DPA ANNEX · ART. 28 (4) GDPR

Subprocessors.

Effective: 16 September 2026

In short: Normal operation needs three subprocessors, all based in Germany. The only addition is payment processing.

Always used

Hetzner Online GmbHGunzenhausen, GermanyHosting of the application, database, website and widgetFalkenstein/Vogtland, GermanyStrato AGBerlin, GermanyOffsite store for encrypted backups (HiDrive); delivery of the DPA documentsGermanyIONOS SE / IONOS Cloud GmbHMontabaur / Karlsruhe, GermanyAI models for chat replies and embeddings (only AI provider)Germany

For payments only

Stripe Payments Europe, Ltd.Dublin, IrelandPayment processing, invoicingEU; transfer to Stripe, Inc. in the US under Standard Contractual Clauses

This concerns the controller’s billing data only — no conversation content.

AI providers outside the EU

We do not use any. Chat replies and embeddings are computed exclusively by IONOS in Germany (see above). The integrations with Anthropic and OpenAI that the software knows technically are blocked and cannot be switched on from the admin interface. Should this change, the procedure below applies: notice at least 30 days in advance.

Not outsourced

Two kinds of processing deliberately run without a subprocessor because they are particularly sensitive:

Speech recognition. Voice messages are transcribed in our own container on our own server. The recording does not leave the machine.
Reading replies aloud. Happens in the visitor’s browser. Nothing is transmitted.

Changes and objection

New or replaced subprocessors are announced to controllers in text form at least 30 days in advance. Within that period the controller may object for good cause; if no agreement is reached, a special right of termination applies.

This page is the currently valid version of the list. Questions to dsb@silentchat.de.