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Legal Documentation

Data Processing Addendum & Sub-processor List

Effective May 24, 2026Third Eye Cyborg, LLCLast updated October 7, 2026

Designed to support GDPR Article 28, the UK GDPR, and equivalent obligations under US state privacy laws. The Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914) are incorporated by reference for transfers from the EEA, and the UK Addendum for transfers from the UK.
On this page
  • 1. Scope
  • 2. Roles
  • 3. Customer instructions
  • 4. Confidentiality and security
  • 5. Sub-processors
  • 6. International transfers
  • 6a. EU representative (GDPR Art. 27)
  • 7. Data subject requests
  • 8. Audits
  • 9. Personal data breaches
  • 10. Return / deletion
  • 11. How to execute

1. Scope#

When Ascended Social processes personal information on behalf of a business customer (e.g., team or organisation accounts) we act as a processor / service provider. This Data Processing Addendum ("DPA") sets out the terms governing such processing and supplements the underlying customer agreement.

2. Roles#

For consumer accounts, Third Eye Cyborg, LLC is the controller of personal information. For business / team accounts, the customer is the controller and Third Eye Cyborg, LLC is the processor / service provider.

3. Customer instructions#

We process personal information only on the documented instructions of the customer, including with regard to transfers, unless required to do otherwise by law (in which case we will notify the customer where legally permitted).

4. Confidentiality and security#

Personnel authorised to process personal information are bound by confidentiality obligations. We maintain appropriate technical and organisational measures, including encryption in transit and at rest, role-based access controls, audit logging, and a documented incident response programme.

5. Sub-processors#

We engage the following categories of sub-processors. The current list is below. We will provide prior notice of new sub-processors and give the customer an opportunity to object on reasonable grounds.

  • Cloud hosting: Cloudflare (US/global edge, including Workers and Durable Objects), Replit (US).
  • Database & storage: Neon (managed Postgres), Cloudflare R2 (object storage).
  • Authentication: Replit Auth / Clerk (where configured).
  • Payments & creator payouts: Polar.sh (web energy packs; web subscriptions while Stripe Managed Payments is off), Stripe Managed Payments / Link (web subscriptions when that checkout is live), Apple App Store and Google Play (mobile subscriptions and energy packs, synced by RevenueCat). The Creator Partner Program stays separate and is not live.
  • Mobile distribution: Expo / EAS, Apple App Store, Google Play.
  • Email & transactional messaging: Courier, Resend (where configured).
  • AI providers: OpenAI (including advisory public-post intention fit checks), Cloudflare Workers AI, Meshy (3D avatar generation), and other vendors listed in the AI & Generative Content Disclosure.
  • Analytics & error monitoring: PostHog (privacy-aware product analytics), Sentry (error monitoring).
  • Customer support / tooling: Linear / ClickUp (internal), GitHub (source control), Flashboard (getflashboard.com — internal CMS / admin dashboard with access to the production database; authorized admin access only, link leads to the Flashboard login page).
  • Social media management: Zernio (publishing to and managing our official social channels, and handling messages sent to those channels).
  • Compliance: TermsHub (terms hosting). We do not list a child-safety reporting authority as a service provider or represent that an authority-reporting workflow is operational on this page.

A current dated sub-processor list is available on request to [email protected].

6. International transfers#

Where personal information is transferred from the EEA, the UK, or Switzerland to a third country without an adequacy decision, the transfer is subject to the Standard Contractual Clauses (and, for UK transfers, the UK International Data Transfer Addendum or UK IDTA), which are incorporated by reference. Supplementary measures (encryption, access controls, transparency reporting) accompany those clauses.

6a. EU representative (GDPR Art. 27)#

Our representative in the Union for the purposes of Article 27 GDPR is:

Prighter

EU and EEA data subjects, supervisory authorities, and customers may address the representative on any matter relating to the processing of their personal information by Third Eye Cyborg, LLC.

7. Data subject requests#

We provide reasonable assistance to the customer in responding to requests from data subjects to exercise their rights of access, rectification, erasure, restriction, portability, and objection.

8. Audits#

On reasonable notice, and subject to confidentiality, we will provide the customer with information necessary to demonstrate compliance with this DPA, including third-party attestations where available.

9. Personal data breaches#

We notify the customer without undue delay after becoming aware of a personal data breach affecting customer personal information, with information sufficient to allow the customer to meet its own notification obligations.

10. Return / deletion#

On termination of the underlying agreement, at the customer's choice we will delete or return personal information processed on its behalf, subject to applicable retention obligations.

11. How to execute#

To execute this DPA for a business / team account, email [email protected] with the customer name, signing authority, and the contracting entity. A counter-signed copy will be returned for your records.

Questions: [email protected]

On this page

  • 1. Scope
  • 2. Roles
  • 3. Customer instructions
  • 4. Confidentiality and security
  • 5. Sub-processors
  • 6. International transfers
  • 6a. EU representative (GDPR Art. 27)
  • 7. Data subject requests
  • 8. Audits
  • 9. Personal data breaches
  • 10. Return / deletion
  • 11. How to execute