CLEARSKY Sub-processors

79th Unit Limited (ICO 00013660448, CRN 17133814). Last updated 14 June 2026.

79th Unit Limited uses the following sub-processors to deliver CLEARSKY. Each processes personal data only as needed for its stated function. We give Customers prior notice of additions or replacements, with an opportunity to object on reasonable data-protection grounds, under clause 8 of our Data Processing Agreement.

Sub-processorFunctionData processedLocation
OVHcloud (OVH SAS)Primary hosting, object storage, backup vaultAll platform dataRoubaix & SBG, France (EU)
Hetzner Online GmbHSecondary off-site backupEncrypted backups onlyGermany (EU)
Stripe Payments EuropeSubscription billing and card processingBilling identity; card data held by Stripe, not by usEU / global per Stripe DPA
Postmark (ActiveCampaign)Transactional email (dossier delivery, notifications)Recipient email and a secure link (no dossier content; delivery is link-only)US (under transfer safeguards)
AnthropicAI: CHAPEL brief generation and INVESTIGATE agentCase text passed for analysisUS (under transfer safeguards)
CLEARSKY's AI also runs on a self-hosted local model tier (Ollama / Qwen 2.5) on CLEARSKY infrastructure; no personal data leaves our systems on that path, so it is not a sub-processor. The optional OpenAI fallback tier is disabled in production (no case data is sent to OpenAI), so OpenAI is not a current sub-processor.

International transfers

Platform data is hosted in the EU (OVHcloud) with encrypted backups in the EU (Hetzner). Where a US sub-processor is used, transfers are made under UK GDPR Chapter V safeguards: Postmark / ActiveCampaign under the UK Extension to the EU-US Data Privacy Framework (the UK-US data bridge); Anthropic under EU Standard Contractual Clauses with the UK International Data Transfer Addendum. Full transfer documentation is available to Customers on request.

Change process

Additions or replacements are notified to Customers per clause 8 of the Data Processing Agreement, with an opportunity to object on reasonable data-protection grounds.