Neo Clarity

Sub-processors

Effective date: October 15, 2026

Annex 2 to the Data Processing Agreement

These providers process data from your workspace on our behalf. The list forms part of the Data Processing Agreement. We inform you of any change at least 30 days in advance by email (§ 6 DPA). Your data is stored in the EU (Frankfurt am Main).

1. Sub-processors

Supabase · Supabase, Inc., San Francisco, USA

Purpose:
Database, authentication and file storage
Data:
All workspace data (leads, appointments, sales, transcripts, reviews, user accounts); integration credentials encrypted
Place of processing:
EU (Frankfurt am Main)
Third-country basis:
Stored in the EU; remote access for support and maintenance under the EU Standard Contractual Clauses

Always in use

Vercel · Vercel Inc., San Francisco, USA

Purpose:
Hosting of the web application, server functions and scheduled jobs
Data:
All data passing through the application during use; technical access data
Place of processing:
EU (Frankfurt am Main); static content delivered through a global network
Third-country basis:
EU Standard Contractual Clauses (Art. 46(2)(c) GDPR); additionally the EU-US Data Privacy Framework where the provider is certified

Always in use

Anthropic · Anthropic PBC, San Francisco, USA

Purpose:
AI features: the Neo assistant, reports, lead grading, call reviews, speaker detection, website and sales-script analysis
Data:
The content each task needs, including metrics, lead details and questionnaire answers, call transcripts including participants' names
Place of processing:
USA
Third-country basis:
EU Standard Contractual Clauses (Art. 46(2)(c) GDPR); additionally the EU-US Data Privacy Framework where the provider is certified

Always in use

ElevenLabs · ElevenLabs Inc., New York, USA

Purpose:
Speech-to-text for call recordings; voice output in call training
Data:
Audio of the calls, not stored at the provider or deleted there right after transcription; in call training only the text to be spoken
Place of processing:
USA
Third-country basis:
EU Standard Contractual Clauses (Art. 46(2)(c) GDPR); additionally the EU-US Data Privacy Framework where the provider is certified

Only when the feature is used

Resend · Plus Five Five, Inc. (Resend), San Francisco, USA

Purpose:
Sending system emails (invitations, access links, notifications)
Data:
Recipients' email address and name, message content
Place of processing:
EU (Ireland)
Third-country basis:
EU Standard Contractual Clauses (Art. 46(2)(c) GDPR); additionally the EU-US Data Privacy Framework where the provider is certified

Always in use

Sentry · Functional Software, Inc. (Sentry), San Francisco, USA

Purpose:
Detecting and fixing technical errors
Data:
Technical error data; personal content is largely stripped before sending
Place of processing:
EU (Frankfurt am Main)
Third-country basis:
EU Standard Contractual Clauses (Art. 46(2)(c) GDPR); additionally the EU-US Data Privacy Framework where the provider is certified

Always in use

2. Services you connect yourself

These services are not sub-processors. They run on your own account with the respective provider; data only flows once you connect them or switch the feature on, and your own contract with the provider applies.

  • Close: Read-only import of leads, activities, calls and opportunities
  • Typeform: Import of form responses; adding hidden fields for source tracking
  • Calendly: Import of bookings including the invitees' details
  • Meta (Facebook/Instagram Ads): Import of campaign metrics; on request, campaign steering and lead-stage feedback via the Conversions API (contact details hashed only)
  • Google Ads: Read-only import of campaign metrics
  • Google Drive: Fetching call recordings from folders the customer shares
  • Fathom: Fetching call transcripts through the customer's share links
  • Telegram: Messages from the Neo assistant, reports and call reviews (PDF with lead names and call excerpts) in chats and groups the customer links
  • MCP (Claude u. a.): Reading workspace data in an AI program a team member connects by signing in; their own contract with the program's provider applies