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Subprocessors

Every third party that can touch customer data in Qua, what it receives, and where it processes it. This list is referenced by our Data Processing Agreement and kept in step with the product.

Last updated: August 25, 2026Applies to: qua.dev and the Qua application
  1. 1. About this list
  2. 2. Infrastructure and platform
  3. 3. Model providers — United States
  4. 4. Model providers — outside the US and EU
  5. 5. Retrieval, media and communications
  6. 6. Contractual safeguards
  7. 7. Change notifications and objections
  8. 8. Contact

1. About this list

A subprocessor is a third party engaged by Qua that may process personal data contained in customer content. This page is the authoritative, current list referenced by our Data Processing Agreement and satisfies our transparency obligations under Article 28(2) of the GDPR and the equivalent provisions of the UK GDPR, the CCPA/CPRA and India's DPDP Act.

It mirrors the data-flow documentation we maintain internally: every provider that can receive customer content is listed here, together with what it receives and where it processes it. When we add a provider to the product, this page is updated in the same change. Last updated August 25, 2026.

2. Infrastructure and platform

These processors host the Qua application and its primary data stores. They are required to deliver the service and cannot be disabled per customer.

SubprocessorPurposeData it can receiveProcessing location
Lovable Labs Incorporated (Lovable Cloud)Application hosting, build and deploy pipeline, managed backend orchestrationAccount data, session metadata, application logsUnited States
Supabase Inc. (managed through Lovable Cloud)Primary database, authentication, file storage, vector indexAccount and organization records, session and message content, uploaded knowledge sources and their embeddings, audit ledgersAustralia (AWS ap-southeast-2)
Amazon Web Services, Inc.Underlying compute and storage for the managed database regionAll data at rest for the managed databaseAustralia (ap-southeast-2)
Cloudflare, Inc.Edge delivery, TLS termination, DDoS protection, bot mitigation (Turnstile on public demo forms)IP address, request metadata, challenge tokensGlobal edge network

3. Model providers — United States

Prompt content, selected knowledge excerpts and conversation history are sent to the model chosen for a turn. Qua does not use customer content to train models, and contracts with these providers prohibit training on API inputs by default.

SubprocessorPurposeData it can receiveProcessing location
Lovable AI GatewayRouting layer in front of Google and OpenAI hosted modelsPrompt and completion content, token countsUnited States
Google LLC (Gemini models)Model inference, grounded answering, embeddingsPrompt and completion content, selected source excerptsUnited States
OpenAI, L.L.C.Model inference and image generationPrompt and completion content, image promptsUnited States
Anthropic PBCModel inference (Claude family)Prompt and completion contentUnited States
Groq, Inc.
Open Models tier — only when a user explicitly selects one of these models
Serving of open-weight modelsPrompt and completion contentUnited States

4. Model providers — outside the US and EU

These models are never selected automatically. They sit in the Open Models tier and are reached only when a user explicitly names one, and an organization administrator can switch the tier off entirely. Data sent to them may be processed in mainland China or Singapore, outside the EEA, the UK and the United States.

SubprocessorPurposeData it can receiveProcessing location
Hangzhou DeepSeek Artificial Intelligence Co., Ltd.
Off by default at organization level; explicit user selection required
Model inference (DeepSeek Chat / Reasoner)Prompt and completion contentChina
Alibaba Cloud (Qwen)
Off by default at organization level; explicit user selection required
Model inference (Qwen family)Prompt and completion contentChina / Singapore
Moonshot AI (Kimi)
Off by default at organization level; explicit user selection required
Model inference (Kimi family)Prompt and completion contentChina

Never automatic. These providers sit in the Open Models tier. Qua's resolver never selects them; a user must name the model, and an organization administrator can disable the tier for the whole organization. Data sent to them may be processed in mainland China, outside the EEA, the UK and the United States, where no adequacy decision applies. Organizations with cross-border restrictions should disable the tier.

5. Retrieval, media and communications

These processors are engaged only for specific features. If the feature is not used, no data reaches the processor.

SubprocessorPurposeData it can receiveProcessing location
Firecrawl (Sideguide Technologies, Inc.)
Only when web research is enabled for a session
Web search and page retrieval for research sessionsSearch queries derived from the promptUnited States
Exa Labs, Inc.
Only when web research is enabled and routed to this provider
Secondary web search providerSearch queries derived from the promptUnited States
ElevenLabs Inc.
Only when audio narration is generated
Text-to-speech narration for tutorials and audio overviewsNarration script textUnited States

6. Contractual safeguards

  • Every subprocessor is engaged under a written contract with data protection terms no less protective than our own.
  • Model providers are contracted on API terms that prohibit training on inputs.
  • Transfers out of the EEA and the UK rely on Standard Contractual Clauses and the UK Addendum, supported by a transfer impact assessment, unless an adequacy decision applies.
  • We assess each provider's security posture before onboarding and review it periodically.
  • We remain liable to our customers for the acts and omissions of our subprocessors.

7. Change notifications and objections

Customers may subscribe to subprocessor change notices by emailing privacy@qua.dev with the subject "Subprocessor notifications". We give at least 30 days' notice before a new subprocessor begins processing customer personal data.

A customer may object on reasonable data-protection grounds within that period. We will work in good faith to offer a configuration that avoids the provider — for most optional providers this is a toggle in the admin console. If no reasonable alternative exists, the customer may terminate the affected subscription and receive a pro-rata refund of prepaid, unused fees.

8. Contact

Questions about this list, or a request for the underlying data-flow documentation: privacy@qua.dev. Data protection contact: dpo@qua.dev. See also the Data Processing Agreement and the Privacy Policy.

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