General Terms and Conditions

The current version of the Warren BV General Terms & Conditions can be found here:

Warren BV - General Terms & Conditions - 2 March 2026.pdf

Data Processing Agreement

The current version of the standard Data Processing Agreement can be found here:

Warren BV - Data Processing Agreement - 2026-08-24.docx.pdf

List of subprocessors

The following subprocessors are in use at Warren BV. Last updated: 24 August 2026.

Warren notifies customers of material changes to this list in line with their Data Processing Agreement.

Name Sub-processor Category Nature of the processing Data residency
Amazon Web Services EMEA SARL Cloud Infrastructure Cloud infrastructure services EU - Germany (eu-central-1, primary compute) and Ireland (eu-west-1, backup storage)
Neon LLC Cloud Infrastructure (Database) Cloud infrastructure services (database) EU
OpenAI OpCo, LLC
Decommissioning planned by Aug 31, 2026 AI Services AI model inference and API services United States (SCCs in place)
Anthropic PBC AI Services AI model inference and API services (Claude models accessed via AWS Bedrock) EU
Auth0 (Okta) Authentication & Identity Authentication and identity management services; processes email addresses, login events, and session tokens for all Warren users EU
Customer.io Communication Email communication and marketing automation services; processes email addresses and metadata for HR Admin contacts and transactional communications EU
Cloudflare, Inc. Network Security & CDN Network security, content delivery, and DDoS protection services; processes all inbound/outbound web traffic, IP addresses, and request metadata EU
Sentry (Functional Software, Inc.) Monitoring & Observability Error monitoring and application performance services; processes error traces and stack traces which may contain request payloads, user identifiers, ip addresses, and session data EU
Langfuse GmbH
Decommissioning planned by Sept 30, 2026 AI Observability AI observability and prompt logging services; processes AI prompt and response logs including member-facing AI conversations which may contain personal financial data EU
GitHub, Inc. (Microsoft) Development & CI/CD Source code management and CI/CD pipeline services United States (SCCs in place)
Fireflies.ai, Inc. Communication Meeting recording, transcription, and note-taking for expert/advisory meetings; processes audio recordings, transcripts, and meeting metadata which may contain personal data discussed in meetings United States (SCCs in place)
Powens SA Open Banking / Account Aggregation Bank-account aggregation and transaction retrieval for the bank-connection feature; processes bank account details and transaction data EU
Mixpanel, Inc. Product Analytics Product-usage analytics; processes pseudonymised usage and event data (aggregated, short retention) EU
HubSpot, Inc. CRM & Sales Customer relationship management; processes business-contact data for prospects and HR-admin contacts (no member financial data) EU
Reasoning Engine B.V. (LangWatch) AI Observability LLM tracing and observability; processes AI prompt and response logs which may include member-facing AI conversations containing personal financial data EU
Calendly LLC Scheduling & Communication Meeting scheduling and coordination United States (EU-US DPF + SCCs)
650 Industries, Inc. (Expo) Mobile Platform Mobile app build and update distribution contains IP addresses, geolocation and some device metadata. United States (SCCs in place)
Google Ireland Limited (Google Workspace) Business Productivity Business productivity and collaboration tools EU
Intercom R&D Unlimited Company (Fin) Customer Support / AI Customer messaging and support EU
Linear Orbit, Inc. Development & CI/CD Engineering issue tracking and project management EU
Notion Labs, Inc. Business Productivity Internal knowledge base and documentation United States (SCCs + UK Addendum)
Oneflow AB Contract Management Contract signing and lifecycle management EU
Zapier, Inc. Workflow Automation Expert appointment orchestration. United States (EU-US DPF + SCCs)
Ringo SAS (Modjo) CRM & Sales Sales call recording and analysis EU