not commit is not engaged. Where a provider’s own terms impose a stricter constraint than itogai’s commitment, the stricter constraint governs and is recorded with that entry.
2. What is never sent to any provider
Email message bodies. Anything held at Level 1 under Section 4 of the Privacy Policy is never available to be sent, because it is never read or stored in the first place.
No provider in this register receives raw email content, and none ever will, because the source it would have to come from is held at Level 1 permanently by canon rather than by configuration.
3. The providers
| # | Provider | What it does for itogai | Training position | Basis | Last verified |
|---|---|---|---|---|---|
| 1 | Anthropic, PBC | Primary model inference for Akai™: drafting, summarization, structured extraction, and answering a person’s questions about their own network | Inputs and outputs submitted through the commercial API are not used to train the provider’s models | The provider’s published commercial terms applicable to itogai’s API account | September 22, 2026 |
| 2 | OpenAI, L.L.C. | Model inference for the same purposes. Audio transcription where a person records and submits a voice input. Text vectorization for retrieval | Inputs and outputs submitted through the API are not used to train the provider’s models | The provider’s published business terms applicable to itogai’s API account | September 22, 2026 |
| 3 | Google LLC | Model inference through the Gemini API, as an additional provider in the same set | Inputs and outputs submitted through the paid API tier are not used to train the provider’s models. This position is specific to the paid tier, and itogai uses no free tier for any customer data | The provider’s published terms applicable to the paid API tier | September 22, 2026 |
The verification behind the dates. Each position above was read on the provider’s published terms on the date shown: Anthropic’s statement that inputs and outputs from its commercial products are not used to train its models by default; OpenAI’s statement that data sent to its API is not used to train or improve its models unless the customer opts in; and Google’s statement that, on the paid tier, prompts and responses are not used to improve its products. A provider’s written agreement specific to itogai’s account, where one exists, is recorded here the day it does.
Retention at the provider, stated plainly. Each provider above keeps API inputs and outputs for a limited period for abuse monitoring under its published terms (up to thirty (30) days at the time of verification) and deletes them after, unless a zero-data-retention agreement is in place, in which case nothing is kept. itogai requests a zero-data-retention agreement from every provider it engages, states which providers hold one here the day one does, and changes nothing else when one is signed; none holds one on the Effective Date.
3a. Where a Customer supplies their own key
On the plans the Service Schedule states, a Customer may run Akai on their own key with a provider in Section 3. Prompt content then leaves under the Customer’s own agreement with that provider and under the terms that provider applies to the Customer’s account. itogai has not verified those terms and does not vouch for them, and the position recorded in Section 3 applies to itogai’s own account with the provider, never to the Customer’s. Two things do not change: only a provider in Section 3 may be used, and Section 2 applies in full, so email message bodies are never sent, on any key. One thing does change on the Customer’s side of the ledger: an action Akai produces on the Customer’s own key consumes no assist, and the fair-use rate limit that applies instead is stated in the Service Schedule and in the product.
On this register. A provider is listed here while it is capable of receiving prompt content, and removed once it is not. Listing a provider that has been switched off is harmless. Omitting one that is live is a defect, which is why this register errs toward listing. Where a provider is removed from the Subscription Service, its row comes out in a routine update under Section 7.
4. What each provider receives
| Category | Sent to a provider | Notes |
|---|---|---|
| Contact name, employer, role | Yes, within a prompt | The context that makes an output useful |
| Communication metadata: who, when, how often | Yes, in summarized form | Envelope fields, never bodies |
| Text a person types into Akai | Yes | This is the request itself |
| Text a visitor types into the assistant on the marketing website | Yes | No account is involved and no personal data is requested. The Product Surface Register describes the assistant |
| Text of a document or slide deck a person selects in Google Drive as a contact source | Yes, for the extraction of contact fields only | The Privacy Policy states the level. The file text is not retained |
| Text a person explicitly asks Akai to work on | Yes | Including a draft they ask it to revise |
| Text of a conversation a person imports as a file or reads on screen, where they have turned content signals on for that source | Yes, once, at import, to derive relationship signals | Not used for training. Kept by the provider only for the short abuse-monitoring period its verified terms state (today, up to thirty (30) days), or not at all where itogai holds a zero-data-retention agreement with it. The request carries no account identifier beyond an opaque batch token. With content signals off, nothing is sent |
| An audio recording a person makes and submits | Yes, to the transcription provider only | Only where a person records one deliberately |
| Email message bodies | Never | Held at Level 1. Not read, not stored, not available to send |
| Message content from a source held at Level 1 | Never | The same |
| Payment instrument details | Never | Collected directly by the payment processor and never held by itogai |
| Authentication credentials or tokens | Never |
5. What the models do and do not decide
Akai drafts, surfaces and explains. Akai does not send. Every outbound message it drafts is delivered only after a person has reviewed it and clicked send on that specific message. No provider in this register is given the ability to take an action on a person’s behalf.
A score is not a model output. The TrustGraph™ score is computed by itogai’s own algorithm from signals itogai holds. It is not produced by, and is not sent to, any provider in this register for the purpose of producing it.
No automated decision-making with legal effect. itogai does not make, and does not enable a customer to make, a decision producing legal or similarly significant effects on a person by automated means. A score is a probabilistic estimate offered as support for a person’s own judgment.
6. How a provider is selected
Before engagement, each is reviewed against: necessity to providing the service; published security posture; published data handling terms including retention of inputs and outputs; the training position, which must be verifiable in an instrument rather than asserted in marketing material; the legal regimes governing its processing locations; and the availability of an approved transfer mechanism.
A provider that will not commit to the position in Section 1 is not engaged, however good the model is.
7. How this register changes
One definition governs every itogai register and every legal document wherever a change affects personal data. Where a document turns on something else, it states its own trigger, and the same thirty (30) days’ notice applies:
A change is material when it expands the categories of personal data processed, expands the purposes of processing, expands the categories of recipients, or reduces a right the customer holds.
Material, with thirty (30) days’ advance notice by publication and by email to the registered account owner, and with the objection route below:
- Adding a provider. Always material, because a model provider is a recipient of prompt content and adding one expands the categories of recipient.
- Any weakening of a training position recorded in Section 3. itogai would not adopt one, and states the notice obligation so that the commitment is enforceable rather than merely stated.
- Sending a category of data to a provider that Section 4 does not list.
Routine, published immediately with the version incremented:
- Removing a provider.
- Changing which provider handles which task, among providers already in this register.
- Recording a re-verification date.
- Recording a strengthened position.
The route to object. During the notice period the Customer may object in writing to legal@itogai.com. itogai and the Customer will discuss the objection in good faith, and if they cannot agree a path forward within thirty (30) days of the objection, the Customer may terminate the affected portion of the Subscription Service for material breach of the Data Processing Agreement, and itogai will refund prepaid fees attributable to the period after termination. Separately, a material change to this register gives every Customer the right to terminate before it takes effect and receive a pro rata refund of prepaid unused fees, under Section 20.5 of the Customer Terms of Service. That right does not require the Customer to object first, or to explain why.
Where a provider’s published terms change so that the position recorded in Section 3 no longer holds, itogai ceases sending Customer Data to that provider and updates this register within five (5) business days.
Subscribe to changes: write to legal@itogai.com with the subject line “Register notifications”.
8. Re-verification
itogai re-verifies each position in Section 3 at least annually, and additionally whenever a provider announces a change to its terms. The result is recorded in the “Last verified” column whether or not the position changed, so that an unchanged date is itself informative.
9. Contact
legal@itogai.com for this register. privacy@itogai.com for data subject and privacy rights requests.
Postal address: Itogai LLC Attn: Legal Department 4821 Jumping Way Lake Worth, Florida 33467 United States of America
Changelog
New in this release. This register did not exist before September 21, 2026. It records each model provider and the training position verified for that provider, replacing the blanket claim the prior documents made.
Amended September 21, 2026, before first publication, for the data-source harness. Section 4 adds the one case in which the text of an imported or on-screen conversation transits a provider, at import, with no training and with retention limited to the provider’s verified abuse-monitoring period, and the pointers to the former Data Source Register now point to the Privacy Policy. Section 3a states that an action on the Customer’s own key consumes no assist.
Amended September 21, 2026, before first publication. New Section 3a states what changes when a Customer runs Akai on their own key, and Section 4 adds the website assistant and Drive document extraction as things a provider receives. The engagement rule and the three providers are unchanged.
Document version: APR-2026-09-21 v5.0. Published at itogai.app/legal/ai-providers.
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