Sub-processors
Last changed · In force from 12 October 2026
These are the companies that process data for SisleLabs OOD ("Puncho") when it runs the service. The Data Processing Agreement says how we choose them and how we tell you before the list changes.
A sub-processor receives data only when the feature that uses it runs. If nobody in your workspace draws a picture with a given image model, that model's maker receives nothing from it.
Sub-processors for workspace content
| Company | What it does for us | What it receives | Where |
|---|---|---|---|
| Hetzner Online GmbH | Runs the app and its database | Everything in a workspace | Nuremberg, Germany |
| Hetzner Online GmbH | Stores files | Every file in a workspace: references, brand assets, product photos, fonts, generated parts, finished ads, videos | Nuremberg, Germany |
| Anthropic | Writes ad concepts when someone presses Generate concepts on the board, and reads a reference ad when it is pasted onto the board | The brief; the brand's name, tone and look; product names, prices and details; excerpts of the brand's writing samples; the brand's own posts and their numbers; reference ads' hooks and advertiser names; rejected concepts with reasons; results by attribute; board notes; a pasted reference image | United States |
| Recraft | Draws pictures (the default image model) and removes backgrounds | The picture prompt, which holds the ad's words and the brand's visual notes; reference pictures; the image whose background is removed | United States |
| Google (Gemini API) | Draws pictures when that model is picked. Can also read a finished picture's words back, a check that is off unless we switch it on | The picture prompt and reference pictures; the finished picture, for that check | United States |
| OpenAI | Draws pictures when that model is picked | The picture prompt and reference pictures | United States |
A picture prompt is written from the concept and the brand's visual notes. Reference pictures are the brand's assets, an earlier render of the same concept, a reference ad whose layout is borrowed, or a design sent to have its lighting redone. A product photo is sent to Recraft when its background is removed.
Anthropic receives data in two cases. One is when someone in your workspace presses Generate concepts on the board. The other is when a reference ad is pasted onto the board: the picture and the notes typed with it are sent to be read, whichever plan the workspace is on. When your own AI app writes the concepts, those concepts do not go to Anthropic from us.
Who we contract with, and how long each keeps data
We do not use your content to train AI models. We reach every model through its maker's paid API, and under each maker's terms for that API what we send and what it returns are not used to train its models.
| Company | Who we contract with | How long it keeps what we send |
|---|---|---|
| Hetzner | Hetzner Online GmbH, Germany | Until we delete it. It is our database and our file storage |
| Anthropic | Anthropic Ireland, Limited | Up to 30 days. A request its safety systems flag as breaking its usage policy can be kept for up to 2 years |
| Recraft | Recraft Inc., United States | It does not store pictures made through its API after delivering them, and deletes results within 24 hours |
| The Google company named on our account for Europe | A limited period, to detect abuse. Google's terms give no number of days | |
| OpenAI | OpenAI Ireland Limited | Up to 30 days, in logs kept to detect abuse. A picture its scan flags as child sexual abuse material is kept for review |
These are the companies' own published terms as read on 12 October 2026. They can change them, and their terms decide, not this table.
Sub-processor for billing
| Company | What it does for us | What it receives | Where |
|---|---|---|---|
| Stripe | Takes card payments, issues invoices, works out VAT and checks VAT numbers against the EU's register | From us: the workspace's name and its internal number. From the buyer, on Stripe's own page: company name, billing address, company or VAT number, card details | Ireland and the United States |
For billing data we are a controller, and the Privacy Policy covers it. Stripe is listed here so the whole picture is in one place.
Stripe processes that data for us, and for some purposes of its own it is a controller: watching for fraud, meeting its legal duties such as checks against money laundering, and improving its products. Its data processing agreement is part of its terms of service.
Services you connect yourself
These are not our sub-processors. They receive data because you told Puncho to send it, and your own agreement with each covers what they do with it.
| Service | What it receives | When |
|---|---|---|
| Meta (Marketing API, Facebook Pages, Instagram) | The ad's picture or video, its words, link and button; campaign, ad set and ad names; budget; audience settings such as places and ages; for a post, the picture and caption | When you launch an ad or a scheduled post goes out |
| Meta (Ad Library search) | The search words and countries | When someone in your workspace searches for competitors' ads |
| An AI app or agent you connect, such as Claude, ChatGPT or Gemini | Whatever its tools read from your workspace: briefs, brand material, writing samples, concepts, designs, pictures, results | Whenever the app calls a tool, for as long as it is connected |
Requests that carry no customer data
Two kinds of request leave our servers without any workspace content, and we list them so nothing is left out:
- Google Fonts. When someone adds a font from the library, our server downloads it from Google. The request holds the font's name.
- A website you ask Puncho to read. Our server fetches the public pages, pictures and product list of the address you gave. The site sees a request from our server, not from you.
Not used
Puncho uses no analytics, advertising or error-tracking service, and no email delivery service: the app sends no email.
Changes to this list
We update this page before a new sub-processor receives customer data and tell the owners of each workspace, as the Data Processing Agreement sets out.