Mivir
Sub-processors

List of
sub-processors

The dated list under clause 12.4 of the Terms of the third parties that access Customer data while the Service is provided.

Version: 2026-09-16 · Published: 16 September 2026

Change on 20 October 2026: From 20 October 2026 the Claude language models run on AWS Bedrock inside the European Union; xAI leaves the list and Anthropic PBC moves from direct API provider to model licensor with no access to customer data. The change is a sub-processor change under clause 12.4 of the Terms; Customers may object until the effective date.

Effective from 20 October 2026

Sub-processorRegistered seatActivityProcessing locationTransfer basis
Amazon Web Services EMEA SARLLuxembourg (RCS B186284)Running the Claude large language models on AWS Bedrock: document recognition and extraction, bank-statement extraction, chat assistant, matching and categorisation suggestionsEU — Frankfurt (eu-central-1) primarily; routed among EU regions only (Frankfurt, Ireland, Paris, Milan, Spain, Stockholm); no data leaves the EUProcessing within the EU; AWS Data Processing Addendum + 2021/914 EU SCCs (Module 2). The residual government-access risk is described in the Privacy Notice.
Cohere Inc.Toronto, Canada (partly US infrastructure)Text embeddings for semantic searchCanada / USA2021/914 EU SCCs (Module 2); supplemented by the Canadian adequacy decision
Hostinger International Ltd.Cyprus; data centre in GermanyOperating the Customer's dedicated server instance, database and file storage (virtual servers)EU — GermanyProcessing within the EU; Hostinger DPA
Deepgram, Inc. — only if the Meetings feature is enabledUSATranscription of meeting recordings (Meetings)USA2021/914 EU SCCs (Module 2). The feature is off by default; enabling it is the Customer's decision.

Not a sub-processor, for information

Anthropic PBC (USA) — developer and licensor of the Claude models; in the AWS Bedrock setup it has no access to customer data and is therefore not a sub-processor under Article 28(2) GDPR. The Provider's self-hosted mail server and AI gateway layer are part of the Provider's own infrastructure, not third parties.

Currently in force (1 May 2026 – 19 October 2026)

Sub-processorRegistered seatActivityProcessing locationTransfer basis
xAI, Inc.USALanguage model (Grok) — chat and text processingUSASCC 2021/914, Module 2 — no longer used by the Service; removed on 20 October 2026
Anthropic PBCUSALanguage model (Claude) — direct APIUSAEU–US Data Privacy Framework + SCC — replaced by AWS Bedrock EU on 20 October 2026
Cohere Inc.Canada (US infra too)Text embeddingsCanada / USACanadian adequacy decision + SCC
Hostinger International Ltd.EU (Germany)Dedicated server, database, file storageEU — GermanyProcessing within the EU

Notice and objection

We notify Customers by e-mail at least 30 days before a new sub-processor is engaged, an existing one is replaced or its scope is extended, and show the notice inside the Service as well. Customers may object until the effective date; failing agreement they may terminate the subscription as of the effective date without adverse consequences.

Questions: info@mivir.hu · Privacy Notice

Previous versions

2026-04 (v1) — the table published in clause 12.4 of the Terms: xAI, Anthropic PBC, Cohere, Supabase.