Sub-processor register

This page lists every third party that processes personal data for Callper, with its legal entity, country, role, the footing on which data leaves the European Union where it does, and what each one keeps. It is the public counterpart of Annex 3 of the Data Processing Agreement and is read together with the privacy policy and the caller notice.

Controller / processor. Callper SRL, Romania, VAT RO55481408, is the processor for the data callers and a business's customers give that business's assistant, and the controller for its own users' identity, billing and correspondence. The register marks which role each vendor serves.

In one sentence: GDPR compliant, DPA available, Standard Contractual Clauses in place, all sub-processors disclosed. Callper does not claim EU data residency: a call's audio is processed live on Telnyx's own infrastructure, at whichever of its sites gives the call the least delay, which Telnyx does not guarantee to be in the European Union, and Telnyx is a United States company. Business and caller records are stored in the European Union — in Romania, as an encrypted nightly backup in an EU region of Telnyx's object storage, and, for what Telnyx itself keeps of a call, in Telnyx's Germany region.

How to read the retention column. Telnyx's retention is per plan: transcripts are retained for businesses on ordinary plans and not retained for businesses whose Business plan has Zero Data Retention switched on. Recordings are off for everyone. Any page that states one answer for Telnyx is wrong; this register states both.

1. The register

#	Vendor (legal entity)	Country	Role for Callper	Data it touches	Transfer footing	Retention	DPA
1	Telnyx LLC	United States (Chicago, IL) for the company. A call is processed live at the Telnyx site that gives it the least delay; what Telnyx stores for Callper is stored in its Germany region	Sub-processor. Phone numbers, inbound and outbound telephony, the AI assistant (speech-to-text, language model, text-to-speech), voice clones, regulatory paperwork for numbers, transactional SMS. Also Callper's own processor for calls to the public voice demo, where Callper is the controller	Caller audio in real time (both directions); the caller's number and country; the transcript of each call; the business's greeting, instructions and knowledge-base content; voice-clone samples; identity documents and company certificates filed for number orders (pass-through: never stored by Callper); the business's identity as the end user of record; and, since 22 September 2026, the nightly dump of Callper's entire database — contacts, transcripts, summaries, appointments, users and billing records alike, a wider class than the rest of this row — encrypted with AES-256 on Callper's own server before it is uploaded. Telnyx holds ciphertext and not the passphrase, which is kept in Callper's secrets manager and never on the Telnyx account, so Telnyx cannot read any of it	EU-U.S. Data Privacy Framework: Telnyx is on the Framework's list as an active participant, with the UK extension and the Swiss-U.S. Framework (read on 28 September 2026). The Standard Contractual Clauses in Telnyx's Data Processing Addendum are the fallback. Callper's account keeps what Telnyx stores at rest — call detail records and, for ordinary plans, conversation content — in Telnyx's Germany region. Live processing is not pinned to a region: Telnyx runs it at the site that gives the call the least delay and may move it during a failure or a shortage of capacity, and it does not guarantee processing inside the European Union. The backup objects are stored in Telnyx Cloud Storage's `eu-central-1` region and do not leave the European Union; the transfer on that part of the row is access by Telnyx LLC in the United States, on the same footing	Transcripts: retained for ordinary plans, not retained for Zero Data Retention businesses (the ZDR templates redact the transcript at the source). Recordings: off on every assistant. Voice-clone samples: retained until the clone is deleted; account deletion deletes clones immediately. Number documents: held in Telnyx's document store until the requirement group is deleted. Conversations can be deleted individually; the public voice demo's are deleted by Callper 30 days after the call. Database backups: deleted after 30 days, the same clock Callper keeps on its own server; that deletion pauses while uploads are failing, so a backup that has quietly stopped working cannot empty the store as well	Data Processing Addendum, version 3.0: part of Telnyx's terms and binding on acceptance, so nothing is signed. Under it Telnyx does not use call content to train models offered to others, except with the customer's opt-in or on data it has first de-identified. Callper asked Telnyx on 2 October 2026 to document an opt-out from that last use as well and has no answer yet
1a	Speech-to-text: Deepgram's Nova-3 and Flux models, run by Telnyx on its own infrastructure	Wherever row 1 processes the call	Part of Telnyx's service, not a separate recipient. Telnyx states, in its published data-residency documentation and in writing to Callper on 2 October 2026, that an assistant's calls are not sent to Deepgram's own service and that Deepgram receives and keeps nothing from them	Caller and assistant audio in real time; interim and final transcripts	Same as Telnyx. Deepgram, Inc., the models' author, receives nothing	Same as Telnyx	None needed beyond Telnyx's
1b	Language model (an open-weight model hosted by Telnyx)	Runs on Telnyx's own hardware, wherever row 1 processes the call	Part of Telnyx's service, not a separate recipient	The conversation turns, in real time	Same as Telnyx. The model's author receives nothing	Same as Telnyx	None needed beyond Telnyx's
1c	Text-to-speech: Telnyx's own voices (the Ultra, Natural, Kokoro and Qwen families) and Resemble AI's models, all run by Telnyx on its own infrastructure	Wherever row 1 processes the call	Part of Telnyx's service, not a separate recipient. Telnyx's usage records label the Ultra voices with another company's model name; Telnyx states that they are its in-house voices, synthesised on its own infrastructure and sent to no third party. Inworld voices are no longer offered (since 5 October 2026): Telnyx's documentation lists Inworld as a third-party engine, which would have received the assistant's words under Inworld's own terms, and no assistant was using one	The assistant's reply text (which quotes what the caller said when the assistant repeats or confirms it); for cloned voices, the business's voice sample	Same as Telnyx. No voice vendor receives anything	Real-time synthesis; same as Telnyx	None needed beyond Telnyx's
2	Clerk, Inc.	United States	Processor for Callper as controller. Sign-in and sessions for the dashboard; the organization and membership model	A business's staff: email, name, sign-in method, session tokens; organization membership. No caller data	EU-U.S. Data Privacy Framework certified (with the UK extension and the Swiss-U.S. DPF). SCCs in the DPA as fallback	Until the Clerk organization is deleted, which account deletion does immediately; Clerk's DPA deletes within 90 days of termination	Data Processing Addendum, incorporated by reference
3	Stripe Payments Europe, Ltd (contracting entity, Ireland) with Stripe, Inc. (US) and Stripe Technology Company, Ltd (Ireland)	Ireland / United States	Both roles: joint controller for regulated payment processing (anti-money-laundering, know-your-customer, fraud, card-scheme rules); processor for what it does on our instructions (invoicing, tax, the billing portal). Not an ordinary sub-processor	A business's billing contact, company identity and VAT ID, invoices, payment method (which never reaches Callper), tax registrations. No caller or health data, ever	EU-U.S. Data Privacy Framework certified (Stripe, Inc.; also the UK extension and Swiss-U.S. DPF); Data Transfers Addendum with SCCs	Stripe's own statutory retention as controller; as processor, per the DPA	Data Processing Agreement, part of the Stripe Services Agreement
4	Scaleway SAS	France	Sub-processor. Transactional email: appointment confirmations and reminders to a business's customers; owner-facing mail (low balance, service alerts)	Recipient email address and name, message body (appointment time, service, business name), delivery events	Intra-EU; French-law DPA	Scaleway states no retention period for its message logs and offers no way to delete them; measured on 22 September 2026, its log still held every message Callper had ever sent, the oldest from 12 August 2026	Data Processing Agreement, part of Scaleway's General Terms of Services and in force on acceptance; nothing is signed
5	Google Cloud EMEA Limited (Dublin, Ireland — the Google entity that contracts with us from Romania), with Google LLC (United States) behind it	Ireland for the contract; the mailboxes themselves are not stored only in Europe. Our Google Workspace edition is Business Starter, which does not offer a choice of data region	Processor for Callper as controller. Our own mailboxes: office and support correspondence, the emails we write to businesses we contact first and their replies, vendor threads, and the alerts our systems send us	Whatever people write to us, which can include a business naming a caller in a support request	EU-U.S. Data Privacy Framework certification for Google LLC, with the Standard Contractual Clauses in Google's Cloud Data Processing Addendum as the fallback	Mailbox retention under our control	Cloud Data Processing Addendum, part of the Workspace agreement
6	Infisical Inc.	United States; the EU instance runs in a separate cloud account in the EU	Infrastructure vendor. Secrets management for Callper's own systems	API keys and configuration. No personal data beyond the operators' own logins	EU-hosted; Infisical staff access from the US is the residual transfer, SCCs via its DPA	Until we rotate or delete a secret	Data Processing Agreement, part of Infisical's terms and in force with them; nothing is signed. Deletion within 60 days of termination
7	TES EURO MEDIA SRL (trading as Gazduire.Net; the server itself is labelled DirectHost), CUI RO 14612719, trade register J2002000536080, Sânpetru, Brașov	Romania (Datacenter M247, Bucharest)	Sub-processor. The virtual server that runs the API, the dashboard and the database: everything Callper stores at rest, save the encrypted backup copy that leaves it nightly for row 1. The host also takes its own daily and weekly backup copies of the whole server	All application data: organizations, users, assistants, transcripts and summaries, contacts, appointments, billing records, and the backups kept on the host — Callper's own dumps, a copy of which also goes, encrypted, to Telnyx Cloud Storage (row 1), and the host's own backups of the server	Intra-EU. The host's server backups are kept in its Bucharest data centre as a rule and may also be stored at Impossible Cloud GmbH, Hamburg, Germany, its own sub-processor, encrypted before they leave with keys only the host holds	Callper's own retention policy applies to the live data and to Callper's dumps: a 30-day deletion archive, then erasure, and dumps pruned at 30 days. The host's daily and weekly server backups are overwritten on its own cycle, whose exact depth it has not stated; its agreement deletes backups within 31 days of a deletion, which Callper takes as the outer bound. So a row erased from the live database can survive in a host backup, unreadable to Callper, for up to 31 days more	Article 28 agreement incorporated in the host's terms and in force on acceptance (gazduire.net/dpa_gazduirenet.pdf, September 2026): breach notice to Callper within 48 hours, 30 days' notice of sub-processor changes with a right to object, deletion within 30 days of contract end and of its backups within 31
8	HubSpot, Inc.	Data stored in the European Union (Germany); HubSpot, Inc. is a US company	Processor for Callper as controller. Callper's own customer-relationship system, and the page where a person books a demo with Callper: who enquires about Callper, who books a demo, which businesses Callper contacts first and what they answered, who signs up, and how the public site is used. For the businesses Callper contacts first it also sends Callper's one-to-one emails, through Callper's own mailbox with open and click tracking off, and may place Callper's calls, unrecorded	Your name, email address, company, the plan you are on, and the contact number your business gave us at sign-up, on your company's record. If you book a demo, your name, email address and timezone, and the booking itself. For a business Callper contacts first, the contact details it publishes (name, email address, phone number, postal address, website, and a person's name where its website gives one: privacy policy, section 3), the emails exchanged with it, the notes of calls with it, and whether it has unsubscribed. Website analytics, and only if you accepted the analytics cookies; if you accepted them and then sign up, the pages this browser read on callper.ai beforehand are joined to your account (privacy policy, section 8). No caller data of any kind — no transcripts, summaries, recordings, callers' numbers, appointments or your contact directory	Storage is intra-EU. US access by HubSpot, Inc. is covered by its EU-U.S. Data Privacy Framework certification (an active listing, read on 28 September 2026), with the Standard Contractual Clauses in its data processing agreement as the fallback	Callper's own retention policy; inactive contacts are not auto-deleted. A business Callper contacted first, or a person who booked a demo, and that did not become a customer: 12 months after the last exchange, deleted by hand (privacy policy, section 6). The page views of a visitor who accepted the analytics cookies and never signed up are held against the cookie's code, which HubSpot offers no way to delete by age: they stay until Callper's HubSpot account closes	Data Processing Agreement, incorporated into HubSpot's Customer Terms of Service; nothing is signed
9	Cal.com, Inc.	United States (Cal.com's own database, file storage, hosting and mail providers are all in the United States)	Processor for Callper as controller, for earlier demo bookings only; closing. Callper's own Cal.com account was the booking page behind every Book a demo link on callper.ai until the page moved to HubSpot (row 8). No link opens it any more and it takes no new bookings. This row is not about a business's own calendar connection, which is that business's own contract (see below)	The name, email address, timezone and booking-form answers of a person who booked a demo with Callper before the move, and the booking itself. Each of those bookings was also copied into HubSpot (row 8) as a contact and a meeting. No caller data and no business's data: the account holds those demo bookings and nothing else	Standard Contractual Clauses, incorporated in the data processing agreement Callper and Cal.com signed on 29 September 2026. Cal.com, Inc. is not on the Data Privacy Framework list (read on 28 September 2026)	Until the account is closed, and within that 12 months after the last exchange unless the person becomes a customer, deleted by hand (privacy policy, section 6); after the account is closed, the signed agreement gives an export window of at least 30 days and then deletion on Cal.com's own schedule, with its backups kept until they are overwritten. This row is removed when the account is closed	Data Processing Agreement, signed by both parties on 29 September 2026
10	Anthropic Ireland, Limited (the contracting entity for a customer in the European Economic Area, Dublin, Ireland) with Anthropic, PBC (United States) behind it	Ireland for the contract; the model runs in the United States, where Callper directs every request	Processor for Callper as controller for two purposes, and from 2026-11-07 a Sub-processor of Customer Data for one: when a business that uses Callper asks, after signing up, for an assistant built from its own website, the model reads the extracted text of up to six public pages of that website and returns the business profile the assistant is built from, which the business confirms before use (DPA Annex 2 row 7, Annex 3); it receives nothing else of that business's data, no caller data and no call content. The two purposes of Callper's own: the AI model that reads each reply a business sends to the emails Callper writes to it first, sorts it (a request to stop, interest, a question, "not now", or something for a person), and writes Callper's answer when the answer is on Callper's fixed sheet of facts about itself; that answer goes out signed "Callper's AI Assistant". For a reply it hands to a person, it also drafts the answer that person may use. It also reads the public pages of a website a visitor names in the builder on callper.ai (up to six pages of that one website) and returns the business profile a draft assistant is built from; Callper is the controller there too (privacy policy, section 3, "An assistant built from a website"). It is not the assistant that answers the phone for a business, which is row 1	The email conversation the reply belongs to: the business's name, the name and email address of the person who wrote, and what was written on both sides; the sheet of facts. For the builder: the text of up to six public pages of the website a visitor names, and the profile returned from it (a business's name, address, phone number, email address, opening hours, services and common questions, and any person's name those pages give). No caller data and no business's data: nothing a business that uses Callper entrusts to it	Standard Contractual Clauses (Module Two, controller to processor) in Anthropic's Data Processing Addendum, which its Commercial Terms incorporate. No EU-U.S. Data Privacy Framework certification found for Anthropic. Anthropic's own sub-processors for hosting are Google Cloud, Amazon Web Services and Microsoft Azure	Anthropic deletes what it receives and what it writes within 30 days, unless its safety systems flag the exchange as breaking its usage policy, when it may keep it for up to 2 years; its terms forbid it to train models on it. The reply and the answer themselves are kept by Callper as email, in rows 5 and 8, on the 12-month clock of the privacy policy, section 6. A draft built from a website, with the pages read for it and its profile, is kept by Callper for 7 days unless the visitor signs up and keeps it (privacy policy, section 6)	Data Processing Addendum, incorporated in the Commercial Terms
11	Bouncer Sp. z o.o. (Wrocław, Poland)	Poland; the checks run on Amazon Web Services in Frankfurt, Germany, and Bouncer's data processing agreement states that the data is not transferred outside the European Union	Processor for Callper as controller. The email verification service that checks, once and before Callper's first email to a business it contacts first, that the address Callper found for it exists: it asks the address's own mail server whether the mailbox is there, without sending anything to it, and answers whether the address can be written to. An address that does not exist is never written to	The email address alone, as the business published it: no name, no business name, no phone number. No caller data and no business's data: nothing a business that uses Callper entrusts to it	None: processing in the European Union by a company in the European Union	Bouncer keeps the address for at most 60 days, then anonymises and deletes it; Callper's script deletes the batch as soon as it has read the results, so the usual life is minutes. The result itself is kept by Callper with the business's record, on the 12-month clock of the privacy policy, section 6	Data Processing Amendment, part of Bouncer's Terms of Service

Deliberately absent:

Cal.com, as a business's own calendar: the business's own account under the business's own contract. Callper holds a key the business supplied and calls Cal.com on the business's behalf. The privacy policy says so; the register does not list that relationship. Callper's own Cal.com account, where demos were booked until the booking page moved to HubSpot, is a different relationship and is row 9 until that account is closed. The two are told apart by whose contract the account sits under, not by the vendor's name.
OpenAI: not a recipient. Anthropic is one for two purposes of Callper's own: the replies to its outreach emails, and the builder on callper.ai that reads a website a visitor names (row 10). The assistant that answers the phone for a business uses no hosted third-party model API; if its language model ever moves to one, this register changes before the assistant does.
Rime: left the voice catalogue on 2026-08-26.
Cloudflare or any CDN: none. callper.ai resolves directly to Callper's own server.

2. What this page states

Telnyx's retention is per plan. Transcripts are retained for businesses on ordinary plans and not retained for businesses with Zero Data Retention switched on; recordings are off for every business's calls. The one line that is recorded is Callper's own public voice demo in English, under the privacy policy, section 3: kept 30 days in Telnyx's Germany region, then deleted.
Stripe is a joint controller for regulated payment processing, not an instructed processor.
No company other than Telnyx hears a call. The speech-to-text, the language model and the voice all run on Telnyx's own infrastructure (rows 1a to 1c). The companies whose models these are, Deepgram among them, receive nothing. The one outside voice vendor that would have received the assistant's words, Inworld, is no longer offered.
Where a call is processed is not fixed, and where its records are stored is. A call is processed live at the Telnyx site that gives it the least delay, which is usually near the caller and which Telnyx does not guarantee to be in the European Union. Business and caller records are stored in the European Union: in Romania, and, for what Telnyx itself keeps of a call, in Germany. Both halves belong in one sentence: the second without the first would be a residency claim Callper does not make.
Telnyx may use de-identified call content to improve its own products, and Callper has asked it not to. Telnyx's agreement forbids training models offered to others on call content, except on data it has first de-identified. Callper asked on 2 October 2026 for a documented opt-out from that exception. With Zero Data Retention switched on, Telnyx keeps no conversation content for such use to draw on.
The host keeps its own backups of the server. TES EURO MEDIA SRL takes daily and weekly backup copies of the whole virtual server, kept in Bucharest and possibly, encrypted, at Impossible Cloud GmbH in Germany (row 7). They exist to restore the server after a failure; Callper cannot read them and does not use them. Data Callper has erased can survive in one of them for up to 31 days more, which is why the erasure promise on the privacy policy and in the DPA names that window.
The nightly backup leaves the server, not the Union. A copy of each nightly database dump is encrypted on Callper's own machine, with AES-256 and a passphrase kept away from the destination, and pushed to Telnyx Cloud Storage in eu-central-1 (row 1). Romania is where the records live and are worked on; since 22 September 2026 it is not the only place a copy of them sits.
An AI model reads the replies to Callper's outreach emails and the public website pages a visitor asks the builder to read, and never a caller's words. Anthropic (row 10) sees the email conversations with the businesses Callper writes to first and the text of the pages the builder on callper.ai reads, and nothing that a business using Callper entrusts to it. It is Callper's processor, not a Sub-processor under the DPA.
Cal.com appears once, as Callper's own processor for the demo bookings made before the booking page moved to HubSpot (row 9, kept until that account is closed). A demo booked today is made on a page HubSpot hosts (row 8). A business's calendar connection is that business's own contract and is not on this page.

Changes to this register are notified to customers under the DPA's sub-processor clause, with 30 days' notice and a right to object, before they take effect.

3. Open items

Points still open with a vendor or with ourselves:

Telnyx's answer to Callper's request of 2 October 2026 for a documented opt-out from the use of de-identified call content to improve its models.
A written retention period for our own mailboxes (row 5), including a rule for the system alerts that can carry a transcript.

Version

Register version 2026-11-07. Change log: 2026-11-07 — row 10 (Anthropic) changes in two ways. It gains a second purpose of Callper's own: the builder on callper.ai, where a visitor names a business's website, Callper's software reads up to six of its public pages and Anthropic's model returns the business profile a draft assistant is built from; Callper is the controller, and the draft is kept 7 days unless the visitor signs up and keeps it. And it becomes a Sub-processor of Customer Data for one purpose: when a business that uses Callper asks, after signing up, for an assistant built from its own website, the same reading of up to six public pages returns the profile the business confirms before use. For that purpose Anthropic receives the extracted text of those pages and nothing else: no caller data, no uploaded document, no call content; it deletes inputs and outputs within 30 days, may not train on them, and the transfer rests on Standard Contractual Clauses (transfer impact assessment in the DPA's Annex 3). This is a change under the DPA's sub-processor clause: every account owner is emailed at least 30 days before this date and may object within that time; the DPA's Annex 3 lists Anthropic among the Sub-processors accordingly. 2026-10-06 — the retention note in section 2 says that recordings are off for every business's calls and that the one recorded line is Callper's own public voice demo in English, kept 30 days in Telnyx's Germany region (privacy policy, section 3). 2026-10-05 — rows 1 to 1c (Telnyx LLC) are restated after Telnyx's written answers and its published documentation: the speech-to-text, the language model and the voices all run on Telnyx's own infrastructure, so Deepgram and the other model authors receive nothing and are no longer described as Telnyx's sub-processors; Inworld voices, the one engine Telnyx lists as third-party, are withdrawn from the voice picker, where no assistant used one; Telnyx is certified under the EU-U.S. Data Privacy Framework, with the Standard Contractual Clauses as the fallback; a call is processed live at the Telnyx site nearest to it, which is not guaranteed to be in the European Union and is not the United States as a rule, as this page said before; and what Telnyx stores for Callper is stored in Germany. Rows 4 (Scaleway), 6 (Infisical) and 8 (HubSpot) state that their agreements are part of terms already accepted, and rows 8 and 9 state the Data Privacy Framework answers read on 28 September 2026; row 9 (Cal.com) records the agreement signed on 29 September 2026. Five open items are closed. No vendor is added: one possible recipient, Inworld, is removed. 2026-10-01 — row 11 added: Bouncer Sp. z o.o. (Poland), Callper's processor for checking, once and before the first email, that the address it found for a business it contacts first exists; it receives the address alone, processes it in the European Union and keeps it for at most 60 days. It receives no caller data and nothing a business entrusts to Callper, so it is not a Sub-processor under the DPA and no notice under the DPA's sub-processor clause is owed; the DPA's Annex 3 names it among the vendors listed for completeness. 2026-09-30 — row 10 added: Anthropic Ireland, Limited, with Anthropic, PBC in the United States behind it, as Callper's processor for the replies businesses send to the emails Callper writes to them first. Its AI model sorts each reply and writes Callper's answer when the answer is on Callper's sheet of facts about itself, signed "Callper's AI Assistant", and anything else goes to a person. It receives no caller data and nothing a business entrusts to Callper, so it is not a Sub-processor under the DPA and no notice under the DPA's sub-processor clause is owed; the DPA's Annex 3 names it among the vendors listed for completeness. 2026-09-29 — 2026-09-29 — Book a demo moves to a page HubSpot hosts, so row 8 (HubSpot, Inc.) also holds the booking page and the demo bookings made on it; row 9 (Cal.com, Inc.) takes no new bookings and is kept only for the demo bookings made before the move, until that account is closed, when the row is removed. No vendor is added or removed yet. 2026-09-29 — row 7 names the host by its legal entity, TES EURO MEDIA SRL (Gazduire.Net), with its registration numbers and data centre, and records what its Article 28 agreement and its written answers say: the host takes daily and weekly backup copies of the whole server, kept in Bucharest and possibly at Impossible Cloud GmbH in Germany, encrypted before they leave; so data Callper has erased may survive in a host backup for up to 31 days more. No vendor is added or removed: the entity was always this one, under the label on the server. 2026-09-25 — row 8 (HubSpot, Inc.) also sends the emails Callper writes to businesses it contacts first, through Callper's own mailbox with no open or click tracking, and may place its calls to them, unrecorded; the notes and the unsubscribe are kept on the record. No vendor is added or removed. 2026-09-25 — rows 8 (HubSpot, Inc.) and 9 (Cal.com, Inc.) state how long a demo booking is kept, 12 months after the last exchange, and row 8 what happens to the page views of a visitor who never signs up. No vendor is added or removed. 2026-09-25 — row 1 (Telnyx LLC) is also Callper's own processor for calls to the public voice demo on callper.ai and its phone number, where Callper is the controller, and those conversations are deleted after 30 days. No vendor is added or removed. 2026-09-25 — rows 5 (Google) and 8 (HubSpot, Inc.) also hold the contact details of businesses Callper contacts first, found on their own websites and on OpenStreetMap, and the emails exchanged with them; row 8 states how long they are kept. No vendor is added or removed, and no data a business entrusts to Callper moves. 2026-09-22 — row 1 (Telnyx LLC) also holds the nightly database backup, encrypted on Callper's server before it is uploaded and stored in Telnyx Cloud Storage's eu-central-1 region; row 7 (DirectHost) no longer holds the backups alone. No vendor is added or removed by this change: the destination is a service of a Sub-processor already on the register. 2026-09-21 — row 5 changes vendor: our own mailboxes moved from Zoho Mail to Google Workspace, so the entity, the country and the transfer footing on that row all change; the Zoho account was closed the same day, so Zoho holds no data of ours from 2026-09-21. 2026-09-20 — row 8 (HubSpot, Inc.) also names the contact number your business gives us at sign-up, on your company's record. 2026-09-20 — row 8 (HubSpot, Inc.) says that a sign-up under the analytics cookies joins the earlier visits to the account. 2026-09-18 — row 9 added (Cal.com, Inc., Callper's own account for demo bookings), and the note on Cal.com now tells that relationship apart from a business's own calendar connection; row 8 (HubSpot, Inc.) was added on 2026-09-16 with the analytics cookies. 2026-09-03 — first published version.