Sub-processor List
1. About This List
1.1 Who this list is for. CelesteOS LLC ("Company") provides the CelesteOS service (the "Service") to business customers ("Customers"). When Company processes personal data contained in a Customer's data, it does so as the Customer's processor or service provider. A "Sub-processor" is a third party that Company engages to process that personal data. Third-party AI model providers used by the Service are Sub-processors.
1.2 Two parts. This list has two parts:
- Part A (public) describes Sub-processors by role and location.
- Part B (named) identifies each Sub-processor. It forms Annex III of the Data Processing Addendum and is provided to Customers under that Addendum, and to prospective customers under a non-disclosure agreement.
1.3 Where data is stored. The Service's primary hosting (database, authentication, file storage and encrypted backups) is in Germany. Data is also processed in the United States and through global networks, including for the edge network through which all App traffic passes, the session-security cache and the AI features. Company is a US entity.
2. Part A — Sub-processors by Role (Public)
| Role | Location | Personal data involved |
|---|---|---|
| Primary hosting, database, authentication, file storage, encrypted backups | Germany (EU) | All Customer data |
| Web application hosting and edge network (all App traffic is routed through it) | United States / global edge | All App traffic in transit |
| DNS and TLS-terminating network proxy for API and sign-in services | Global | API and sign-in traffic in transit; IP addresses |
| Session-security cache (sign-in lockouts, session revocation, short-lived caches) | United States | Token identifiers, counters, short-lived cached data |
| AI model providers (search and answers, document classification and extraction, text recognition, search ranking) | United States (one provider's processing region is under vendor confirmation) | Record and document text and search context. Names are not removed before processing |
| Text recognition (OCR) for scanned documents | United States / global | Page images, processed in memory and not stored by the provider |
| Sign-in and transactional email: single sign-on with a work account, sign-in verification, and password-reset, verification-code and account-notice emails sent from an email account we control | Global | Identity details (name, email address, account identifiers); content of transactional emails |
| Error monitoring | United States | Error events and logs, which may include vessel identifiers; personal data is scrubbed before events are sent |
| Push-notification delivery (browser and device makers' push services) | Global | Notification title and text |
| Trusted timestamping for sealed records | Germany / United States | Cryptographic hash values only (timestamp requests contain only a hash) |
| Internal alerting | United States | Alert titles; no Customer data intended |
| Source-code hosting and build pipeline | United States | No Customer data |
Collective. The Collective is hosted with the primary hosting provider in Germany (Nuremberg), and no additional Sub-processor is used for it. The Collective site shows content collected from public third-party sources ("Public-Source Content"), which is not Customer data and is processed by Company with its own models on its own infrastructure. Once fleet-contributed insights are published, participating Customers will also see there de-identified insights built from the contributions of Customers that have opted in. Authorized Users sign in to the Collective site with their account credentials through the same authentication service as the Service. Contribution processing for Customers that opt in uses the same hosting.
Recipients that are not Sub-processors.
- Company does not use a third-party payment processor. Invoices are paid by bank transfer, and bank details are handled by Company's bank.
- Website analytics and advertising tools are used only on Company's marketing website, not in the Service. Company is the controller for that data; see the Privacy Policy and Cookie Notice.
3. Changes to Sub-processors
3.1 Advance notice. Company will give at least 30 days' notice before a new Sub-processor, or a material change in an existing Sub-processor's role or processing location, begins processing Customer personal data. Each notice states the Sub-processor's name, role, location and the data concerned. Company gives notice by:
(a) updating this list and its "Last updated" date;
(b) emailing each Customer's designated privacy contact; and
(c) emailing everyone subscribed under Section 4.
3.2 Objections. A Customer may object on reasonable data-protection grounds within the notice period by writing to contact@celeste7.ai. If the objection is not resolved within 30 days, the Customer may terminate the affected service and receive a refund of prepaid fees for the unused period, as set out in Section 8.5 of the Data Processing Addendum.
3.3 Security incidents at a Sub-processor. If a security incident at a Sub-processor affects Customer personal data, Company notifies affected Customers without undue delay, with a target of 48 hours after Company confirms the incident (Data Processing Addendum, Section 7.1).
3.4 Emergency replacement. If Company must replace a Sub-processor urgently, for example because of a security failure or the Sub-processor's withdrawal of service, Company may do so on shorter notice. It will notify Customers as soon as practicable, and the objection rights above apply from that notice (Data Processing Addendum, Section 8.6).
3.5 Change log.
| Date | Change | Notice sent |
|---|---|---|
| October 15, 2026 | Initial list for CelesteOS LLC | n/a |
4. Subscribe for Updates
To receive notices of Sub-processor changes, email contact@celeste7.ai with the subject "Subscribe — Sub-processor updates", giving your name, organization and email address. Customers' designated privacy contacts are subscribed automatically. We use the subscription list only to send these notices.
Version 1.0 — last updated October 15, 2026.
Structure informed by the Data Processing Addendum (Global) template prepared and made publicly available by General Legal, PC ("General Legal") under CC0. General Legal has not reviewed, and takes no position on, this document.