LegalSub-processor List
Sub-processor List
1. Purpose of this list
Being Optimal engages the following sub-processors to operate the Services (pregnancy-nutrition planner, account surfaces, AI assistant, community forum where enabled, help/content delivery, and related infrastructure).
This document is the sole public place that names vendors. Elsewhere in the suite, documents stay vendor-agnostic so providers can be substituted without re-drafting; transparency for data subjects and regulators is preserved here.
2. Active sub-processors
| Provider role | Sub-processor (current vendor) | Purpose | Data categories (typical) | Primary region(s) |
|---|---|---|---|---|
| Authentication Provider | Clerk, Inc. | Sign-up, sign-in, sessions, account identity; lifecycle webhooks | Email, name/profile metadata, authentication identifiers, session tokens | United States (provider-dependent) |
| Webhook Transport | Svix (via Clerk) | Delivery of Authentication Provider webhooks (e.g., user.created, user.deleted) used for provisioning and deprovision |
Webhook payloads; user lifecycle events | United States (provider-dependent) |
| Database Provider | Supabase, Inc. | Primary application database; row-level security (RLS) with user JWT | Health/profile data, environments, meals, journal, templates/combos, AI conversation content, preferences, entitlements metadata | Primarily United States |
| Hosting Provider | Vercel, Inc. | Hosting of the Next.js application (public site + signed-in shell); may include Vercel Web Analytics (page-view / performance telemetry) when the app enables it | HTTP request metadata, session cookies, application logs; optional analytics events (path, referrer, device class — not meal/health content) | United States / global edge |
| CDN / Edge Network Provider | Cloudflare, Inc. | DNS, CDN, edge/gateway for privileged backend access | IP addresses, request headers, geo signals, proxied traffic | Global |
| Cloud Infrastructure Provider | Google Cloud (Cloud Run, Cloud Storage / GCS) | Privileged backend APIs (provisioning, deprovision, heavy compute), object storage (e.g., community uploads where used) | Backend-processed account and health-related data; stored objects | Primarily United States |
| Email Delivery Provider | Amazon Web Services, Inc. (Amazon SES) | Transactional email delivery | Recipient email address, message subject/body, delivery metadata | Configurable (operator-selected region) |
| AI Model Providers | Anthropic, xAI, OpenAI | Generative AI assistant (“Borg”); prompts may include conversation text and health-context snippets | Conversation content; optional Special Category Health Data snippets; model metadata | Primarily United States |
| Community Platform Provider | Discourse | Hosted community forum with SSO | Identity used for SSO, forum posts, uploads, forum profile | Configurable (forum host region) |
| Email Design Provider | Stripo | Operator-side email template design tooling | Template assets; limited operational metadata (not end-user meal/health logs) | Operator / provider regions |
| Reverse-Geocoding Provider | BigDataCloud | Convert device raw latitude/longitude to country/region labels | Raw lat/lng transmitted transiently; Being Optimal does not store GPS coordinates — only country/region (or similar place labels) may be persisted | Global (API) |
| Billing Provider | Clearway (placeholder — not yet live) | Subscription billing / merchant-of-record when paid plans go live | Billing email, subscription status, payment references — Being Optimal does not store full payment card numbers | TBD when live |
| Push Delivery | VAPID / Web Push (browser push; no third-party push SaaS) | Browser push notifications for opted-in devices | Push subscription endpoint, cryptographic keys, notification payloads as configured | Device / browser; endpoint stored in our database |
3. Data sources that are not personal-data processors
| Role | Source | Note |
|---|---|---|
| Nutrient Data Source | USDA FoodData Central | Public nutrient composition catalog used to power food data and scores. This is a data source, not a Sub-processor of Personal Data. No user health profiles are sent to USDA as part of catalog use. |
4. Explicitly absent (not used today)
Being Optimal does not currently engage the following categories of third parties for the Services:
| Category | Status |
|---|---|
| Third-party marketing analytics / ad pixels / session replay | Absent — no marketing analytics SaaS, ad networks, or session replay. Note: Hosting Provider page telemetry (Vercel Web Analytics) may be present as part of hosting; first-party consent-gated catalog analytics is separate |
| Third-party error-tracking / crash-reporting SaaS | Absent |
| Advertising networks / ad pixels | Absent |
| Session-replay / heatmapping SaaS | Absent |
| CAPTCHA / bot-mitigation SaaS | Absent |
| Third-party push notification SaaS | Absent — browser VAPID/Web Push only |
If any of these are added later, they will be named in this list and users will be notified as required by the Privacy Policy and Versioning And Acceptance.
5. How data flows (summary)
- You authenticate via the Authentication Provider (Clerk). Lifecycle events may be delivered via Svix webhooks to our backend.
- Application data (meals, journal, health profile, AI conversations, etc.) is stored with the Database Provider under RLS keyed to your authenticated identity.
- The web app is served by the Hosting Provider; edge/DNS may involve the CDN / Edge Network Provider.
- Privileged operations (account provisioning/deprovision, heavy compute) run on Cloud Infrastructure Provider (Google Cloud Run); service-role access is confined to that privileged backend — not to the Next.js frontend host.
- AI assistant may send prompts (including health-context snippets) to AI Model Providers; conversation content may also be persisted in our database.
- Location: if you use reverse-geocoding features, raw coordinates are sent to BigDataCloud; we store place labels (e.g., country/region), not GPS.
- Community: forum identity/posts are handled by Discourse (SSO identity only for product health fields that are gated off).
- Email / push: transactional mail via Amazon SES; optional browser push via VAPID.
6. International transfers
Infrastructure and AI providers are primarily United States-based, with global edge delivery. Where Personal Data (including Special Category Health Data) is transferred internationally, we rely on appropriate safeguards (e.g., Standard Contractual Clauses, provider DPAs, and other mechanisms as required). Details of transfer posture are summarized in the Privacy Policy regional annexes and Records Of Processing.
7. Change notification (changeFeed: true)
| Event | Our practice |
|---|---|
| Material new sub-processor | Update this list; provide notice per Privacy Policy; objection rights where applicable |
| Material change to processing purpose or transfer risk | Same as above; may trigger re-acceptance per Versioning And Acceptance |
| Immaterial vendor rename / contact update | Update this list; notice only |
How to stay informed: monitor this page and the suite README changelog. Contact [email protected] to ask about change notifications or to raise an objection where the law provides one.
8. Sub-processor inquiries
| Topic | Contact |
|---|---|
| Sub-processor list, DPAs, transfer questions | [email protected] |
| Security of our use of sub-processors | [email protected] |
| Legal process directed at a vendor | May need to contact that vendor; we can help scope — [email protected] |
Related documents
- Privacy Policy
- Data Subject Request Procedure
- Records Of Processing
- Security And Compliance
- OPERATOR VARIABLES
- Legal Manifest