Trust
Subprocessors.
The complete list.
Every company that processes data on behalf of Leeside Labs Limited, what each one does, where it does it, and which of them ever see a client's material. Last reviewed October 2026.
We commit to the EEA, not to a country
Our commitment is to the European Economic Area as a contractual boundary, not to a particular country.
Chapter V of the GDPR turns on whether personal data leaves the EEA. It draws no distinction between Belgium and the Netherlands, so a promise of “Belgium” gives you no protection that a promise of the EEA does not already give, while guaranteeing that our next infrastructure change makes our own privacy policy inaccurate.
It also keeps the product good. Google ships its newest models on EU-wide endpoints; pinning to a single country means either paying a premium or staying on older models, and for legal documents model quality is not a cosmetic concern.
So: the EEA guarantee is binding. The specific regions are recorded below, are accurate at the review date, and may change.
Why that costs us nothing contractually
Google’s Service Specific Terms define an AI/ML Data Location as configuring services to store customer data at rest and perform machine-learning processing of it in a specified region or multi-region, with Google performing both only there. A multi-region is a defined term in those same terms (“a defined set of Regions”), so the commitment attaches to the boundary, not to a building. The eu multi-region strictly covers EU member states; the UK and Switzerland are outside it.
The register
Who processes your data
Six subprocessors. Two of them ever see matter content.
Supabase
Supabase, Inc. · parent: United States
- Purpose
- Database, authentication, backend functions, and storage for scanned pages and templates
- Processing location
- EEA (Ireland)
- Matter content
- Yes: Task text, notes, transcripts, formatted documents, scanned pages
Google Cloud
Google Cloud EMEA Ltd (Dublin) · parent: United States (Alphabet Inc.)
- Purpose
- All AI inference; object storage for audio recordings and uploaded documents; nightly database backups
- Processing location
- EEA (Belgium and the EU multi-region)
- Matter content
- Yes: Audio, documents, transcripts, prompts and completions, database backups
Vercel
Vercel, Inc. · parent: United States
- Purpose
- Website and application hosting, CDN
- Processing location
- EU functions region; US transfers allowed under its DPA (SCCs)
- Matter content
- No: Static assets and request logs
Stripe
Stripe Payments Europe Ltd (Dublin) · parent: United States (Stripe, Inc.)
- Purpose
- Subscription billing and VAT calculation
- Processing location
- Irish contracting entity; US transfers allowed under its DPA
- Matter content
- No: Name, email, billing address, business name and VAT number if entered at checkout, payment method, subscription state
PostHog
PostHog, Inc. · parent: United States
- Purpose
- Product analytics and session replay (consent-gated, off until you accept)
- Processing location
- EEA (Germany)
- Matter content
- No: Page views, feature events, a pseudonymous identifier, opt-in session replays
Brevo
Sendinblue SAS · parent: France
- Purpose
- Transactional and notification email, workspace activity digest
- Processing location
- EEA (France)
- Matter content
- No: Email address, name, lifecycle events; in the activity digest, task labels only (document type, recipient or subject, status), never a recording, a transcript or a document body
Two of those columns are easy to conflate, so we keep them apart. Processing location is where the bytes are processed and stored. That is what Chapter V of the GDPR turns on. Parent is where the group is incorporated, which determines whether a foreign government can serve a production order on the parent. It is not a transfer, but it is an exposure; see US ownership and the CLOUD Act below.
Matter content goes to two of them
Your recordings, transcripts, fee notes, briefs, attendance notes and correspondence are processed only by Supabase (database and scanned pages) and Google Cloud (audio and document storage, and all AI inference), both in the EEA.
Matter content is notsent to Stripe, PostHog, or any analytics, marketing or advertising processor. Brevo delivers our emails, and the workspace activity digest may include a document’s subject line, but never a recording, a transcript or a document body. Matter content is not sold, rented or shared, and it is not used to train AI models.
Google Cloud is the sole AI processor
Every user-facing task that touches matter content (transcription, tidying, classification, formatting, filing suggestions, reading a photographed page) runs on Google Vertex AI. There is no fallback AI provider. If Vertex is unavailable, the feature waits; it does not quietly reroute to somebody else.
“Sole AI processor” is a statement about who we send data to, not about whose model runs. Vertex serves models from more than one developer, including Anthropic. Document formatting runs on Anthropic’s Claude, served by Google on the EU multi-region endpoint. The request still goes to Google, under the Google Cloud data processing addendum and our own service-account credentials. Google’s partner-model terms state that customer prompts and model responses are not shared with third parties, including partner models. Anthropic receives nothing from us and is not a subprocessor. If that ever stops being true, they appear in the table above before the code ships.
Not a subprocessor: Microsoft
Sign-in uses Microsoft OAuth. We receive an identity assertion (your name, email address and tenant identifier) from your own Microsoft tenant. Microsoft is an independent controller for your Microsoft account, not our processor, and it receives no matter content from us. It is listed here because the privacy policy names it and readers ask.
Disclosed
The one exception for matter work
Deliberate, minimised, and yours to switch off.
When you record a letter to a solicitor we hold on no register, Clerk& can look up their public office address so the addressee block fills itself in. That lookup uses Google’s Web Grounding for Enterprise, and it is the single part of our stack Google does not contractually guarantee to process inside the EEA: their data-residency terms explicitly carve web grounding out of the machine-learning processing location commitment. We treat it as a permanent exception.
- What is sent: the recipient solicitor’s name, plus a fixed qualifier. Nothing else.
- What is never sent: the document, the recording, your client, the matter, any file.
- Lawful basis: legitimate interest, Article 6(1)(f): addressing your correspondence correctly. Assessed in a written legitimate interests assessment, available on request.
- Transfer mechanism: the Google Cloud data processing addendum and the 2021 Standard Contractual Clauses.
- Your control: it is on by default and can be turned off for your whole workspace in the practice profile. Each recipient is looked up at most once, then cached.
US ownership and the CLOUD Act
Five of our six subprocessors are US-headquartered groups. The position:
- Region is contractual and real. All matter content is stored and processed in the EEA, and we verify it rather than take it on trust. Stripe and Vercel, which never receive matter content, may transfer the account, billing and website data they hold to the United States under their own data processing terms.
- Region does not extinguish jurisdiction. The US CLOUD Act can in principle reach data held by a US provider’s foreign subsidiary. Choosing an EU region does not make a US-owned provider immune to a US order.
- What actually protects the material is therefore not geography alone, but the providers’ published commitments to challenge overbroad orders and to notify customers where lawfully permitted; the Standard Contractual Clauses and supplementary measures in each agreement; and the protections legally privileged material carries in its own right.
- We do not hold customer-managed encryption keys. A provider served with a valid order could technically produce plaintext. Customer-managed keys on the object store are the mitigation, and they are not implemented.
If customer-managed keys are a requirement for your chambers or instructing solicitors, tell us.
Changing this list
Adding a subprocessor is a decision we take deliberately, not a deployment detail. In order: a signed data processing agreement on file, this page and our internal register updated, the privacy policy updated, and, under the agreement we offer you, advance notice with a right to object.
Email hello@clerkand.com to be told in advance when this list changes, to raise an objection, or to ask for our data processing agreement, a transfer impact assessment, or a completed security questionnaire.
Appendix
Current regions
Accurate at the review date. Informational, not the commitment: the EEA guarantee above is.
Web and application hosting
Vercel
Dublin, Ireland (functions); global CDN
Database, auth, backend functions, storage
Supabase
Dublin, Ireland (AWS eu-west-1)
Audio and document storage
Google Cloud Storage
Belgium (europe-west1)
AI: transcription, tidying, classification, vision
Google Vertex AI
Belgium (europe-west1)
AI: document formatting
Google Vertex AI
EU multi-region
Subscription billing
Stripe Payments Europe Ltd
Ireland; Stripe, LLC (United States)
Opt-in analytics
PostHog EU Cloud
Frankfurt, Germany
Email
Brevo
France
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