AICtrlNet Sub-Processors
This page lists the third-party service providers Bodaty LLC engages to process personal data on behalf of its customers in connection with AICtrlNet™ and HitLai™. It constitutes Annex C of Bodaty's Data Processing Agreement and is incorporated by reference into the DPA, the Terms of Service, and the Privacy Policy.
Notice of changes — shorter window for AI sub-processors
Bodaty provides Customers with prior notice of any addition, replacement, or material expansion of a sub-processor that processes their personal data. The notice window depends on the sub-processor category:
AI Sub-Processors (Foundation Model providers and any sub-processor that processes Customer Personal Data using machine-learning inference or training infrastructure): at least 15 days' prior notice. The shorter window reflects the faster cadence of change in the AI vendor ecosystem.
Other Sub-Processors (infrastructure, security, billing, communications, observability): at least 30 days' prior notice.
Notice is delivered by email to Account administrators, by in-platform notification, and by updating this page. Customers may object to a new sub-processor on reasonable data protection grounds per Section 6.4.4 of the DPA.
AI Sub-Processors (15-day notice category)
Foundation Model providers and AI inference infrastructure. Each is contractually committed to no-default-training of Customer data and either Data Privacy Framework (DPF) certified or bound by EU Standard Contractual Clauses (SCCs Module Three: Processor-to-Processor). Edition tier indicates the lowest paid tier where the adapter is available; Community Edition is open-source and self-hostable, in which case no AI Sub-Processor is engaged by Bodaty.
| Sub-processor | Edition | Purpose | Categories of personal data | Region | Transfer mechanism |
|---|---|---|---|---|---|
| Anthropic, PBCAI | Community+ | Claude Foundation Model inference | Customer prompts and AI outputs (no training) | United States | DPF + SCCs (Module Three) |
| OpenAI, LLCAI | Community+ | GPT Foundation Model inference (where Customer enables) | Customer prompts and AI outputs (no training, commercial / API tier) | United States | DPF + SCCs (Module Three) |
| HuggingFace, Inc.AI | Community+ | HuggingFace Inference API for hosted open-source models (where Customer enables) | Customer prompts and AI outputs (no training) | United States; EU | DPF + SCCs (Module Three) |
| DeepSeekAI | Community+ | DeepSeek Foundation Model inference (where Customer enables) | Customer prompts and AI outputs — Controller should review transfer-impact assessment before enabling | China-based provider | SCCs (Module Three); supplementary measures |
| Google LLC (Gemini)AI | Business+ | Gemini Foundation Model inference (where Customer enables) | Customer prompts and AI outputs (no training) | United States; EU (regional availability) | DPF + SCCs (Module Three) |
| AWS BedrockAI | Business+ | Multi-model Foundation Model gateway (Anthropic, Meta, Mistral, Cohere, and others as Customer selects) | Customer prompts and AI outputs (no training) | United States (primary); EU (where supported) | DPF + SCCs (Module Three) |
| Cohere, Inc.AI | Business+ | Cohere Foundation Model inference (where Customer enables) | Customer prompts and AI outputs (no training) | United States; Canada | SCCs (Module Three) |
| Microsoft (Azure OpenAI)AI | Business+ | OpenAI models via Azure regional deployment (where Customer enables) | Customer prompts and AI outputs (no training) | Customer-selected Azure region | DPF + SCCs (Module Three) |
Customer-controlled / self-hosted runtimes. Customer may also configure the Service to use locally hosted Foundation Model runtimes such as Ollama or vLLM. When operated on Customer-controlled infrastructure, these are not AI Sub-Processors under the DPA — Bodaty does not engage them on Customer's behalf.
Infrastructure, security, payments, and communications (30-day notice category)
Service providers that process personal data to operate the AICtrlNet / HitLai platform. Customer may verify Data Privacy Framework certification status at dataprivacyframework.gov/list.
| Sub-processor | Purpose | Categories of personal data | Region | Transfer mechanism |
|---|---|---|---|---|
| Amazon Web Services, Inc. | Primary cloud infrastructure (compute, storage, networking, managed database, managed cache) | All personal data processed by the Service | United States (default); EU (upon Customer request) | DPF + SCCs (Module Two) |
| Google Cloud Platform | Secondary cloud infrastructure; AI/ML services | Workflow data; AI inputs and outputs | United States; EU | DPF + SCCs (Module Two) |
| Cloudflare, Inc. | Content delivery network, DDoS protection, web application firewall | IP addresses, request metadata, security event logs | Global edge network | DPF + SCCs (Module Two) |
| Stripe, Inc. | Subscription billing and payment processing | Billing contact information, payment instrument metadata (Stripe stores the actual payment-instrument data, not Bodaty) | United States | DPF + SCCs (Module Two) |
| Twilio SendGrid | Transactional and notification email delivery | Email addresses; notification content (e.g., approval requests, audit summaries) | United States | DPF + SCCs (Module Two) |
Where you run the platform on your own infrastructure
For Customers operating self-hosted AICtrlNet Community Edition or air-gapped Enterprise deployments, none of the sub-processors above process Customer personal data. The Customer is the sole Controller and Processor. Locally hosted Foundation Models (Ollama, vLLM, or other Customer-controlled runtimes) replace the AI Sub-Processors listed above. See Section 12.6 of the Privacy Policy and the relevant deployment documentation for details.
Change history
- May 26, 2026 (b)
- Expanded AI Sub-Processors list to align with live adapter inventory: added HuggingFace, DeepSeek (Community+); AWS Bedrock, Cohere, Microsoft (Azure OpenAI) (Business+). Added edition-tier column. Added explicit non-disclosure of Customer-controlled Ollama / vLLM self-hosted runtimes (not AI Sub-Processors).
- May 26, 2026
- Initial public publication of Annex C as a standalone page. Sub-processors listed reflect the production stack as of this date. Added explicit identification of AI Sub-Processors (Anthropic, OpenAI, Google) subject to the 15-day notice category under DPA §6.4.3(a).
Need to object to a new sub-processor, or have specific data-residency requirements?
Customers may object to the engagement of a new sub-processor on reasonable data protection grounds. Enterprise Customers may request specific residency commitments, dedicated sub-processor exclusions, or extended objection windows in their Order Form.
Email privacy@aictrlnet.com