DRAFT — requires review by Canadian privacy counsel before publication. Not in force.
Last updated: 1 November 2026 · Part of our Privacy Policy and the Customer Data Processing Addendum (DPA).
A sub-processor is a company we engage that may handle Customer Data or personal information for which Nysroc is responsible, to help us provide the Service. Each one is bound by a written contract requiring it to use the data only on our instructions, protect it at least as well as we do, notify us of incidents, and delete or return it at the end of the service.
Changes. We give customers at least 30 days' notice (by email to account owners and on this page) before adding or replacing a sub-processor that handles Customer Data. Customers may object under the DPA. [PROPOSED: subscribe to changes at privacy@nysroc.com.]
| Sub-processor | What it does for Nysroc | Data involved | Where data is processed | When it applies |
|---|---|---|---|---|
| OVHcloud — [CONFIRM contracting entity, e.g. OVH Hébergement Inc.] | Cloud infrastructure: servers, databases, object storage, backups, call-recording storage, write-once audit-log storage | All Customer Data and account data | Canada: Beauharnois, Quebec (two dedicated servers: primary and replica); Toronto, Ontario (encrypted off-site backups, kept 35 days) | Always |
| Hangzhou DeepSeek Artificial Intelligence Co., Ltd. (DeepSeek API) | Text generation for Nysroc AI (managed): assistant answers, drafts, summaries, website and ad copy, video scripts | The user's instruction, the records the AI reads for that request with the user's permissions, and the output | People's Republic of China | Only when a workspace uses Nysroc AI in managed mode. Not used when AI is off, in bring-your-own-key mode, or in workspaces set to Canada-only. Do not send health or other regulated data (Privacy Policy §8.6). [COUNSEL: no written data processing agreement with DeepSeek at the date of this draft; Quebec s. 17 transfer assessment and GDPR transfer mechanism outstanding — see open items.] |
| [DECISION PENDING] AI speech and image provider(s) | Speech-to-text (call summaries), text-to-speech (video narration), image generation (ad images). (Search embeddings run on Nysroc's own self-hosted model in Canada — no sub-processor [CONFIRM].) | Call audio or transcripts, narration scripts, image prompts | [TBD] | These functions stay off until the provider is chosen and listed here |
| [TBD] Telecommunications carrier (SIP trunk) | Connects Nysroc Phone to the public telephone network; phone numbers; 911 | Phone numbers, call metadata, call audio in transit, 911 civic address | [Canada — TBD] | Workspaces using Nysroc Phone |
| [DECISION PENDING] Transactional email delivery provider | Sends emails from the Service (sign-up, billing, notifications, and email a customer sends from its workspace) | Recipient address, sender, subject, message content | [Canada or United States — TBD] | Always |
| HeyGen (HeyGen Technology Inc.) [CONFIRM entity] | Avatar video generation | Script, chosen avatar and voice | United States | Only if Nysroc's own HeyGen key is offered to customers (not yet). When a customer uses its own HeyGen key, HeyGen is the customer's provider, not ours. |
| Sub-processor | What it does | Data involved | Where | When |
|---|---|---|---|---|
| Stripe (Stripe Payments Canada, Ltd. and affiliates) [CONFIRM entity] | Subscription billing for Nysroc: card collection on Stripe's page, trials, invoices, tax, customer billing portal | Billing contact, card details (held by Stripe only — Nysroc never sees full card numbers), invoices | United States and other countries where Stripe operates | Every account that subscribes or starts a trial |
| [TBD] Customer support tooling, if any external tool is adopted | — | — | — | Currently support runs on Nysroc's own help desk, hosted in Canada [CONFIRM] |
These companies receive data only because a customer chooses to connect its own account to Nysroc. They act under the customer's own agreement with them (as the customer's provider or as independent businesses), not as Nysroc's sub-processors. Disconnecting in Nysroc stops the exchange.
| Service | What Nysroc exchanges with it, at the customer's direction |
|---|---|
| Google (sign-in with Google) | Name, email and account ID to sign you in (only if you choose Google sign-in) |
| Google Ads, Meta (Facebook, Instagram), Microsoft Advertising | Campaigns, budgets, ads, spend; hashed conversions server-to-server, only for visitors who accepted advertising measurement |
| Square, Clover (and planned Lightspeed Retail, Shopify POS, Moneris) | Sales, refunds, items, stock, fees |
| The customer's own Stripe account | Payments, fees, refunds, payouts into the customer's books |
| HeyGen with the customer's own key | Avatar video scripts and settings |
| AI providers in bring-your-own-key mode | Prompts and records the AI reads, sent to the provider the customer chose |
| Google Business Profile, Canada Post, Purolator (planned) | Reviews, business details, shipping labels and tracking |
| Nysroc Automations connections to other apps | Whatever data the customer's automation is built to send |
Domain registration and DNS for nysroc.com, the public certificate authority that issues free TLS certificates for customer domains (receives domain names only), and professional advisers under confidentiality. [OPEN ITEM: the nysroc.com marketing page currently fetches its typeface from Google Fonts, which receives visitors' IP addresses; to be self-hosted before launch.]