Sub-Processor List

Last updated: March 11, 2026

This page lists the Sub-processors that Pom Labs, Inc. ("POM") uses to Process Personal Data on behalf of its Customers in connection with the POM platform (the "Service"). This list is maintained in accordance with POM's Data Processing Agreement ("DPA").

Capitalized terms used in this page have the meanings given to them in the DPA or the POM Terms of Service.


Notification of Changes

POM provides at least thirty (30) days' advance notice before authorizing any new Sub-processor to Process Personal Data. Notifications are sent by email to subscribed contacts and this page is updated concurrently.

Subscribe to Notifications

To receive advance notice of Sub-processor changes, send an email to:

[email protected]

Include "Subscribe" in the subject line and the email address(es) you wish to register for notifications.

Objection Process

Customers may object to a new Sub-processor within thirty (30) days of receiving notice, in accordance with the DPA (Section 6.4 — Sub-processor Objections). Objections must:

  • Be submitted in writing to [email protected]
  • State reasonable grounds related to data protection
  • Be received within the thirty (30) day Notification Period

POM will work in good faith to resolve objections. If an objection cannot be resolved, Customer may terminate the affected portion of the Service and receive a prorated refund of prepaid fees. Full details of the objection and resolution process are set forth in the DPA.


Current Sub-processors

POM-Managed AI Model Providers

These Sub-processors receive and process Customer Data (prompts, files, documents, and agent outputs) to provide AI inference as part of the Service. POM selects, contracts with, and maintains data processing agreements with each POM-Managed Provider.

Sub-processorEntity TypePurposeData ProcessedLocationData RetentionNo-Training Commitment
Anthropic, PBCUS public benefit corporationAI model inferenceCustomer prompts, files, documents, agent outputsUnited States7 days (API logs), then deletedYes — API and commercial data is not used for model training. Zero Data Retention (ZDR) available for Enterprise customers via negotiation with Anthropic.
OpenAI, LLCUS limited liability companyAI model inferenceCustomer prompts, files, documents, agent outputsUnited States30 days (API logs), then deletedYes — API and business data is not used for model training by default. Note: OpenAI's terms permit processing of de-identified, anonymized, or aggregated data to improve its systems.
Google LLCUS corporation (Alphabet subsidiary)AI model inferenceCustomer prompts, files, documents, agent outputsUnited States55 days (abuse monitoring retention only), then deletedYes — paid API tier only. Important: POM exclusively uses Google's paid API tier, where Customer Data is not used for model training or improvement. Google's unpaid/free tier does use data for training; POM does not route Customer Data through unpaid tiers.

How Customer Data Flows to AI Providers

When your agents run on POM, Customer Data (such as prompts, documents, and files) is processed by the POM platform, which handles orchestration, permissions, and budget enforcement. POM then routes the data to an AI model provider in one of two ways:

  1. POM-Managed Providers — POM sends the data to one of the providers listed above via their paid/commercial API tier. POM holds a DPA with each provider, and contractual no-training commitments apply.
  2. Customer-Configured Providers — If you have configured your own provider (e.g., your own API keys or a self-hosted model), POM passes the data through to that provider on your behalf. Your own terms with that provider govern; POM acts as a technical pass-through only.
  3. POM Internal Models — POM may process Customer Data through its own internal machine learning models for operational purposes such as model routing optimization, query classification, and cybersecurity (e.g., threat detection and content filtering). These models do not generate agent outputs returned to the Customer; they support the platform's routing, classification, and security functions. POM does not use Customer Data processed by internal models for model training.

In all cases, the AI model output is returned to you via POM. All data in transit is encrypted over HTTPS/TLS.

Key commitments across all POM-Managed Providers:

  • POM uses only paid or commercial API tiers that include contractual no-training commitments
  • Customer Data is used solely for the purpose of generating AI model responses and is not incorporated into model training datasets
  • All data transmission to AI providers occurs over encrypted connections (HTTPS/TLS)
  • Each POM-Managed Provider maintains its own DPA with POM imposing data protection obligations substantively no less protective than POM's DPA with Customers

Customer-Configured Providers

The POM platform allows Customers to configure connections to third-party AI model providers or model routing services that are not managed by POM. This includes supplying your own API keys, connecting to third-party routing services, or using self-hosted models.

Customer-Configured Providers are NOT Sub-processors of POM. POM does not select, vet, contract with, or maintain data processing agreements with Customer-Configured Providers.

AspectPOM-Managed ProvidersCustomer-Configured Providers
Selected byPOMCustomer
DPA with POMYesNo
No-training commitmentYes (contractually enforced)Customer must verify independently
Listed on this pageYesNo
Data retention knownYes (see table above)Customer must verify independently
Sub-processor change notificationYes (30 days for Enterprise)Not applicable
POM liabilityPer ToS and DPAPOM acts as technical pass-through only

When Customer Data is routed to a Customer-Configured Provider, POM acts solely as a technical pass-through. Customer is solely responsible for evaluating the provider's data handling, training practices, security, and compliance with applicable law. For full terms, see Section 4.3 of the Terms of Service.


Infrastructure Sub-processors (Active)

Sub-processorEntity TypePurposeData ProcessedLocationStatus
Amazon Web Services, Inc.US corporation (Amazon subsidiary)Cloud hosting, compute, and storage for POM platform infrastructureCustomer Data processed within POM execution environmentsUnited StatesActive
Cloudflare, Inc.US corporationCDN, DDoS protection, and edge networking for POM web applicationsRequest metadata, IP addresses, cached contentUnited States / Global edgeActive
Stripe, Inc.US corporationPayment processing, subscription billing, and card handlingPayment card data, billing information, transaction recordsUnited StatesActive — PCI DSS Level 1 certified. Stripe's DPA is incorporated. Customer payment card numbers are collected and stored by Stripe directly; POM does not receive or store full card numbers.

Removed Sub-processors

No Sub-processors have been removed to date.

Sub-processorDate RemovedReason
———

Contact

For questions about this Sub-processor List or POM's data processing practices:


This Sub-processor List is maintained in accordance with POM's Data Processing Agreement and is updated at least thirty (30) days before any new Sub-processor begins Processing Personal Data on behalf of Customers.

Questions about these terms? Contact us at [email protected]