Legal
Sub-processors
Last updated 1 September 2026
This page lists the sub-processors that Baseline Telemetry Advisory currently engages to deliver the website, the delivery workspace, and the advisory services. It is referenced by our Data Processing Agreement and our Privacy Policy.
Where an engagement is delivered in Mode B (direct in-platform execution inside the client's own tools, for example Jira, Linear, Vanta, Drata, or Secureframe), those tools are the client's own sub-processors, not ours, and the client's agreements with those providers govern them.
We give clients at least 30 days' notice of any change to this list. Clients may object to a change on reasonable grounds by writing to privacy@btadvisory.io.
Current sub-processors
Scroll the table sideways to see every column.
| Sub-processor | Purpose | Data categories | Region | Transfer mechanism |
|---|---|---|---|---|
| Lovable | Frontend hosting and application deployment for the Baseline Telemetry Advisory workspace. | Static assets, request metadata (IP, user agent) at edge, no primary personal data storage. | European Union | Intra-EEA. No transfer mechanism required. |
| Cloudflare | CDN, DNS, TLS termination, and bot mitigation. | Request metadata (IP, user agent), TLS session data, strictly-necessary cookies. | Global edge network; EU / UK edge nodes preferred. | SCCs 2021/914 module 3 where processing occurs outside the EEA/UK. |
| Lovable Cloud managed Postgres (on AWS eu-west-2, London) | Managed Postgres, authentication, storage, and realtime for workspace data. | All primary application and engagement data, authentication factors, audit trail. | United Kingdom (AWS eu-west-2). | UK adequacy decision (2021) for EEA-to-UK transfers. |
| Google (Gemini models, via our managed AI gateway) | AI text generation for optional workspace features when the client opts in. | Only the content the user submits to the AI feature at time of use. | United States (Google Cloud). | SCCs 2021/914 module 2 (controller-to-processor). |
| OpenAI (models via our managed AI gateway) | AI text generation for optional workspace features when the client opts in. | Only the content the user submits to the AI feature at time of use. | United States. | SCCs 2021/914 module 2 (controller-to-processor). |
| Anthropic (Claude / Claude Code) | AI-assisted software engineering, and Drift Watch: a scheduled internal audit that verifies the platform's own behaviour against the live database. Processed under a commercial Team agreement; inputs are not used to train Anthropic's models. | Source code and platform configuration. For Drift Watch specifically, a dedicated internal reference tenant only, a permanent fixture and never a real client engagement. No other tenant's data is queried. | United States. | SCCs 2021/914 module 2 (controller-to-processor). |
| Lovable Emails (managed sender) | Transactional email delivery: authentication mail, invites, booking confirmations, reminders, and operational notifications. Sent from notify.btadvisory.io. | Recipient email address, name where provided, and the transactional content of the message. | European Union. | Intra-EEA. No transfer mechanism required. |
| Functional Software, Inc. (Sentry) | Application error telemetry for the public site and the authenticated workspace alike, including a masked session replay of the moments leading up to a browser error. | Stack traces, breadcrumbs, browser and route metadata, and tagged server error events. Request bodies and authentication tokens are excluded at the SDK layer. Replay is captured only for sessions where an error occurred, never a healthy one, with all text and input values masked and all media blocked. | European Union (Sentry data storage region: EU). | Intra-EEA. No transfer mechanism required. |
Marketing and analytics (public website only)
The vendor below is used exclusively on the public marketing website and only when the visitor gives consent via the cookie banner. It is never invoked inside the authenticated delivery workspace and never receives engagement data. No advertising or marketing tags are deployed. See /cookies for cookie-level detail and controls.
Scroll the table sideways to see every column.
| Vendor | Purpose | Data categories | Region | Transfer mechanism |
|---|---|---|---|---|
| Google Ireland Ltd (Google Analytics 4, active) | Website analytics (page views, aggregate session data). IP anonymisation on, Google Signals off, Consent Mode v2 default-denied. | Pseudonymous identifiers (_ga cookie), truncated IP, user agent, referrer, page path. | Ireland (controller) with processing in United States. | SCCs 2021/914 and EU-US Data Privacy Framework where applicable. Activated on consent only. |
| PostHog Ireland Ltd (PostHog, active) | Website analytics on the public marketing pages only: page views, and three named events when a visitor requests the service brief or starts and confirms a booking. Autocapture, session recording, and feature flags are all switched off. | A pseudonymous device identifier, the page URL and path, and, for the three named events, the source and topic parameters already visible in that page's own URL, plus which day of the week a booked slot falls on. Nothing a visitor types into a form ever reaches PostHog. Traffic is relayed through a proxy on our own domain rather than calling posthog.com directly, but PostHog is still the only party receiving and processing it. | European Union (PostHog data storage region: EU). | Intra-EEA. No transfer mechanism required. Activated on consent only. |
Notes
- AI features are opt-in per engagement and process only content submitted to the feature. If they are not enabled, no data is transferred to the model providers listed above.
- Baseline Telemetry Advisory uses a managed business productivity suite for email, bookings, documents, and administration. This is separate from workspace-hosted engagement data. Delivery tooling AI is not a routine sub-processor route because client data and evidence are not intentionally submitted to it. Any change requires a data-protection review and a new sub-processor entry before processing begins.
- A managed transactional email provider sends authentication messages, invitations, booking confirmations, reminders, and operational notifications.
- Our internal engineering, code scanning, dependency scanning, and uptime monitoring tools are not listed here. They operate on Baseline Telemetry Advisory source code, platform configuration, and public health endpoints, and do not process client personal data or engagement content. Controls for those tools are described on /trust. Anthropic, above, is the one exception: Drift Watch reads our own dedicated reference tenant to verify the platform against the live database, never a client's tenant, which is why it is disclosed here rather than folded into that general note.
- Where a sub-processor operates a global edge network, we require EU / UK edge nodes wherever the provider supports region pinning.
Legal / last updated 1 September 2026