Sub-Processor Register

Effective date: 2026-05-10  ·  Version: 1.0  ·  Last updated: 2026-05-10

Purpose

This register exists for three audiences:

1. Subscribers — to know exactly which third parties have access to their personal data and where that data is stored.
2. Mexican regulators (INAI) — as the operative documentation supporting our compliance with LFPDPPP Article 36 (international transfer) and the responsable's general duty to maintain a record of processing activities under Mexican data-protection law.
3. Counsel and auditors — to verify that contractual safeguards are in place with each sub-processor and that the documented purposes match actual data flows.

We (Jaime Muriel Monroy) act as responsable del tratamiento (data controller) under LFPDPPP. The sub-processors below act as encargados (data processors) and process personal data only on our documented instructions.

Current sub-processors

As of the effective date, the following sub-processors handle personal data on our behalf:

1. Clerk

2. Stripe

3. Resend

4. Cloudflare

5. Anthropic

Sub-processors NOT used

For clarity and to forestall future questions, the following common SaaS sub-processors are not used by Dardo:

• No analytics SDKs (no Google Analytics, no Mixpanel, no Amplitude, no Segment, no PostHog)
• No advertising or marketing platforms (no Meta Pixel, no Google Ads, no LinkedIn Insight)
• No customer-support platforms (no Intercom, no Zendesk, no Crisp) — support is via direct email to [email protected]
• No CRM (no Salesforce, no HubSpot)
• No session-replay tools (no FullStory, no Hotjar, no LogRocket)
• No third-party error monitoring sending personal data (no Sentry user-context, no Datadog APM personal fields)
• No third-party comments, chat widgets, or social-media embeds

The Service explicitly avoids these to minimize data exposure and simplify regulatory posture. Adding any such processor in the future would require updating this register, providing 30-day notice per Privacy §12, and contractual review.

Adding or changing sub-processors

A new sub-processor or material change in an existing sub-processor's scope is a material change to data processing and triggers:

1. Internal review — verify a current DPA exists or is executable, that the processor's data-protection commitments meet LFPDPPP Article 36 standards, and that the purpose is necessary.
2. 30-day advance notice to all active subscribers via email and an in-Service notice, per Privacy Policy §12.
3. Update to this register — bump version, add an entry, update the effective date.
4. Right of objection — subscribers who object to a new sub-processor may cancel their subscription; the change does not retroactively affect data already processed under the prior register.

Emergency changes (e.g., a sub-processor experiencing a security incident requiring immediate replacement) may be made without 30-day notice but require notice within 30 days after the change and full disclosure of the rationale.

Sub-processor data flow summary

The end-to-end flow for personal data through these sub-processors:

[Subscriber] ─sign-up─▶ [Clerk]              (auth, identity)
      │                    │
      │                    └─webhook─▶ [Cloudflare D1]   (Dardo user record)
      │
      ├─subscribe─▶ [Stripe]            (billing, payment method)
      │                  │
      │                  └─webhook─▶ [Cloudflare D1]   (subscription state)
      │
      ├─uses Service─▶ [Cloudflare Pages + Workers + KV]
      │
      └─receives email─▶ [Resend]      (transactional only)

[Cron]─▶ [Anthropic]   (anonymized analytics in, brief content out)
         │
         └─writes─▶ [Cloudflare KV]    (content blobs read by all subscribers)

No personal data flows to Anthropic. Anthropic receives only aggregated market analytics produced by Dardo's pipeline.

Audit and verification

DPAs with each sub-processor are maintained in Dardo's internal records and are available for INAI inspection on reasonable notice. Each DPA is reviewed at least annually for material changes by the sub-processor and re-executed if required.

A copy of the most recent version of this register is maintained at dardoresearch.com/sub-processors for subscriber reference.

Document v1.0 published 2026-05-10. Companion to Privacy Policy v1.0. Next review: 12 months from publish, on any sub-processor change, or sooner if a material change is required.