Attunr subprocessors and outside services
Draft. Written 2026-10-17 and revised the same day after the legal review in lawyer-review.md (points 8, 16j and 16l). Not in force and not published.
BUILD: marks something that depends on a planned build step.
Built from the code on main (commit b7e3128): every outside address in
server/,src/lib/andextension/, and the 97 settings indocs/accounts-walls.json. Each company, country and data agreement was checked on that company's own legal pages on 2026-10-17.
We tell customers at least 30 days before adding or replacing anyone in parts A and B, as the data processing agreement says.
How to read this list
- Part A, always used. These run Attunr. Every account's data passes through some of them.
- Part B, included features. Attunr pays for these through its own accounts, and they're included in every plan up to its monthly limits. They get only what the feature needs.
- Part C, services you connect. You pick them, you hold the account and their terms apply between you and them. They are not our subprocessors, but data goes to them when you connect them, so they are listed here.
- Part D, public sources. Public websites and services Attunr reads. Attunr sends them search words, city names or public web addresses, not your records.
- Part E, your browser. Services your own browser uses while you work in Attunr.
Part A: always used
| Service | What Attunr uses it for | What data goes there | Company and where |
|---|---|---|---|
| Fly.io | Hosting: the web servers, the worker that runs site checks and imports, and storage disks | Everything in Attunr | Fly.io, Inc., US. Attunr runs in its Toronto region. Fly.io's backup storage provider (Amazon Web Services) is in the US. BUILD: sign Fly.io's data agreement (fly.io/documents) before launch. |
| Fly Managed Postgres | The database: every account's records and history | Everything in Attunr | Fly.io, Inc., US. The database runs in Toronto. Fly.io keeps 10 days of backups, which may be stored in the US until Fly.io confirms otherwise. |
| Object storage. BUILD: Stage 3.2 picks it. | Voice notes, screenshots, client hub files, nightly account copies | Those files | Not picked yet. It must offer a Canadian region. |
| Cloudflare Turnstile | Bot check on the sign-in page | Internet address and browser signals of the person signing in. No workspace content. | Cloudflare, Inc., US. Runs worldwide. Cloudflare also uses these signals to improve its bot detection, under its own privacy terms. No cookie is set. |
| Stripe | Billing for Attunr plans and the tax on them, through Figured Media's Stripe account | Owner's name and email, business name, billing address, tax number if given, plan, seats, invoices. Card details go straight to Stripe. | Stripe Payments Canada, Ltd., Canada, with Stripe, LLC (US) for personal information |
| Email for sign-up, invites, password resets and billing notices. BUILD: not picked yet. | Messages from Attunr itself, not your sales email | Recipient's name and email, the message | Not picked. If it's Resend (already in the code for client hub newsletters): Plus Five Five, Inc., US, which stores everything in the US. |
Part B: included features
| Service | What Attunr uses it for | What data goes there | Company and where |
|---|---|---|---|
| Google Gemini API (paid) | AI writing: call wrap-ups, email drafts, meeting prep briefs, voice notes, call practice, the marketing writer, report notes | The text each feature needs: call transcripts, a lead's company and notes, earlier touches, pitch-page findings, the question asked. Ask Attunr sends only the question and field names. | Google Cloud Canada Corporation, Canada (Attunr's account is billed in Canada). Google may process it outside Canada. Google doesn't train on it and keeps it 55 days for abuse checks. |
| Anthropic | The same AI writing, when Gemini fails | The same text | Anthropic, PBC, US. Doesn't train on it and deletes it within 30 days as a rule. |
| fal.ai | Transcripts (Whisper and Wizper), the practice voice (Kokoro), AI images | Audio of voice notes and recordings sent for transcripts, the text to speak, image prompts | Features & Labels, Inc., US. Doesn't train on it. Attunr asks it to keep no history of requests. |
| Brave Search API | Market scans and the searches on pitch pages | Search words: a trade and a city, such as "snow removal Ottawa" | Brave Software, Inc., US |
| DataForSEO | Google rank checks, keyword ideas and demand charts | Search words and a city | DataForSEO OÜ, Estonia |
| Google PageSpeed Insights API | Phone speed tests in site checks and audits | Public web addresses of business websites | Google LLC, US |
| A map address service. BUILD: not picked yet. | Placing business street addresses on a map for Doorstep day | Business street addresses. A sole trader's may be their home. | Not picked. It must be a paid service with a data agreement, or Attunr's own server. |
BUILD: until text AI moves off fal.ai's any-llm service before launch, the text goes from fal.ai to OpenRouter, Inc. (US), which passes it to Google, Anthropic or OpenAI (OpenAI OpCo, LLC, US). Those companies are fal.ai's subprocessors, so ours one step removed, and each receives the same text. None of them trains on it.
If Attunr later sells calling minutes itself, Telnyx moves from part C to part B.
Part C: services you connect
| Service | What it's for | What data goes there |
|---|---|---|
| Your mailbox provider (Gmail, Microsoft 365, your web host, any IMAP and SMTP mailbox) | Sending as you, syncing replies, the Mail page, booking invites | Every email you send through Attunr. Attunr reads mail to or from leads to log it, and shows your whole mailbox on the Mail page without storing it. Your mailbox password, stored encrypted. |
| Telnyx (Telnyx LLC, US) | Calling, inbound calls, voicemail | Phone numbers, call audio, recordings and call times. Recordings stay in your Telnyx account: Attunr plays them from there and asks Telnyx to delete them at the end of your retention setting. Telnyx stores them in the US unless you pick Germany or Australia, and keeps a recording a year if no one deletes it. It has no Canadian storage option today. |
| Hunter (Hunter Web Services, Inc., US) | Checking whether a guessed email address exists | Names, company domains and guessed addresses. Hunter keeps its check history 3 months. |
| Google: Search Console, Analytics, Business Profile, Google Ads, Data Manager | Agency reports, Google posts, ad reports and conversions | Report requests. For conversions: contact details hashed one way (SHA-256) and ad click identifiers. |
| Meta: Facebook Pages, Instagram, Threads, Conversions API, ad reports | Posting, social numbers, conversions | Posts and images. For conversions: contact details hashed one way and click identifiers. |
| LinkedIn, X, Pinterest, Bluesky, WordPress, Discord | Posting | Posts and images. X charges per post, at the customer's cost. |
| TikTok Events API | Conversions | Contact details hashed one way and click identifiers |
| Slack or Discord webhooks | Alerts and the digest | New leads, meetings, replies. Amounts only if the owner turns them on. |
| Your own outgoing webhooks (Zapier, Make, n8n or any HTTPS address) | Sending Attunr events to your other tools | New leads, stage moves, handoffs, meetings, proposals, client enquiries, as JSON |
| A calendar address you give (any secret iCal link) | Showing when you're busy | Attunr reads busy times |
| Twilio, CallRail | Call tracking for clients (agency mode) | Call times, caller numbers |
| Mailchimp, Klaviyo, Microsoft Clarity, Bing Webmaster Tools, Google Places | Client report numbers (agency mode) | Report requests. Mailchimp and Klaviyo return list numbers. |
| Cloudflare, Resend, Quo | Client hub site hosting, client newsletters, client call tracking (agency mode). BUILD: Stage 4. | Client site files; newsletter recipients and messages; call details |
Attunr uses its own Google, Meta and LinkedIn apps for these connections, separate from Figured Media's. Each customer signs in to its own account. BUILD: Google verification and Meta app review are outside waits (product plan, "Things to start early").
Part D: public sources Attunr reads
Attunr sends these only search words, city names or public web addresses.
| Source | What for |
|---|---|
| Business websites themselves | Site checks, pitch pages, enrichment, site watch |
| Google search, in your own browser | Only when you press Check Google on a lead and then the extension's button on that tab (terms, section 7.1) |
| Open-Meteo (OpenMeteo GmbH, Switzerland) | Weather forecasts and history for cities, on its paid commercial service, with its credit shown next to the charts. BUILD: the commercial key and the credit line, or season charts stay out of Attunr. |
| Domain registries (RDAP) and IANA | Domain renewal dates |
| Public job boards (Greenhouse, Lever, Ashby, Workable) and Wikidata | Company details for enrichment |
| Public social profiles | Follower and post counts for social stats and competitor watch (agency mode) |
| Bank of Canada | Exchange rates |
Attunr doesn't read public search result pages, autocomplete or Google Trends by software, and doesn't use OpenStreetMap's public address server or Check-Host. BUILD: the code does all of these today (Brave's, DuckDuckGo's and Bing's result pages, Google, Bing, DuckDuckGo and YouTube autocomplete, Google Trends, Nominatim, Check-Host). The Attunr build turns them off or replaces them.
Part E: your browser
| Service | What for | What data goes there |
|---|---|---|
| Your browser's speech service | The live transcript on the call screen, and live words while you record a voice note | Your microphone audio. In Chrome it goes to Google. Other browsers differ. The call screen says so the first time you turn live words on: "Live words use your browser's speech service. In Chrome, the audio goes to Google." BUILD: that note. |
| The Chrome Web Store and Mozilla Add-ons | Installing and updating the extension | No workspace data |
Not used in Attunr
These belong only to Figured Media's own Relay and never load in Attunr (product plan, "The guards"):
- Figured Media's Slack and Discord;
- the VisitSend plan control;
- Figured Media's Google Ads manager account, its own ad conversions and the Google Ads tag on its own pitch pages;
- the AI and search keys of Figured Media's own Relay. Attunr has its own, separate accounts with Google, Anthropic, fal.ai, Brave and DataForSEO.