Sub-processors
Document control
| Field | Value |
|---|---|
| Version | 1.0 (draft) |
| Effective date | To be set |
| Last revised | 22 September 2026 |
| Approved by | Pending |
| Contracting entity | Substrate Artificial Inteligence, S.A. |
The full version history is available in the Legal document changelog.
Draft
This is a working draft adapted from the Serenity Star Sub-processors list. It has not been reviewed by Legal and is not yet in force.
This page will be the up-to-date list of Sub-processors referred to in clause 6 of the Data Processing Agreement and in section 6 of the Privacy Policy. It follows the structure of the Serenity Star list.
1. Platform Sub-processors
Engaged for every Customer, whatever the access route.
| Sub-processor | Service provided | Categories of personal data | Region of processing | Basis for international transfer |
|---|---|---|---|---|
| Microsoft Ireland Operations Limited (Microsoft Azure) | Request handling for the API | Request metadata, technical and security logs | Spain (Azure Spain Central) | Not applicable (EEA) |
| Subgen AI Spain, S.L. | Operation of the GPU facility in Valencia where inference runs | Inputs and Outputs in memory for the duration of the request | Spain (Valencia) | Not applicable (EEA); intra-group agreement pending |
2. Sub-processors engaged by the Customer's access route
| Sub-processor | Service provided | Categories of personal data | Region of processing | Basis for international transfer |
|---|---|---|---|---|
| Subgen AI Spain, S.L. (Serenity Star) | Authentication, API key management and billing for Serenity Star account traffic | Account, contact and billing data | European Union (Azure France Central) | Not applicable (EEA) |
| OpenRouter, Inc. | Routing of requests sent through OpenRouter | Whatever the Customer sends to OpenRouter, under OpenRouter's own terms | United States | Governed by the Customer's agreement with OpenRouter |
3. Changes to this list
Outline of the section: 30 days of prior notice for new Platform Sub-processors; how to subscribe to notifications; objection right under clause 6.3 of the Data Processing Agreement.