This page (the “Subprocessor Page”) identifies the Subprocessors that Innovative Data Processing Solutions LLC (“Innovative”) engages to process Customer Personal Data in providing the MRS Services, and where they process it. It is maintained under Section 7.3 of the Darcy Dispatch Data Processing Addendum (the “DPA”) and Section 9.8 of the Innovative Managed Routing Service (MRS) Terms and Conditions (the “MRS Terms”), and forms part of the Agreement. Capitalized terms not defined on this page have the meanings given in the DPA or the Agreement.

1. SCOPE

1.1 What This Page Covers. A Subprocessor is any third party that Innovative engages to process Customer Personal Data, meaning Personal Data contained in the prompts Customer submits to Darcy Dispatch and in the outputs returned to Customer. Each Subprocessor listed on this page may receive Customer Personal Data in the course of serving a Metered Request.

1.2 What This Page Does Not Cover. Innovative processes Account Data and Service Records as an independent business under Section 2.2 of the DPA. Vendors that receive only Account Data or Service Records, such as providers of billing, metering, analytics, observability, and database services that store usage records but not the text of prompts or outputs, are not Subprocessors and are not listed on this page. Their processing is described in Innovative’s privacy policy. Providers of model provider keys that Customer adds to Darcy Dispatch are also not Subprocessors, as described in Section 8.

1.3 Location. Darcy Dispatch, its cloud infrastructure, and its supporting services process Customer Personal Data in the United States only. Inference routers and Underlying Model Providers process Customer Personal Data in the Approved Processing Jurisdictions listed in Section 3.1 or, while Customer has U.S.-Only Processing enabled, in the United States only.

2. PROVIDER STANDARDS

Each inference router and Underlying Model Provider listed on this page is engaged under written terms that meet the Provider Standards in Section 9.4 of the MRS Terms, including:

2.1 No Training. Customer Personal Data and Customer Content are not used to train, fine-tune, or otherwise improve any artificial intelligence or machine learning model.

2.2 Processing Location. Customer Personal Data is processed and, where stored at all, stored only in the Approved Processing Jurisdictions or, while U.S.-Only Processing is enabled, only in the United States.

2.3 Zero Data Retention. Prompts and outputs are not retained after the response is returned, other than transiently as needed to process the request or as required by law.

2.4 Restricted-Party Screening. No Subprocessor is based in, or controlled from, a country of concern under 28 C.F.R. Part 202.

3. PROCESSING LOCATIONS

3.1 Approved Processing Jurisdictions. While U.S.-Only Processing is off, inference that Innovative provides may be processed in the following countries (the “Approved Processing Jurisdictions”) under Section 9.8 of the MRS Terms:

3.2 Never Included. The Approved Processing Jurisdictions never include a country of concern under 28 C.F.R. Part 202, a country or region subject to comprehensive U.S. sanctions, any member state of the European Economic Area, the United Kingdom, Switzerland, or Australia.

3.3 U.S.-Only Processing. Customer may turn on U.S.-Only Processing for its account at any time in Darcy Dispatch (Settings → Data & security). While it is on, inference is routed only to inference routers and Underlying Model Providers that process requests, and store any retained data, in the United States. U.S.-only processing generally costs more, so Customer’s savings will typically be lower while it is on. Customer controls this setting and is solely responsible for choosing it, as described in Section 9.8 of the MRS Terms.

3.4 Per-Request Records. Darcy Dispatch records the country in which each request is processed and shows it to Customer.

4. INFERENCE ROUTERS

Inference routers receive prompts and outputs from Darcy Dispatch and transmit them to an Underlying Model Provider. They do not host model weights.

4.1 Additional Inference Routers. Innovative may engage additional inference routers that meet the Provider Standards and will add each one to this page before it processes Customer Personal Data.

5. UNDERLYING MODEL PROVIDERS

Underlying Model Providers perform AI model inference on prompts and return outputs. Prompts and outputs reach them through an inference router listed in Section 4, or directly where a router is not used.

5.1 Other Underlying Model Providers. Darcy Dispatch may route requests to other providers of AI model inference that meet the Provider Standards. Because Underlying Model Providers change frequently, providers not listed in the table above are identified by category only, as described in Section 7.3 of the DPA. Each processes Customer Personal Data only in the Approved Processing Jurisdictions or, while U.S.-Only Processing is enabled, only in the United States.

6. SUPPORTING SERVICES

7. CLOUD INFRASTRUCTURE

8. YOUR OWN PROVIDER KEYS (BYOK)

8.1 Not Subprocessors. When Customer adds its own model provider keys to Darcy Dispatch, requests sent through those keys are processed by Customer’s own providers under Customer’s agreements with them. Those providers are Customer’s vendors, not Subprocessors of Innovative, and the Provider Standards, the Approved Processing Jurisdictions, and the U.S.-Only Processing setting do not apply to them (MRS Terms, Section 9.7, and DPA, Section 2.4).

9. CHANGES AND OBJECTIONS

9.1 Updates. Innovative may change its Subprocessors and the Approved Processing Jurisdictions at any time and will update this page to reflect each change, including the Last Updated date above and the Change Log in Section 10. Changes take effect when posted.

9.2 Objections. To the extent U.S. Privacy Laws require it, Customer may object to a change on reasonable data protection grounds by written notice within fifteen (15) days after this page is updated, as described in Section 7.4 of the DPA. The parties will discuss the objection in good faith. If they cannot resolve it, Customer’s sole remedy is to stop using, or terminate, the affected MRS Services, and no Early Termination Fee applies to a termination under that Section. Customer may also turn on U.S.-Only Processing at any time under Section 3.3.

9.3 Responsibility. Innovative remains responsible for its Subprocessors as described in Section 7.5 of the DPA.

9.4 Archive. Innovative keeps a dated archive of each version of this page and will provide a prior version on request.

10. CHANGE LOG