# ETP Foundry: sub-processors and service providers

**Draft v0.2, pending counsel review, 19 October 2026**

> **In short.** Google (Cloud, Firebase, Vertex AI, Workspace) hosts and runs the service and is the only provider that receives personal data, apart from GitHub (committer e-mails). Price data for the funds comes from Chainlink feeds read through public Ethereum RPC endpoints, and from Kaiko where it is configured; none of them receives personal data.

> **What changed from v0.1.** Added the price sources the fund model uses: Chainlink feeds read through public Ethereum mainnet RPC endpoints (publicnode.com, LlamaRPC, Cloudflare's Ethereum gateway), and Kaiko as a second source. Because one of those endpoints is Cloudflare's, Cloudflare is removed from the "not used" list. Nothing else changed.

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) |
| **Chainlink price feeds, via public Ethereum mainnet RPC endpoints** (publicnode.com, LlamaRPC, Cloudflare's Ethereum gateway, tried in order) | Read-only BTC/USD and ETH/USD prices for the funds' NAV | No |
| **Kaiko** | Second price source for a fund that names it; read only where an API key is configured | No |
| **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 (other than its public Ethereum gateway above), 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.