BloodGPT

Subprocessors

Third parties that process personal data on our behalf when we provide BloodGPT services to business customers.

Version 1 · In force since August 20, 2026

Objections to a change: [email protected]

Every customer

These process personal data for every customer of the B2B service; no setting removes them.

Cloudflare, Inc.

All customers
Applies to
All customers
Service Description
Reverse proxy, web application firewall, content delivery, TLS termination, and tenant custom-hostname routing for BloodGPT's B2B web, API, and patient-portal services.
Role in the processing chain
Further subprocessor
Processing Purpose
Traffic delivery, tenant-domain routing, availability, and application security
Data Types Processed
  • IP addresses and device or network metadata
  • URLs, headers, cookies, and request metadata
  • Application request and response content passing through the proxy
  • Security and access logs
Location
  • Global edge network
Transfer mechanism
EU standard contractual clauses (Commission Implementing Decision 2021/914) under the Cloudflare Data Processing Addendum: Module Two where BloodGPT acts as controller and Module Three where BloodGPT acts as processor, together with the UK International Data Transfer Addendum (version B1.0) where UK law applies. Cloudflare additionally relies on the EU-US Data Privacy Framework for transfers it treats as unrestricted.

Functional Software, Inc. d/b/a Sentry

All customers
Applies to
All customers
Service Description
Application error monitoring and performance tracing for the B2B platform and supporting clinical-processing services.
Role in the processing chain
Further subprocessor
Processing Purpose
Error detection, debugging, performance monitoring, and service reliability
Data Types Processed
  • Error messages and stack traces
  • User, request, and application metadata
  • Application performance traces
  • Patient or clinical context if present in an error payload
Location
  • United States
Transfer mechanism
Primary reliance is the EU-U.S. Data Privacy Framework, with the Swiss-U.S. framework and the UK Extension, under which Sentry self-certifies. If that framework is invalidated or does not apply to a transfer, the Sentry Data Processing Addendum falls back to the EU standard contractual clauses (Commission Decision 2021/914): Module 2 where BloodGPT acts as controller and Module 3 (processor to processor) where BloodGPT acts as processor, with the UK International Data Transfer Addendum (version B1.0) for transfers from the UK and Swiss adaptations for transfers from Switzerland.

Google Cloud EMEA Limited (Google Cloud Platform)

All customers
Applies to
All customers
Service Description
Cloud infrastructure and managed services used to host and operate BloodGPT's B2B API, operations platform, patient portal, analysis services, clinical FHIR stores, databases, object storage, networking, secrets, and telemetry.
Role in the processing chain
Further subprocessor
Processing Purpose
Application hosting, storage, database and clinical-record processing, networking, security, and operations
Data Types Processed
  • Organization and workforce identity data
  • Patient identifiers, demographics, and contact data
  • Lab documents, results, FHIR clinical records, and generated reports
  • Application, security, and operational telemetry
Location
  • Primary regional resources: Netherlands (europe-west4); some edge, support, and control-plane processing is global
Transfer mechanism
Primary processing takes place in the Netherlands, inside the EEA, where no Chapter V transfer mechanism is required. For transfers to other countries the Google Cloud Data Processing Addendum applies (Appendix 3, European Data Protection Law, section 4.1): Google's SCCs (Processor-to-Processor, Google Exporter) cover onward transfers to Google's own subprocessors, or an Alternative Transfer Solution where Google has adopted one for those transfers.

Google Cloud EMEA Limited (Vertex AI / Gemini)

All customers
Applies to
All customers
Service Description
Gemini model inference through Google Cloud Vertex AI for recognition, embeddings, analysis, generation, and patient-portal chat.
Role in the processing chain
Further subprocessor
Processing Purpose
Artificial-intelligence inference, embeddings, extraction, analysis, and content generation
Data Types Processed
  • Lab documents and extracted laboratory data
  • Prompts and patient-linked clinical context
  • Portal questions and relevant health context
  • Embeddings, generated outputs, and request metadata
Location
  • Model and route dependent; production routes may use global processing
Transfer mechanism
Covered by the same Google Cloud Data Processing Addendum as the rest of Google Cloud (Appendix 3, European Data Protection Law, section 4.1). Gemini routes configured to the global endpoint are a transfer outside the EEA in practice and rely on that addendum rather than on EEA processing.

Inngest Inc

All customers
Applies to
All customers
Service Description
Cloud workflow orchestration, event delivery, realtime status, reminders and durable step state for ingestion, analysis and report workflows. Events carry internal identifiers, workflow status and processing options; documents and clinical records stay in Google Cloud and are fetched there by the worker.
Role in the processing chain
Further subprocessor
Processing Purpose
Workflow orchestration, event delivery, durable execution, and realtime processing status
Data Types Processed
  • Pseudonymous internal identifiers: organization, patient, test, report, reminder, job and workflow ids
  • FHIR resource identifiers for the patient and the diagnostic report
  • The customer's own external test identifier, where it appears in a storage object key
  • Workflow routing, timing, status and durable step state
  • Processing options such as target language and panel grouping
  • No laboratory values, no submitted JSON or HL7 content, no uploaded file content, no report content, no demographics and no direct identifiers
Location
  • United States
Transfer mechanism
EEA standard contractual clauses under the signed Inngest Data Processing Agreement: Module Two where BloodGPT acts as controller and Module Three (processor to sub-processor) where BloodGPT acts as processor, with the UK Addendum incorporated.

Langfuse GmbH

All customers
Applies to
All customers
Service Description
Hosted prompt management, tracing and evaluation for artificial-intelligence requests made by BloodGPT's B2B and patient-portal services. The service is provided on the dedicated HIPAA Cloud region and, following the acquisition of Langfuse by ClickHouse, is governed by the ClickHouse customer data processing addendum.
Role in the processing chain
Further subprocessor
Processing Purpose
AI request tracing, prompt management, evaluation, and operational monitoring
Data Types Processed
  • AI prompts and generated outputs
  • Organization, patient, test, and request identifiers where present in traces
  • Clinical context included in traced model requests
  • Model timing, usage, and evaluation metadata
Location
  • United States (AWS us-west-2, Oregon)
Transfer mechanism
EU standard contractual clauses (Commission Implementing Decision 2021/914) under the ClickHouse Customer Data Processing Addendum, which covers Langfuse Cloud following the acquisition: Module Two where BloodGPT acts as controller and Module Three where BloodGPT acts as processor (Schedule I), with the UK Addendum for transfers from the UK and Swiss adaptations for transfers from Switzerland. While ClickHouse holds a valid Data Privacy Framework certification covering the transfer, it is treated as unrestricted instead.

OpenAI Ireland Ltd.

All customers
Applies to
All customers
Service Description
API-based artificial-intelligence model inference used for document recognition, analysis, report generation, patient-portal chat, and optional audio transcription.
Role in the processing chain
Further subprocessor
Processing Purpose
Clinical-data extraction, analysis, content generation, portal chat, and transcription
Data Types Processed
  • Lab documents and extracted laboratory data
  • Prompts and patient-linked clinical context
  • Portal chat or audio content when those features are used
  • Generated analyses, reports, and API request metadata
Location
  • Global; the production project uses the standard API endpoint with no regional residency configured
Transfer mechanism
EU standard contractual clauses under the OpenAI Data Processing Addendum, sections 8.1 and 8.2: Module Two where BloodGPT acts as controller and Module Three where BloodGPT acts as processor, together with the UK Addendum for data subject to UK law (section 4.2).

WorkOS, Inc.

All customers
Applies to
All customers
Service Description
Workforce authentication, SSO, organization and membership management, invitations, sessions, and API-key validation for business customers.
Role in the processing chain
Further subprocessor
Processing Purpose
Workforce authentication, access control, organization management, and API-key validation
Data Types Processed
  • Staff name, email address, and account identifier
  • Organization, role, membership, and invitation data
  • Session, authentication, and API-key metadata
  • No patient or clinical data
Location
  • United States
Transfer mechanism
EU standard contractual clauses (Commission Decision 2021/914), attached to the WorkOS data processing addendum as its Exhibit C and governing transfers to countries without an adequacy decision: Module Two where BloodGPT acts as controller and Module Three where BloodGPT acts as processor, which is the position in the B2B service. The addendum includes the ICO's International Data Transfer Addendum for transfers subject to UK law. Under Module Three, clause 9(a), BloodGPT is responsible for passing WorkOS subprocessor changes on to the customer as controller.

Only in some cases

These process personal data only where the stated feature is in use, or where the contract is concluded through the stated entity.

BLOODGPT LIMITED

Conditional
Applies to
Only contracts concluded through: BLOODGPT Inc. (United States)
Service Description
European Union entity that owns and operates the infrastructure used to provide platform.bloodgpt.com and process customer data. Disclosed as a subprocessor where the customer contract is concluded through BLOODGPT Inc. (United States); where the contract is with BLOODGPT LIMITED itself, it is the processor rather than a subprocessor.
Role in the processing chain
Direct subprocessor
Processing Purpose
Infrastructure ownership and operation, application hosting, and customer-data processing
Data Types Processed
  • Organization, workforce identity, and account data
  • Patient identifiers, demographics, and contact data
  • Lab documents, results, FHIR clinical records, and generated reports
  • Application, security, and operational telemetry
Location
  • European Union
Transfer mechanism
Not applicable: the entity is established in the EEA (Cyprus), so no transfer to a third country arises on this leg. The customer-to-BLOODGPT Inc. transfer is covered by the standard contractual clauses in the data processing agreement with the customer.

Mailgun Technologies, Inc.

Conditional
Applies to
Only customers using: Patient portal, Email notifications, Customer email sending domain, Follow-up reminders
Service Description
EU-region transactional email delivery for patient invitations, magic links, report-ready notices, follow-up reminders and tenant sending-domain support. Messages carry identity, a test date and an opaque link rather than laboratory values, report content or attachments; follow-up reminders additionally name the recommended test.
Role in the processing chain
Further subprocessor
Processing Purpose
Transactional email delivery, sending-domain support, and delivery-status processing
Data Types Processed
  • Recipient name and email address
  • Sending organization identity and branding
  • Test date and an opaque report or magic link
  • Message content and delivery metadata
  • Where follow-up reminders are enabled: the name of the recommended follow-up test and its rationale
  • No laboratory values, report content or attachments are sent
Location
  • European Union data region; support and subprocessors may operate in other locations
Transfer mechanism
EU standard contractual clauses (Commission Decision 2021/914), incorporated by the Sinch data processing agreement that Mailgun's terms make part of the service agreement: Module 2 where BloodGPT acts as controller and Module 3 (processor to processor) where BloodGPT acts as processor, with the UK Addendum where required. Sinch is the data importer and BloodGPT the data exporter; the Swedish supervisory authority and Swedish courts are designated. Annex IB of those clauses records that no sensitive data is transferred, so the mechanism covers invitation, login and report-ready messages and does not extend to clinical content.

Stripe Payments Europe, Limited

Conditional
Applies to
Only customers using: Card billing and subscriptions
Service Description
Payment, subscription, and invoice administration for BloodGPT business customers. Patient and clinical data is excluded from Stripe fields and metadata.
Role in the processing chain
Further subprocessor
Processing Purpose
Payment processing, subscription administration, invoicing, and fraud prevention
Data Types Processed
  • Business customer and billing contact data
  • Payment-method and transaction data
  • Subscription, invoice, usage, and payment-status metadata
  • No patient or clinical data
Location
  • Ireland, with Stripe affiliates and subprocessors operating globally
Transfer mechanism
EEA standard contractual clauses (Modules 1 and 2), the UK International Data Transfer Addendum, or the Data Privacy Framework, as applicable under the Stripe Data Processing Agreement. BloodGPT is the controller of the billing data in scope.