Preamble
Black Swan Ventures Group LLC (the "Company") engages the third-party providers set out below in the operation of the website located at cashflowpositive.ai and in the delivery of its services. Each acts under a written data processing agreement where applicable, processes personal data solely upon the Company's documented instructions, and is bound by obligations of confidence and by appropriate security measures.
This Register is maintained pursuant to Article 28(2) GDPR and is referred to by the Privacy Policy, the Cookie Policy, the Data Processing Addendum, and the Cybersecurity Disclosure.
[CONFIRM the whole of the Register prior to publication.] Every entry must correspond to a provider in fact engaged, with the correct entity name, place of processing, and mechanism of transfer. Entries not in production must be deleted. An inaccurate register constitutes a direct breach of Article 28 GDPR and is the first matter examined by an enterprise procurement function.
1. Infrastructure and Hosting
| Provider | Purpose | Data | Place | Transfer mechanism |
|---|---|---|---|---|
| Lovable | Website construction and deployment | Site content; form submissions | Union / United States | Standard Contractual Clauses |
| [CONFIRM: edge or content delivery provider] | Delivery; denial-of-service mitigation; web application firewall | IP address; request metadata | Global | Standard Contractual Clauses |
| Supabase | Application database and authentication | Application and account data | [CONFIRM region] | Standard Contractual Clauses |
2. Communications and Correspondence
| Provider | Purpose | Data | Place | Transfer mechanism |
|---|---|---|---|---|
| Google (Workspace) | Business electronic mail; documents | Content of correspondence | United States / Union | SCCs and Data Privacy Framework |
| Instantly | Outbound electronic mail delivery | Business contact data; message content | United States | Standard Contractual Clauses |
| Aircall | Inbound and outbound telephony; call recording | Telephone numbers; call audio; metadata | Union / United States | Standard Contractual Clauses |
| Slack | Internal collaboration | Internal messages; shared files | United States | SCCs and Data Privacy Framework |
3. Enrichment and Client Relationship Management
| Provider | Purpose | Data | Place | Transfer mechanism |
|---|---|---|---|---|
| Apollo.io | Discovery and enrichment of business contacts | Business contact data | United States | Standard Contractual Clauses |
| Clay | Orchestration and enrichment of data | Business contact data | United States | Standard Contractual Clauses |
| Explorium | Firmographic and prospect indicators | Business contact data | United States / Israel | Standard Contractual Clauses |
| FullEnrich | Enrichment of telephone numbers | Business telephone numbers | Union | n/a |
| Attio | Client relationship management | Contact records; engagement history | Union / United States | Standard Contractual Clauses |
4. Scheduling, Payment, and Execution of Documents
| Provider | Purpose | Data | Place | Transfer mechanism |
|---|---|---|---|---|
| iClosed | Booking of consultations | Name; electronic mail address; scheduling data | United States | Standard Contractual Clauses |
| Calendly | Scheduling of meetings | Name; electronic mail address; availability | United States | SCCs and Data Privacy Framework |
| Stripe | Processing of payments | Billing particulars; transaction data | United States / Union | SCCs and Data Privacy Framework |
| Mercury | Business banking | Payment and payee data | United States | n/a |
| DocuSign / SignWell | Contracts, releases, and signature | Identity of signatory; document content | United States | Standard Contractual Clauses |
5. Artificial Intelligence and Capture
| Provider | Purpose | Data | Place | Transfer mechanism |
|---|---|---|---|---|
| Anthropic | Language model processing for research, drafting, and delivered systems | Content submitted for processing | United States | Standard Contractual Clauses |
| [CONFIRM: further model providers in production] | n/a | n/a | n/a | n/a |
| Plaud | Capture and transcription of calls | Call audio; transcripts | [CONFIRM] | [CONFIRM] |
The Company employs the business or enterprise tier wherever an undertaking against training upon customer inputs is available, and configures that setting. See clause 4 of the Cybersecurity Disclosure.
6. Analytics and Consent
| Provider | Purpose | Data | Place | Transfer mechanism |
|---|---|---|---|---|
| [CONFIRM: analytics provider] | Aggregated analytics | IP address (truncated); device; page views | [CONFIRM] | [CONFIRM] |
| Termly | Consent management | Consent records; IP address | United States | Standard Contractual Clauses |
7. Professional Advisers
Accountants, tax advisers, and lawyers act as independent controllers or as processors under professional obligations of confidence. They are engaged as occasion requires and are not individually listed.
8. Alteration of the Register
8.1 The Company shall notify clients of the addition or substitution of any sub-processor processing that client's data not less than thirty days before the change takes effect, by electronic mail to the address on record.
8.2 A client reasonably objecting upon data protection grounds within that period may require the Company to use commercially reasonable endeavours to identify an alternative. No alternative being available, either party may terminate the affected service without penalty in respect of the unused portion.
8.3 Notification of alterations may be requested by writing to mgmt@blackswanventuresgroup.com with the words SUB-PROCESSOR UPDATES in the subject line.
9. The Company
Black Swan Ventures Group LLC
30 N Gould Street, Ste N, Sheridan, Wyoming 82801, United States of America
mgmt@blackswanventuresgroup.com · +1 872-375-3144
Correspondence
Black Swan Ventures Group LLC30 N Gould Street, Ste N
Sheridan, Wyoming 82801
United States of America
mgmt@blackswanventuresgroup.com
+1 872-375-3144
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