Mintry gives at least 30 days' notice of a new or replacement subprocessor by updating this list and emailing the members of every team (DPA, section 7.2).
Mintry uses the following subprocessors to provide Penny. "Customer Content" means the messages, mail, files, code, database results and derived memory of a team (Mintry acts as processor). "Account data" means members' account, billing and security data (Mintry acts as controller; these providers are Mintry's processors for it).
1. Infrastructure and service providers
| Subprocessor | Service | Data | Location of processing | Transfer safeguard |
|---|---|---|---|---|
| Google Cloud (Google Cloud EMEA Ltd / Google LLC) | Hosting: GKE (application), Cloud SQL (PostgreSQL database), Cloud Storage (files, uploaded exports), Secret Manager (connector credentials), Cloud Logging, Cloud NAT | All Customer Content and Account data | europe-west1 (St. Ghislain, Belgium) for data at rest | Cloud Data Processing Addendum; SCCs; EU-US DPF |
| Temporal Technologies, Inc. (Temporal Cloud) | Durable workflow orchestration for sync, backfill, extraction and digests | Workflow inputs, results and history | Temporal Cloud namespace on GCP europe-west3 (Frankfurt); company in the US (support access) | Temporal DPA; SCCs |
| OpenRouter, Inc. | Routing of AI model requests; usage and cost reporting | Excerpts of Customer Content sent in prompts, and the responses; request metadata | United States (EU in-region routing is available on OpenRouter's Business/Enterprise plans) | OpenRouter's data processing terms; SCCs |
| Stripe (Stripe Payments Europe Ltd / Stripe, Inc.) | Payments, saved cards, invoices, Stripe Tax, Customer Portal | Account data only: billing email, address, tax id, card data (held by Stripe), payments | EU and US | Stripe DPA and Data Transfer Addendum; SCCs; EU-US DPF |
| Resend (Plus Five Five, Inc.) | Transactional email: magic links, invitations, low-balance and billing notices, digests by email | Account data; Customer Content in digest emails | United States (sending may use eu-west-1, but account data and logs stay in the US) | Resend DPA; SCCs; EU-US DPF |
| Composio (Composio, Inc.; composio.dev) | Connecting outside apps (tools) and Google accounts, and executing tool calls and API requests on a team's behalf | Connection tokens for the apps and Google accounts a team connects (held by Composio, encrypted at rest with AES-256-GCM and in transit with TLS); the content of tool calls and their results, including email and calendar data for Google accounts connected through Composio. Composio keeps tool-call logs, including request arguments and response data, for up to 12 months, and files staged for a tool call for 24 hours. Zero data retention is not in place yet. | Composio does not publish where it processes data; per Composio's documentation | Data processing terms with Composio; transfer mechanism as set out in them |
2. AI model providers (reached through OpenRouter)
Penny sends Customer Content to these models only through OpenRouter, with the settings in section 3. The provider that serves an open-weight model is chosen by OpenRouter's routing unless pinned; section 3 recommends pinning.
| Model (as configured) | Used for | Provider | Location | Provider's data terms (API) |
|---|---|---|---|---|
anthropic/claude-sonnet-5 | Answers (Ask agent), extraction, digests | Anthropic, PBC (or, if routed, Google Vertex AI / Amazon Bedrock) | US | Commercial Terms: no training on customer content; inputs and outputs deleted within 30 days by default (flagged content up to 2 years); ZDR by agreement |
google/gemini-3.1-flash-lite | Classification and gating (secret check, mail gate, extraction gate) | Google (Vertex AI or Gemini API paid tier) | US / global | Paid services: prompts and responses not used to improve products; logs kept for a limited time for abuse detection. Free tier must never be used (human review, training; and not allowed for EEA/UK/CH users) |
baai/bge-m3 | Embeddings (search index) | An inference provider chosen by OpenRouter among zero-data-retention providers | Varies by provider | Zero data retention through OpenRouter |
cohere/rerank-v3.5 | Re-ranking search results | Cohere | Varies by provider | Zero data retention through OpenRouter |
qwen/qwen3-reranker-8b | Re-ranking (alternative) | An inference provider chosen by OpenRouter among zero-data-retention providers | Varies by provider | Zero data retention through OpenRouter |
3. How AI requests are configured
Mintry's OpenRouter account has prompt and response logging off and the use of inputs and outputs for training off,
with zero data retention enforced account-wide. Every request asks for zero data retention, denies data collection,
and is limited to named providers, so a fallback never leaves that list. Free (:free) model variants are never
used.
4. Planned (not in use during pilots)
| Subprocessor | Service | When |
|---|---|---|
| Unipile | Gmail access for gmail.com users through an aggregator with its own CASA | Only if Google verification and CASA are not complete by public launch (umbrella spec). Its brand appears on the Google consent screen. |
5. Not subprocessors: the sources you connect, and your own agents
These services are where the Customer's data comes from or where Penny posts on the Customer's instruction. The Customer chooses and contracts with them directly; they process data under their own terms as independent controllers (or as the Customer's processors), not on Mintry's behalf. Mintry does not list them as subprocessors, and the DPA's subprocessor-change notice does not apply to them.
| Service | Why it is not a subprocessor |
|---|---|
| Slack (Slack Technologies) | The Customer's workspace. Penny reads it with the Customer's authorisation and posts answers and digests into it. Slack holds the data under the Customer's own Slack agreement. |
| Telegram (Telegram Messenger Inc. / Telegram FZ-LLC) | The chat platform. Penny's bot receives messages from groups and channels it is added to and posts into them. Telegram processes that under its own terms. Uploaded Telegram Desktop exports go straight to Penny (Google Cloud). |
| Google as Gmail provider | The member's mailbox. Distinct from Google Cloud and Google's AI models above, which are subprocessors. When a mailbox or calendar is connected through Composio, Composio is the subprocessor (section 1); Google remains the provider of the data. |
| GitHub | The Customer's repositories, read through the Penny Memory GitHub App. |
| The Customer's database host | The Customer's own infrastructure. |
| AI assistants connected by MCP (Claude, ChatGPT, Cursor and others) | Connected and configured by the Customer under its own agreement with that vendor. |