ReplyContextSub-processors
Last updated: September 30, 2026
Introduction
This page lists the infrastructure involved in providing ReplyContext to users whose applicable legal documents are for the United States. Transcription, reply generation, and revision requests travel from the ReplyContext server in Germany directly to Google's Gemini API.
ReplyContext uses Gemini for these requests; we configure the model on the server.
Current Processors and Routing Infrastructure
Hetzner Online GmbH
- Purpose
- Application, database, and Redis infrastructure for all ReplyContext users
- Data Processing Regions
- European Union
- Legal Documents
Cloudflare
- Purpose
- DNS, TLS certificate validation, and network-edge services
- Data Processing Regions
- Global
- Legal Documents
Apple
- Purpose
- App Store distribution, payment processing for iOS subscriptions (and for one-time reply credit packs if they are offered in the app), and Sign in with Apple
- Data Processing Regions
- Global
- Data Usage
- Apple processes payment details. ReplyContext receives transaction confirmation, subscription status, and store transaction identifiers to verify purchases and adjust credit for refunds; if a credit pack purchase is offered and made, the same data is used to credit and consume it. ReplyContext does not receive payment card details.
- Legal Documents
- Purpose
- Google sign-in, and Google Play distribution and payment processing for one-time reply credit packs if a released Android app offers them
- Data Processing Regions
- Global
- Data Usage
- Google processes payment details. If a credit pack is purchased through Google Play, ReplyContext receives the product id, purchase token, purchase state, and an obfuscated account identifier to verify, credit, recover, and consume the purchase and to adjust credit for refunds or voids. ReplyContext does not receive payment card details.
- Legal Documents
Google Gemini API
- Purpose
- Transcribes dictation and generates or refines replies
- Data Processing Regions
- Global; processing may take place outside the EU/EEA
- Data Usage
- Receives the recording, and your personal vocabulary list if you added one, when you request transcription. For a reply or refinement, receives any captured messages and screenshots, your stated intent and any instructions, and selected numeric style signals. Requests go directly from the ReplyContext server to Google. Google's API terms describe its processing and retention.
- Legal Documents
Changes to Sub-processors
We will notify customers of any changes to our sub-processors list at least 30 days in advance. Customers can object to the use of a new sub-processor within this notice period.
Contact
If you have questions about our sub-processors, please contact us at Email.