Neogenic Subprocessors
Scality Ltd uses the following companies to provide Neogenic. Each processes clinic data to deliver its part of the service, under a data processing agreement with us; where a company also uses data under its own terms, its row says so. Your primary data is stored in the European Union. Health data that a clinic stores in the places our Terms of Service allow (section 2.3) is processed only by the companies on this list whose row says so, and, for calendar sync, by the Google or Microsoft account that your staff connect (section 6.1 of our Terms of Service). We notify each clinic's privacy contact at least 14 days before adding or replacing a subprocessor.
Subprocessor list
| Company | What it does for Neogenic | Data location | Transfer safeguard | May receive health data |
|---|---|---|---|---|
| Amazon Web Services EMEA SARL (Luxembourg) | Hosting: application servers, background processing, the web apps, Forms, the Neogenic admin console, the queue and logs | EU (Frankfurt, Germany) | EU Standard Contractual Clauses, for any access from outside the EEA | Yes |
| Amazon Web Services EMEA SARL (Luxembourg): Amazon Bedrock | Runs the Anthropic Claude models that generate Neo's responses and read files shared with Neo. It is set to zero data retention: no request or answer is written to durable storage or shared with the model provider, and none is used to train models. To answer faster, Bedrock keeps a short-lived cache of a conversation, scoped to Scality's AWS account and the EU region that processed it; the caches Neogenic sets end at most 1 hour after their last use. AWS may keep content that its automated checks flag as child sexual abuse material, in order to report it. | EU: requests are sent to Frankfurt, Germany, and may be processed in any of six EU regions | EU Standard Contractual Clauses, for any access from outside the EEA | Yes |
| Amazon Web Services EMEA SARL (Luxembourg): Amazon Simple Email Service | Sending all email to patients: booking confirmations and reminders, Patient Portal sign-in codes and invitations, invoice links and access codes, card sign-up links and form verification codes | EU (Frankfurt, Germany) | EU Standard Contractual Clauses, for any access from outside the EEA | Yes |
| Supabase Pte. Ltd. (Singapore) | Database, sign-in and file storage | EU (Stockholm, Sweden); its service logs may be held by its own subprocessors outside the EU | EU Standard Contractual Clauses | Yes |
| Twilio Inc. (SendGrid) | Sending email from Neogenic to clinic staff, such as invitations and notices. It sends no email to patients | United States | EU–US Data Privacy Framework; EU Standard Contractual Clauses | No. Under its own terms, Twilio also uses email content as an independent controller, for the security of its service and to prevent abuse |
| Stripe Payments Europe, Ltd. (Ireland), with Stripe, Inc. | Online card payments for the Clinic's invoices and memberships, when the Clinic connects its own Stripe account; receives the email address on the invoice, the invoice number, the amount, the currency and Neogenic's reference numbers. For these payments Stripe also works under its own agreement with the Clinic (DPA section 2.8) | EEA (Ireland); United States | EU–US Data Privacy Framework; EU Standard Contractual Clauses | No |
| Cloudflare, Inc. | Domain name service (DNS); bot protection (Turnstile) on a public form when the Clinic turns it on, which receives the form visitor's IP address and browser signals; in production, a form with it switched on accepts no submissions yet | Global | EU Standard Contractual Clauses | No |
Not our subprocessors
Google and Microsoft accounts that your staff connect to Neogenic for email and calendar are your own services under your contract with them. Neogenic acts on them only as your staff instruct, or as calendar sync does (section 6.1 of our Terms of Service).
Scheduling tools you embed in your forms, such as your own Calendly account, are also your own services: the form visitor's browser connects to them directly.
If you choose to sign in with Google, Google handles that sign-in under its own terms and privacy policy.
Change history
23 Oct 2026: corrected the Amazon Bedrock row to describe its short-lived prompt cache and AWS's one retention exception. No new subprocessor and no new kind of processing.
Previous versions: Version 9 (22 October 2026), Version 8 (16 October 2026), Version 6 (15 October 2026), Version 5 (9 October 2026), Version 4 (1 October 2026), Version 3 (30 September 2026), Version 2 (30 September 2026), Version 1 (24 September 2026)