EPAV DESK · SUB-PROCESSOR LIST

Version 1.0 · Effective from 9 October 2026

Operator: NeriusCognitaren OÜ, registry code 17503018, Sepapaja tn 6, 15551 Tallinn, Harju maakond, Estonia
Questions and objections: privacy@epavdesk.com

This list is Annex 3 of the EPAV Desk Data Processing Agreement (the "DPA"). It names the companies that process personal data of your Visitors and Agents on our behalf when you use EPAV Desk ("Sub-processors"), what each does, which data it receives, where, and on what basis data leaves the European Economic Area (EEA).

How we tell you about changes. Before we add or replace a Sub-processor, we email the owner of every cabinet at least 30 days before it starts processing your data. You can object within 14 days of that email at privacy@epavdesk.com. Section 7 of the DPA describes what happens then, and when an urgent replacement is allowed. Each change is also recorded at the end of this page.


1. Always used

Railway Corporation


2. Used when the cloud AI of your plan answers

On a paid plan, the AI assistant uses our cloud AI while the AI budget of your plan lasts. Requests go from our AI gateway to OpenRouter, which passes each one to a model host. If you connect your own AI provider in your Site, the requests that it answers go to your provider instead, under your own contract with it.

OpenRouter, Inc.

Models and hosts behind OpenRouter

Hosts named "seen in use" are chosen by OpenRouter for each request among those that meet our settings, and may change without prior notice from OpenRouter (Section 7.3 of the DPA). Hosts in Indonesia, Singapore and China are in countries without an adequacy decision; OpenRouter passes requests to them under its own terms with them.

Voyage AI Innovations, Inc. (MongoDB, Inc.)


3. Used for email

SMTP2GO (Sand Dune Mail Ltd)


4. Used for our support

Google LLC (Gmail)


5. Not Sub-processors

EPAV's own AI model. During a trial, when the cloud AI budget of your plan is used up, after 14 days of a failed payment, after the paid period of a cancelled plan, and as a backup when our cloud AI does not answer, the AI assistant answers, searches and transcribes on EPAV's own model, on hardware that EPAV operates itself in the EU. This is processing by EPAV, not by a Sub-processor.

Cloudflare, Inc. runs the DNS of epavdesk.com and receives no personal data of your Visitors. If we start receiving email for Sites through Cloudflare, we will add it to this list with the notice in Section 7.3 of the DPA.

Services you connect yourself. When you connect one of these, it works for you under its own terms, and EPAV passes data to it only on your instruction: your own AI provider, your own mail server or mailbox (including sign-in through Google or Microsoft), Telegram, Meta (WhatsApp), Atlassian Confluence, Shopify, WooCommerce, Cal.com, your webhooks and the custom tools of your assistant. The browser push services that deliver notifications to your Agents (from Google, Mozilla or Apple, depending on the browser) receive them encrypted.

Our own customer relationship. creem (Armitage Labs OÜ, Estonia) sells your subscription to you as merchant of record, and we use other services for our own support and accounts. These process data about you as our customer, not data of your Visitors, and are described in our Privacy Policy.


Change log