# ETP Foundry — Sub-processors and service providers

**Draft v0.1 — pending counsel review · 28 September 2026**

These are the third parties that host, run or carry ETP Foundry's service, and whether each receives
personal data. We will update this list before adding a provider that receives personal data.

| Provider | What it does for us | Personal data? |
|---|---|---|
| **Google Cloud** (region `us-central1`) | Cloud Run (the desk API, the hosted MCP, the testnet vault deployer and chain watcher), Compute Engine (our Canton DevNet validator), Secret Manager, Cloud Scheduler (the chain-watcher tick, every minute), Cloud Logging, Cloud IAP, Cloud Build, Cloud Storage | Yes: stored desk data and logs, which contain e-mail addresses |
| **Google Firebase** | Hosting for etpfoundry.com; Firebase Authentication (Google sign-in only) | Yes: user id, e-mail, verification status, provider metadata |
| **Google Vertex AI** (Gemini, location `global`) | Runs the in-console assistant | Yes: whatever the user types, and the desk data the assistant reads for them. Under Google Cloud's terms for Vertex AI this is not used to train Google's models |
| **Google Workspace** | E-mail for all etpfoundry.com addresses | Yes: the content of e-mail |
| **Porkbun** | Domain registrar and DNS for etpfoundry.com and asklucilla.com | No (registrant data only) |
| **Public EVM testnet RPC providers** (for example publicnode.com and dRPC) | Read-only chain data for the chain watcher and vault deployments | No |
| **GitHub** | Private source hosting; GitHub Actions for the daily publication record | Committer e-mail addresses only |
| **Canton Network (DevNet)** | The ledger, operated by a decentralised set of Super Validators, not by us. We operate only our own validator | No; ledger records use Canton party identifiers |
| **Coinbase, Kraken, Bitstamp** (public endpoints) | Keyless public spot prices, used internally only as a pre-fill and sanity check. Their terms do not permit publication, so no value derived from them is published | No |
| **Anthropic** | Development tool used to write code and documents. Also an **optional, currently disabled** assistant provider. If it is enabled, it becomes a data sub-processor and this list changes first | No, while disabled |

**Not used:** AWS, Azure, Cloudflare, third-party identity providers, payment processors, CRM or
e-mail-marketing platforms, analytics or error-tracking services.

Lucilla, Inc., federal corporation no. 16699448, Toronto, trading as ETP Foundry.
Questions: hello@etpfoundry.com.