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Sub-processor Register

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Flusso R&D Tax Platform: Sub-processors

This page lists the third-party service providers ("sub-processors") that may process personal information on our behalf to run Flusso R&D Tax Platform. It is referenced from our Privacy Policy (section 6, section 7).

Last updated: 9 November 2026

Flusso Pty Ltd (ABN 86 651 038 078, ACN 651 038 078) uses the sub-processors below. Each is engaged under a written agreement requiring confidentiality and protections consistent with our Privacy Policy and the Australian Privacy Principles. Your primary database records are held in Australia (Sydney); other providers, listed below, may process information overseas.


Sub-processor register

Each row names the provider, its function, the data it processes, its processing location, and the in-repo evidence (a worker binding or a package dependency) that shows it is actually wired. A machine-readable version of this list is docs/legal/rdtp-data-map.json, and scripts/check-data-map.ts fails CI if a provider or binding in the code is missing here.

ProviderFunctionData processedProcessing locationEvidence
AWS RDS (Sydney)Primary application database (account and claim records)Account, organisation and RDTI claim recordsAustralia (Sydney, ap-southeast-2)infrastructure/src/aws/rds.ts; reached via the HYPERDRIVE binding
Cloudflare R2File object storage (source library, audit exports, RFI correspondence, firm assets), being migrated to AWS S3 Sydney under Story 338-14Documents and files you or your advisor upload or generateOceania location hint (best effort), migrating to Australia (Sydney)apps/api-rdti/wrangler.toml R2 bindings R2_SOURCE_LIBRARY, RDTI_AUDIT_EXPORT_BUCKET, RDTI_RFI_CORRESPONDENCE_BUCKET, FIRM_ASSETS_BUCKET
Cloudflare WorkersApplication compute, key-value cache, queues and internal service bindingsRequest data in transit during processingUnited States / global edgeapps/api-rdti/wrangler.toml service, KV and queue bindings
ClerkAuthentication and identity managementName, email, roleUnited States@clerk/nextjs dependency in apps/rdti/web/package.json
ResendTransactional and service emailEmail address, message contentUnited States@flusso/email dependency (reaches api.resend.com over HTTPS) in apps/api-rdti and apps/rdti/web
StripeBilling and paymentsBilling and account detailsUnited States / globalstripe dependency in apps/api-rdti/package.json
AnthropicAI features (large language model), drafting and analysis of R&D claim contentThe content you submit to AI featuresUnited States@anthropic-ai/sdk dependency in apps/api-rdti/package.json
UpstashCaching and rate limitingTransient operational dataUnited States@upstash/redis dependency in apps/api-rdti, apps/api-connect and apps/rdti/web
VercelWeb application hostingRequest data in transit for the web appUnited Statesinfrastructure/src/vercel/projects.ts (hosts apps/rdti/web)
HubSpotSupport-ticket syncSupport request content and contact detailsUnited StatesExternal (support requests sync server-side via the gateway; Stories 174-6 and 174-7)

Note on Cloudflare R2 location. Cloudflare R2 has no Australian jurisdiction. The buckets above use the OC (Oceania) location hint, which is a best-effort placement hint, not a jurisdictional guarantee. Story 338-14 moves these file objects to AWS S3 Sydney (ap-southeast-2): the staging environment completed the move on 5 November 2026 and production follows under the operator-supervised runbook. This register is updated to name AWS S3 Sydney as the file-object store when the production cut-over is verified.

Infrastructure and operational processing (non-record copies)

The providers below process requests in transit or hold operational data only. They do not hold a durable copy of your account or claim records. They are listed here, and in the data map with recordCopy: false, for completeness.

ProviderFunctionData processedProcessing locationEvidence
Cloudflare HyperdriveConnection pooling and short-lived read caching (at most sixty seconds) in front of the AU databaseQuery results in transitUnited States / global edgeapps/api-rdti/wrangler.toml HYPERDRIVE binding
AWS Logpush S3 sinkExternally provisioned AU log sink (operational logs, not Claimant Data)Request and operational logsAustralia (Sydney, ap-southeast-2)infrastructure/src/cloudflare/logpush.ts

Artificial intelligence

The AI provider (Anthropic) is named in the register above and described in Privacy Policy section 5.

We do not currently use your content to train these providers' models or our own. The providers' retention of your inputs, and the commitment that they are not used to train their models, are subject to verification before this page is published. See Privacy Policy section 5.

These providers process your information only if you connect the corresponding integration to import data into Flusso R&D Tax Platform. If you do not link a connector, it processes nothing.

ProviderFunctionData processedProcessing location
XeroImport general-ledger / accounting data for R&D expense classificationCompany financial data you authoriseAustralia / New Zealand / global
Google (Drive)Import R&D evidence documents from folders you nominateDocuments you authoriseUnited States / global
Microsoft (OneDrive)Import R&D evidence from resources you nominateDocuments you authoriseUnited States / global
Atlassian (Confluence)Import R&D evidence from spaces you nominatePages you authoriseUnited States / global
GitHubImport development evidence from repositories you nominateRepository evidence you authoriseUnited States

Changes to this list

We may update this list as our services change. Where we add a sub-processor that materially affects how your personal information is handled, we will update this page and its "Last updated" date. To be notified of changes, contact privacy@flusso.ai.