Sub-Processors
The third parties we rely on to deliver the Service, what they do, and where your data goes.
FunctionalAI engages a limited number of trusted third-party companies ("sub-processors") to help us provide, secure, and improve the Service. This page is maintained in accordance with our Terms and Conditions, our Privacy Policy, and the Data Processing Addendum incorporated therein, and is provided to comply with our obligations under GDPR Article 28 and equivalent laws.
Each sub-processor is bound by written terms imposing data-protection obligations substantially similar to those we accept with you. Where personal data of EEA, UK, or Swiss data subjects is transferred outside those territories, we rely on the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, the Swiss FDPIC adaptations, and/or EU–U.S. Data Privacy Framework certifications as applicable.
Current Sub-Processors
| Sub-Processor | Purpose | Data Categories | Location |
|---|---|---|---|
| OpenAI, L.L.C. | Large language model inference (chatbot responses, embeddings, AI-driven features) and abuse monitoring. Engaged under OpenAI’s API terms which prohibit training on customer inputs/outputs by default. | Prompts, conversation content, knowledge-base content, files submitted to AI features. | United States (with EU data residency where offered by the API). |
| Hetzner Online GmbH | Primary cloud hosting and compute: application servers, PostgreSQL database, Redis, and persistent storage volumes for the Service. | All Service data at rest and in transit, including account data, knowledge bases, conversation logs, and operational logs. | European Union — Falkenstein, Germany (fsn1). |
| Amazon Web Services EMEA SARL ("AWS") | Object storage (Amazon S3) for user-uploaded files, avatars, and conversation-export archives. | Files uploaded to knowledge bases, avatars, exported conversation archives. | European Union — Frankfurt (eu-central-1). |
| Lemon Squeezy (LMSQUEEZY, LLC — a Stripe company) | Merchant-of-record payment processing, invoicing, sales-tax handling, and subscription management for customers who subscribe outside the Shopify ecosystem. Lemon Squeezy was acquired by Stripe in 2024 and continues to operate as a separate brand. | Billing name, billing email, billing address, payment method details (collected and stored by Lemon Squeezy directly), transaction history. | United States. |
| Mailjet (Mailjet SAS, a Sinch company) | Transactional email delivery (account verification, password reset, billing receipts, system notifications). | Recipient email address, sender identifiers, email subject and body, delivery and bounce metadata. | European Union — France. |
| Meta Platforms, Inc. (Messenger and Instagram APIs) | Delivery and receipt of messages on Meta channels you have explicitly connected to your account. WhatsApp Business is not currently offered. | Messages, message metadata, sender/recipient identifiers, and any attachments transmitted through the connected channel. | United States and EU (per Meta data-transfer practices). |
| Google LLC (Gmail API) | Reading, drafting, and sending email on Google accounts you have explicitly connected to your account. | Email content, email headers, attachments, and account identifiers from connected Gmail accounts. | United States and global Google infrastructure. |
| Shopify Inc. | Store, product, customer, and order data integration for merchants who have installed the FunctionalAI Shopify app. | Store metadata, product catalogue, order data, and customer data made available through the Shopify Admin API. | Canada, United States, and EU per Shopify data-residency practices. |
| PostHog Inc. | Product analytics and session replay for the marketing site — usage patterns, feature adoption, and session insights used to improve the product. Analytics is opt-in in the EEA, UK and Switzerland and on by default with an opt-out elsewhere; session replay is off everywhere until the visitor switches it on, with inputs masked by default. Global Privacy Control turns both off in every region. | Account identifier (where available), IP address, browser/device information, pages viewed, feature interactions, and session metadata. | United States (PostHog US Cloud). |
| Google Analytics (Google LLC / Google Ireland Ltd.) | IP-anonymized aggregated website analytics for the FunctionalAI marketing site. Opt-in in the EEA, UK and Switzerland; on by default with an opt-out elsewhere. Global Privacy Control turns it off in every region. | IP address (truncated), browser type, device type, pages viewed, referring URL. | United States (with Google Ireland Ltd. as EU contracting entity). |
Channels and Integrations You Activate Yourself
Several of the sub-processors above (including Meta Platforms, Google, and Shopify) only receive your data if you explicitly connect the corresponding integration in the application. If you do not connect a channel, we do not transmit data to that provider on your behalf. You may disconnect any integration at any time from your account settings; once disconnected, we will stop transmitting new data to that provider.
The same applies to Slack, Discord, and Telegram. If you connect Slack or set up a Discord or Telegram alert, we send conversation data to the workspace, server, or chat you choose. Those providers are not on our list because they process the data under your own agreement with them, not ours. See the Privacy Policy, section 1, for what each one receives.
Notification of Changes
We will provide at least thirty (30) days' notice before engaging a new sub-processor that processes personal data, or before replacing an existing one. Notice will be given by updating this page and (where you have subscribed to such notifications) by email to the address associated with your account. To subscribe to email notifications, send a request to privacy@functional-ai.com with the subject line "Subscribe: Sub-Processor Updates."
Right to Object
If you reasonably object to a new sub-processor on documented data-protection grounds, please contact us at privacy@functional-ai.com within 30 days of the notice. We will work with you in good faith to find a resolution. If no resolution can be reached, you may terminate the affected portion of the Service for convenience and receive a pro-rata refund of any prepaid, unused fees, as set out in our Terms.
Internal Affiliates
In addition to the third-party sub-processors listed above, FunctionalAI may share data with its own personnel and contractors who are bound by written confidentiality and data-protection obligations and who require access to provide, support, or secure the Service.
Contact
If you have any questions about this Sub-Processors page, our processing activities, or your rights, please contact us:
FunctionalAI Privacy Team
Privacy / Sub-Processor Requests:privacy@functional-ai.com
Legal Matters:legal@functional-ai.com