Sub-Processor List
Engramia — Reusable Execution Memory for AI Agents
Last updated: 2026-04-07
Effective date: 2026-04-07
1. Introduction
Engramia (operated by Marek Čermák, Czech Republic) uses a limited number of third-party sub-processors to deliver the Engramia Cloud Service. A sub-processor is any third party that processes personal data on our behalf under a data processing agreement.
This page lists all current sub-processors, the countries in which they operate, the purpose for which they are engaged, and the legal mechanism used to transfer personal data outside the European Economic Area (EEA) where applicable.
This list is maintained in accordance with Article 28(2) of the GDPR and the Data Processing Agreement available at https://engramia.dev/legal/dpa-template.
2. Current Sub-Processors
| Name | Country | Purpose | Data Processed | Transfer Mechanism |
|---|---|---|---|---|
| Hetzner Online GmbH | Germany (EU) | Infrastructure hosting — compute, storage, and networking for all Engramia services | All data stored and processed by the Engramia API (memory records, embeddings, metadata, logs) | Not applicable — data remains within the EU |
| Stripe, Inc. | USA / Ireland (EU entity for EEA customers) | Payment processing, billing, subscription management, and tax calculation | Customer billing details (name, email, payment instrument, billing address, tax ID) | EU–US Data Privacy Framework; Stripe DPA |
| OpenAI, Inc. | USA | LLM inference used for memory evaluation, summarisation, and embedding generation | Memory content submitted for evaluation or embedding (may contain personal data if included in agent memory) | Standard Contractual Clauses (SCCs) — EU Commission Decision 2021/914 |
| Anthropic, PBC | USA | Alternative LLM inference for memory evaluation (used when OpenAI is unavailable or for specific model configurations) | Memory content submitted for evaluation (may contain personal data if included in agent memory) | Standard Contractual Clauses (SCCs) — EU Commission Decision 2021/914 |
3. Notification of Changes
We will notify customers of any intended addition or replacement of sub-processors at least 30 days in advance by:
- Updating this page (the "Last updated" date will change), and
- Sending an email notification to the account owner's registered email address.
Customers who object to a new sub-processor may terminate their subscription in accordance with the Data Processing Agreement before the change takes effect.
4. Sub-Processor Data Processing Agreements
Each sub-processor is bound by a data processing agreement that requires it to:
- Process personal data only on documented instructions from Engramia;
- Implement appropriate technical and organisational security measures;
- Assist Engramia in fulfilling data subject rights obligations; and
- Delete or return personal data upon termination of the engagement.
5. Contact
For questions about this sub-processor list or our data processing practices:
Marek Čermák Email: legal@engramia.dev Czech Republic