DullDocs Subprocessor and Transfers Notice
Last updated: 24 September 2026
This notice identifies the principal providers used to deliver DullDocs.
- Owner
- RJS & Partners LLP, trading as DullDocs
- Version
- 2026-09-24
- Effective date
- 24 September 2026
- Audience
- Customers, procurement teams and privacy advisers
Current subprocessors
DullDocs remains responsible for subprocessors under its customer DPA.
Lovable Cloud / Supabase
- Purpose
- Public website hosting and website-tool database services
- Information sent
- Website enquiries, free-scan contact details and results, calculator configuration and related events; separate from the application workspace database
- Location
- Website database region is being verified; no UK-only or EU-only claim is made for this service
PostHog
- Purpose
- Product analytics: how DullDocs is used, so it can be improved
- Information sent
- Counts and timings against a code that stands for your organisation, and a code that stands for a signed-in user. Never document contents, file names, dates read from your documents, decision reasons, staff or children’s names, email addresses, page addresses or IP addresses. No session recording, no screen capture and no cookies.
- Location
- European Union (PostHog Cloud EU)
Cloudflare
- Purpose
- Public website delivery, DNS and edge security
- Information sent
- Requests to our public pages, including IP address and user agent
- Location
- Global edge network
Render
- Purpose
- Background processing for Ofsted Inspector Briefings
- Information sent
- Published Ofsted inspection data and briefing job records. It holds no credential for the DullDocs application database, so it never sees your documents, staff records or evidence.
- Location
- Frankfurt, EU
Vercel
- Purpose
- Application hosting and document file storage (Vercel Blob)
- Information sent
- All application traffic; uploaded document files
- Location
- Application functions run in Dublin, EU (dub1). Document files are held in a private store in Dublin, EU (dub1). Files uploaded before 3 September 2026 were previously held in Washington DC, US (iad1); they have all been moved, and no customer document, extracted text or staff photograph is held outside the EU. Organisation logos, which are published material, remain in the older store.
MongoDB Atlas
- Purpose
- Database (organisation, requirement, staff-record and document metadata)
- Information sent
- Application data, including extracted document text and staff records
- Location
- Region is being verified; no UK-only or EU-only claim is made for this service
Stripe
- Purpose
- Payments and subscription billing
- Information sent
- Billing contact details and payment information (card data is entered directly with Stripe)
- Location
- EU/US (global payment infrastructure)
Resend
- Purpose
- Transactional email (reminders, document requests, acknowledgements, declarations) and receiving documents emailed to your DullDocs address
- Information sent
- Recipient name and email address, plus the message content of each notification; and, where you use email-in, the emails sent to your DullDocs address, including their attachments
- Location
- EU/US
WhatsApp (Meta), via a self-hosted WhatsApp gateway reached through an ngrok tunnel
- Purpose
- Internal alerts to the DullDocs team when something happens on an account (a new sign-up, a payment, a failed card, a cancellation, a support request)
- Information sent
- Account facts only: your organisation name, the name and email address of the person on the account who triggered the event, the plan, amounts charged or refunded, how many settings you hold, and the domain of anyone invited to your team. For inspector briefings it also includes the inspector reference you bought a briefing about. Never documents, never their contents, and never the text of a support message.
- Location
- Global (Meta)
ngrok
- Purpose
- Tunnel that carries the internal alerts in the WhatsApp row above from the application to the self-hosted WhatsApp gateway
- Information sent
- The text of each of those internal alerts passes through the tunnel: account facts only, never documents, never their contents, and never the text of a support message.
- Location
- Not verified; no location claim is made for this service
OpenAI / Anthropic (whichever is configured)
- Purpose
- AI document classification, date and name extraction, evidence checks, reading scans and photographs, the Ask DullDocs assistant, report summaries and recommendations, chase email drafts and Projects
- Information sent
- For each document with readable text: the first 6,000 characters of its text with the filename, to classify it; the first 6,000 characters plus, for a longer document, up to 4,000 characters of later passages that introduce a person (up to 10,000 in all), without the filename, to read dates and names; and, when it matches one of our standard requirements, the first 5,000 characters with the requirement, organisation and setting names, without the filename, for the evidence check. Assume this applies to every document we can read text from. For photographs and PDF scans with no readable text, the image or PDF file itself is sent automatically on upload, without the filename, up to 12 MB and 20 pages per call; what the provider reads from it then goes through the same three calls. Scans longer than 20 pages are sent in parts of up to 20 pages, to a maximum of 60. For an organisation that has accepted the DullDocs Terms of Service and Customer Data Processing Agreement dated 24 September 2026, a complete-document analysis also sends the extracted text of every page, with the filename, to find restrictions, missing dates and integrity problems, but only once DullDocs switches it on for that organisation, which its Legal agreements page in Settings shows; it is not made for photographs or scans. Ask DullDocs sends your question with requirement names (including your own custom requirement names), categories, severities, statuses, dates and setting names, status counts, and staff names, job roles and statuses (inactive staff by job role and status only). Report summaries send status counts, the readiness score and up to eight requirement names. Drafting a chase email sends the requirement name or action title, not the due date. Projects send the project type, name, goal, location and setup answers you type; drafting a project support document also sends the setting name and the checklist and linked requirement titles.
- Location
- United States
Companies House API
- Purpose
- Company-name lookup during signup
- Information sent
- The company name or number you type: public-register data only, no staff or document data
- Location
- UK
Google Maps Places
- Purpose
- Address autocomplete on site/address forms
- Information sent
- The address text you type into an address field
- Location
- Global (Google)
Microsoft (OneDrive)
- Purpose
- Optional read-only cloud-drive import
- Information sent
- Files in the folders you explicitly select, read-only
- Location
- Your Microsoft tenant
Used only if you connect it.
Google Drive
- Purpose
- Optional read-only cloud-drive import
- Information sent
- Files you explicitly select (least-privilege drive.file scope by default), read-only
- Location
- Your Google account
Used only if you connect it.
International transfers
DullDocs is operated from the UK, but processing is not limited to the UK. Application functions and the private document store are in Dublin, EU. Files uploaded before 3 September 2026 were previously held in Washington DC, United States; those customer files have been moved into the private EU store. Published organisation logos remain in the older store.
Our automated processing providers, OpenAI and/or Anthropic, are based in the United States. Document content, including special-category or criminal-offence data where present, may be transferred there for the AI features described above. Email, payments and global infrastructure providers can also process information outside the UK. EU storage does not mean that every provider processes information only in the EU.
Transfers outside the UK require an applicable UK adequacy arrangement or another valid transfer mechanism, such as the UK International Data Transfer Agreement or UK Addendum to the EU Standard Contractual Clauses, with any required assessment. We are completing verification of the transfer terms incorporated in each AI provider’s account-level agreement, including retention and model-training settings. We do not currently describe those account-level terms as verified. Contact privacy@dulldocs.com to request information about the safeguards relevant to your data or a copy where available. We will update the notice when the position is confirmed.
Subprocessor changes
Customers give general authorisation under the DPA. DullDocs will provide at least 14 days' notice before a new subprocessor begins processing Customer Personal Data, except where an urgent security or continuity replacement is required. A customer may object on reasonable data-protection grounds during the notice period.
Contact and change notifications
Questions and objections should be sent to privacy@dulldocs.com. The version accepted with the customer contract is retained in the customer audit record.
Versions
- Version 2026-09-24, effective (current)