Effective Date: October 15, 2026 for any Account created on or after that date. For an Account existing on that date, this version takes effect thirty (30) days after itogai gives notice under Section 9. Last Modified: October 15, 2026 Document Version: SP-2026-10-15 v5.2
This register lists every third party that Itogai LLC, a Florida limited liability company (“itogai”), engages to process personal data on itogai’s behalf in operating the Subscription Service. It is incorporated by reference into the Privacy Policy and the Data Processing Agreement, and it is one of the registers described in Section 8 below.
What this register is for. The contract states what itogai may do with data and what rights a Customer holds. This register states who is currently involved in doing it. Vendors change more often than obligations do, so separating them means engaging a vendor updates this page rather than amending a contract. What does not change is the notice a Customer receives, which is set out in Section 9 and is identical to the rule in the Customer Terms of Service and the Data Processing Agreement.
Definitions. A sub-processor is a third party engaged by itogai that processes personal data on itogai’s behalf. itogai remains responsible to the Customer for each sub-processor’s acts and omissions to the same extent as for its own. A customer-directed recipient, listed separately in Section 6, is a third party the Customer connects using the Customer’s own credentials; itogai transmits data to it at the Customer’s direction and does not engage it.
Each sub-processor is bound by a written agreement that limits its processing to the services it provides to itogai; requires safeguards appropriate to the nature of the data; and, where transfers out of the EEA, the United Kingdom or Switzerland are involved, incorporates the European Commission’s Standard Contractual Clauses together with the UK International Data Transfer Addendum or the Swiss addendum as applicable.
On processing locations. The location column states where the sub-processor processes itogai data, drawn from the vendor’s own published documentation and, where itogai controls the setting, from itogai’s configuration. itogai’s own application hosting runs in the United States. Where a sub-processor’s row names more than one location, that row states the regions in which that vendor operates the service itogai uses, and itogai’s configuration within them. Locations are re-verified each time this register is reversioned. itogai’s own personnel access its production systems from the United States and from Colombia, under written terms that bind each of them to process personal data only on itogai’s instructions and to store none of it locally; no itogai data is stored in Colombia, and itogai has no establishment there.
1. Infrastructure and platform
These sub-processors run, store or secure the Subscription Service itself. Every category of data the service holds passes through them.
| # | Sub-processor | Service provided | Categories of data | Processing location |
|---|---|---|---|---|
| 1 | Auth0, part of Okta, Inc. | Authentication and identity management. Token issuance and validation for every surface | Account Data, email address, subject identifier, authentication tokens | United States |
| 2 | Railway Corp. | Application hosting and application logs | All Account Data, Customer Data and Usage Data the service processes, and application logs | United States |
| 3 | Stripe, Inc. | Payment processing for subscription fees, Sparks, and payouts to Bridgers | Billing Data, plan state, customer and account identifiers. Payment instrument details are collected by Stripe directly and are never transmitted through or stored by itogai | United States |
| 4 | Supabase, Inc. | Managed PostgreSQL, the primary datastore, and object storage | Account Data, Billing Data, Customer Data, structured relationship signals, encrypted integration tokens | United States and European Union; itogai’s project, including the primary database, is configured in the United States |
2. AI providers
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. A provider that will not commit is not engaged. What each engaged provider has committed to, and the date itogai last verified it, is stated per provider in the AI Provider Register.
| # | Sub-processor | Service provided | Categories of data | Processing location |
|---|---|---|---|---|
| 5 | Anthropic, PBC | Model inference for Akai™ and for relationship intelligence features including drafting, summarization and structured extraction | Prompt content, which may include contact names, communication metadata, relationship context and text the User supplies | United States |
| 6 | Google LLC (Gemini API) | Model inference, as an additional provider in the same set | Prompt content as above | United States |
| 7 | OpenAI, L.L.C. | Model inference for the same purposes. Audio transcription where a User submits a voice input. Text vectorization for retrieval | Prompt content as above; audio a User records and submits; text submitted for vectorization | United States |
What is never sent to a model provider. Email message bodies. Content from any source held at Level 1 under the Privacy Policy is not available to be sent, because it is never read or stored in the first place.
The case in which consented content transits. Where a Customer has turned content signals on for a conversation it imports as a file or reads on screen, the text of that conversation may transit one of the providers above once, at import, to derive relationship signals. No provider uses it to train its models, no provider keeps it beyond the period its verified terms set for abuse monitoring (today, up to thirty (30) days, or fifty-five (55) days for Google, and longer for content a provider’s own systems flag for a policy violation) unless itogai holds a zero-data-retention agreement with that provider, and the request carries no account identifier.
3. Data enrichment and professional information
These sub-processors receive identifiers for a contact that a Customer has asked itogai to enrich, or for a contact in an import the Customer starts or a person a User names to reach whose profile itogai completes, and return business contact and professional information about that person or their employer.
| # | Sub-processor | Service provided | Categories of data | Processing location |
|---|---|---|---|---|
| 8 | People Data Labs, Inc. | Contact enrichment and profile completion | Identifiers of the contact submitted for enrichment or whose profile is completed | United States |
4. Communications and notifications
| # | Sub-processor | Service provided | Categories of data | Processing location |
|---|---|---|---|---|
| 9 | Brevo, operated by Sendinblue SAS | Transactional email delivery: account, security, billing and product notifications, and an introduction email a User sends from intros@itogai.com when the User’s own account can’t send it. Contact records captured through itogai’s own marketing forms |
Recipient name and email address; message subject and body, which itogai composes for its own transactional mail and which carries the User’s own text in an introduction email sent from intros@itogai.com; form submissions |
European Union |
| 10 | Canny, Inc. | Product feedback board reachable from the Subscription Service | The User’s name and email address, and the feedback they choose to submit | United States |
| 11 | Day AI, Inc. | itogai’s own customer relationship system of record, used to operate itogai’s business | Contact and account records for itogai’s customers and prospects, meeting history, and notes itogai appends | United States |
| 12 | Granola, Inc. | Meeting notes for itogai’s own calls, used to operate itogai’s business | Recordings and transcripts of calls itogai’s team holds with customers and prospects, and the notes itogai keeps | United States |
| 13 | Nylas, Inc. | The Microsoft 365 (Outlook) mailbox and calendar integration, through API aggregation; it reads only, and nothing is sent or written through it | Message metadata only, never message bodies; calendar event times and attendees; the mailbox grant token | United States |
| 14 | OneSignal, Inc. | Push notification delivery on any surface that offers notifications. The Product Surface Register records which surfaces currently do | Notification title and body as composed by itogai, which may include a contact’s name; external user identifier; device subscription identifier | United States |
| 15 | Slack Technologies, LLC | Internal operational alerting and escalation, and inbound support routing | Import and error summaries, escalation content, and support inquiry content where a User initiates one | United States |
5. Analytics, monitoring and security
| # | Sub-processor | Service provided | Categories of data | Processing location |
|---|---|---|---|---|
| 16 | Amplitude, Inc. | Product analytics | Usage Data, plan state, acquisition source, the User’s email address used as the analytics identifier, and marketing website usage data after a visitor agrees | United States |
| 17 | Cloudflare, Inc. | Automated abuse prevention on public forms only. itogai does not use Cloudflare as a content delivery network | The challenge token and the caller’s IP address | Global anycast. A request is served from the nearest edge, which may be outside the EEA |
| 18 | Functional Software, Inc., trading as Sentry | Application error and performance monitoring, and session replay. Replay masks all text and blocks all media before transmission | Stack traces, release identifiers, breadcrumbs, a user identifier in error context, and masked replay recordings | United States |
| 19 | PostHog, Inc. | Product analytics | Usage Data, and the User’s email address used as the analytics identifier, as in row 16 | United States |
| 20 | Webflow, Inc. | Hosting of the marketing website | Marketing website visitor device and log data | United States |
Two disclosures stated plainly, because a general description would understate them. First, Sentry’s session replay records a masked reconstruction of a session on the authenticated platform, not merely an error report. Second, Amplitude and PostHog receive the User’s email address itself as the identifier that distinguishes one User from another, which is a direct identifier rather than a pseudonymous one.
6. Customer-directed recipients
These are not itogai sub-processors. A Customer connects each one with the Customer’s own credentials, and itogai transmits data to it at the Customer’s direction and under the Customer’s own agreement with that provider. They are listed here because a complete picture of where data goes is more useful than a technically narrow one.
Sources a Customer may bring in are named on the informational page Supported sources and import methods, and the content level of each category is stated in the Privacy Policy.
Destinations a Customer may direct itogai to write to: the record systems and tools the Customer connects. A User’s own email and calendar account is also a destination, where the integration for that provider supports it: a message the User reviewed and clicked send on goes out through it, from the User’s own address, and an event the User scheduled is written to it. Where the Customer maps the field, a relationship score is among what is written to a record system.
The User’s own AI assistant. Where a User connects itogai to an AI assistant they already use through the MCP server described in the Product Surface Register, that assistant receives the User’s own itogai data at the User’s direction and under the User’s own agreement with that assistant’s provider. The MCP server returns the requesting User’s own data and nothing else.
A Customer who disconnects an integration stops all further transmission to that recipient. Data already delivered to it is governed by the Customer’s own agreement with that provider, and itogai cannot retrieve or delete it.
7. Incidental recipients
A third party that receives personal data by virtue of how a page is delivered, without processing it on itogai’s behalf, would be disclosed here rather than left out on a definitional technicality.
There are none. the platform’s pages load their typefaces and static assets from itogai’s own origin, the marketing website’s from its website host in row 20, and the marketing website loads the analytics script of the provider in row 16 only after a visitor agrees, so loading an itogai page discloses nothing to any third party this register does not already carry. This section is kept, empty, because an absent section reads as an oversight and an empty one reads as a commitment.
Google LLC appears in Section 2 as a model provider and, where a Customer connects a Google account, as a Customer-directed source named on the page Supported sources and import methods and as the provider through which a User’s own email is sent and own calendar written. Those are separate engagements under separate terms, and neither involves a page load.
8. The registers
This page is one of three registers incorporated by reference, each published, versioned and governed by the notice rule in Section 9. The page Supported sources and import methods sits beside them, informational and not incorporated.
| Register | Holds |
|---|---|
| Sub-processors, this page | Every third party that processes personal data on itogai’s behalf |
| Supported sources and import methods (informational, not a register incorporated by reference) | The sources a Customer may bring in, described by category and by the way data enters an account |
| AI Providers | Every model provider, with the training commitment verified and dated for that provider |
| Product Surfaces | Every surface the Subscription Service is delivered on, with the device capabilities each may request and requests |
A vendor, source, provider or surface is added by updating its register. No amendment to the Customer Terms of Service or the Data Processing Agreement is required, which is what allows itogai to ship without a contract cycle for every integration. The converse also holds: a third party that receives data and does not appear in the applicable register is a defect, and it is a defect whether or not anyone has noticed.
9. 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.
Everything else is a routine update.
Material change. At least thirty (30) days’ advance notice, given both by updating this page and by email to the registered Account Owner of every Customer. The Data Processing Agreement is incorporated automatically when a Customer creates an Account or pays a fee, so this notice is not limited to Customers that have requested a countersigned counterpart. Adding or replacing a sub-processor always carries this notice, whatever its category.
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.
Routine update. Published immediately with the Document Version incremented. No advance notice.
The right to leave. Separately from the objection route above, 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.
Worked examples. Adding a second payment processor carries the same thirty (30) days’ notice, because every addition does, even where the purpose and the category of recipient are already disclosed. Adding a first voice transcription provider is material, because it introduces a category of personal data the register did not previously carry. Replacing one data provider with another carries the same notice. Removing a sub-processor is routine. Beginning to send message bodies to a recipient that previously received only metadata is material, and in the specific case of email bodies is not permitted at all.
Subscribing to changes. Write to legal@itogai.com with the subject line “Register notifications” and itogai will add the address to the notification list. Any person may subscribe, whether or not they have executed a Data Processing Agreement.
10. How itogai selects a sub-processor
Before engagement, each is reviewed against: necessity to providing the service; published security posture covering encryption, access control and incident response; published privacy posture covering processor terms, support for data subject rights, and training commitments where relevant; independent certification where it exists; and the legal regimes governing its processing locations together with the availability of an approved transfer mechanism.
itogai prefers vendors that publish their own processing terms, maintain their own sub-processor lists, and will commit contractually to the training position stated in Section 2. A provider that will not commit is not engaged.
11. Historical versions
On written request to legal@itogai.com, itogai will provide the version of this register in effect on a specified date.
12. Contact
Questions about this register, sub-processor objections, and notification subscriptions: legal@itogai.com. Data subject and privacy rights requests: privacy@itogai.com.
Postal address: Itogai LLC Attn: Legal Department 4821 Jumping Way Lake Worth, Florida 33467 United States of America
Changelog
Amended October 15, 2026, version SP-2026-10-15 v5.2. Row 10 carries an introduction email only when the User’s own account can’t send it, and row 12 carries the Microsoft 365 integration only until itogai’s direct integration ships, reading only. Section 6 lists a User’s own email and calendar account as a destination, and Section 8 says which registers are incorporated.
Amended October 9, 2026, version SP-2026-10-09 v5.1. A placeholder location in one row was replaced with the location confirmed with the provider. No sub-processor was added or removed, and no purpose, category of data or location in any other row changed, so this is a routine update under Section 9 and takes effect immediately.
What changed from SP v2.0, May 11, 2026, and why.
Amended September 21, 2026, before first publication, for the security, privacy and AI governance layer. Section 2 discloses that itogai’s own personnel access its production systems from the United States and from Colombia under written processor terms, storing nothing locally. Row 12 names the calendar integrations and the Microsoft 365 (Outlook) integration as what the aggregation provider carries.
Amended September 21, 2026, before first publication, for the data-source harness. Section 2 states the one case in which consented conversation content transits a model provider at import, with no training and with retention limited to the provider’s verified abuse-monitoring period. The pointers to the former Data Source Register now point to the informational page Supported sources and import methods.
- Twenty-four sub-processors, where the prior version listed twelve. Fifteen receive data and were missing; three named vendors were not in use.
- Vercel and Neon are removed, along with the content delivery network description of Cloudflare, none of which reflected what runs.
- Three model providers are listed, where the prior version listed two.
- Customer-directed recipients and incidental recipients are separated from itogai’s own sub-processors.
- Notice now reaches every Customer, not only those holding a countersigned agreement, and carries the refund the Data Processing Agreement promises.
- Audio transcription is now recorded as a purpose and as a category of data. The provider that performs it was already listed; the audio itself was not named, and the worked example in Section 9 calls that material.
Amended September 21, 2026, before first publication. Row 10 no longer describes every message body as composed by itogai. An introduction message is sent in itogai’s own name but carries the User’s own text, and the row and the note beneath the table now say so. Rows were added so that the register describes the platform as designed, including Granola and Canny, which itogai uses to run its own business. Section 6 names the User’s own AI assistant as a customer-directed recipient over the MCP server, and a Slack channel as a digest destination. The subscription subject line is Register notifications, the same on every register.
A copy of the prior version is available on written request to legal@itogai.com.
Document version: SP-2026-10-15 v5.2. Published at itogai.app/legal/sub-processors.
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