Subprocessors
Version 1.0 · Effective August 9, 2026
Pre-launch. Commercial activity has not commenced.
What this page is. Foothold (a product of Ellis Intelligence LLC) engages the third parties below ("Subprocessors") to process Customer Data on our behalf in delivering the Service. This is the public disclosure described in our Data Processing Addendum ("DPA") §5.1, kept current as our stack changes.
Ellis Intelligence LLC, a Colorado limited liability company, operates Foothold as a d/b/a; Foothold is not a separate legal entity. This page describes the Subprocessors used specifically by the Foothold Service. Ellis Intelligence LLC has no subsidiaries or affiliated entities, and no entity other than Ellis Intelligence LLC processes Customer Data as part of the Service.
Update cadence & your objection right
We review this list quarterly. Before we engage a new Subprocessor, we specifically inform affected customers in writing — by email to the account's designated contacts, or by in-product notice — with notice deemed given when sent, and we post the change here in addition to (not instead of) that written notice. Customers have 30 days from the date notice is given to object on reasonable data-protection grounds; a timely objection suspends our use of the new Subprocessor for that customer pending resolution, per DPA §5.3.
Current Subprocessors
Foothold — current Subprocessor list
Infrastructure and hosting
| Subprocessor | Purpose | Data accessed | Region | Notes |
|---|---|---|---|---|
| Cloudflare, Inc. | Edge, DNS, DDoS, WAF, Access gating, tunnel; marketing site on Cloudflare Pages | Network metadata; request bodies in transit, not at rest | US (global edge) | Cross-brand. |
| Fly.io, Inc. | Production application hosting + database (Fly Volume holds the SQLite file) | Tenant data in transit and at rest | US (iad / Ashburn, VA) | Chosen production host (decided 2026-06-27; US-domiciled Delaware C-corp). Apps currently self-hosted (Flask + SQLite) pre-launch, migrate to Fly.io US region before public launch. |
| Cloudflare R2 (via Litestream) | Continuous SQLite backup -> point-in-time restore | Encrypted copies of the tenant database file | US (R2) | Streaming replication of tenant SQLite to R2. Wired at the Fly.io cutover. |
Artificial intelligence
| Subprocessor | Purpose | Data accessed | Region | Notes |
|---|---|---|---|---|
| Anthropic, PBC | LLM drafting of capability statements, SAM.gov descriptions, and outreach emails (business-profile data only) | Business-profile data submitted for drafting | US | Not currently covered by a written Anthropic Zero Data Retention agreement or a code-level enforcement gate; we do not represent Zero Data Retention as a current safeguard, and will not make or reinstate that representation until both exist. |
Billing and communications
| Subprocessor | Purpose | Data accessed | Region | Notes |
|---|---|---|---|---|
| Stripe, Inc. | Subscription billing | Billing contact + tokenized payment method | US | Pre-launch: Stripe TEST mode only. |
| Resend Inc. | Transactional email | Recipient address + message content | US | — |
| Google LLC (Workspace) | Our internal business email | Our internal email only; not customer-product data | US | — |
A category with no entries is omitted from the published page rather than shown empty. A vendor we have not engaged is never listed here — planned or candidate vendors are disclosed, if at all, through the notice mechanics above, at the time we engage them.
Subprocessors NOT used. No brokerage, custodian, or regulator system is a Subprocessor. Eligibility data is derived from public federal sources (SAM.gov) we query; we do not transmit Customer Data to those sources.
Data Residency
Data at rest is stored in the United States. Fly.io production hosting and Cloudflare R2 backup replication are launch gates — required to be in place, U.S.-region-pinned, before public launch and before the first production customer. Cloudflare and, where used, Anthropic operate global edge infrastructure for delivery; data at rest stays U.S.-only under our configuration.
Customers Outside the United States
We do not currently market to or onboard customers in jurisdictions that prohibit U.S. data processing under their data-protection law. Customers in the EU/EEA, UK, or Switzerland may onboard subject to the Standard Contractual Clauses ("SCCs") incorporated by reference into our DPA (together with the UK Addendum, for UK transfers).
Audit Rights
You may request a summary of our subprocessor-management practices by emailing [email protected]. SOC 2 Type I is planned; an auditor has not yet been engaged; our report will be available under NDA once complete. We do not permit direct audit of our Subprocessors; we share their relevant audit reports under NDA.
For a customer whose personal data is transferred under the SCCs or the UK Addendum incorporated into our DPA, nothing in this section limits that customer's audit and inspection rights under Clause 8.9 of the SCCs. For that customer, an audit request is satisfied first by our security-posture documentation (or SOC 2 report, once one exists) together with the relevant Subprocessors' audit reports under NDA; any further Clause 8.9 inspection is conducted on reasonable notice, during business hours, subject to confidentiality obligations, and at the customer's expense except where the audit reveals material non-compliance.
Contact Us
Ellis Intelligence LLC
Attn: Privacy & Security — Foothold
Email: [email protected]
Related: Privacy Policy · Terms. This list is referenced by, and generated in accordance with, our Data Processing Addendum. Foothold is not affiliated with, endorsed by, sponsored by, or acting on behalf of SAM.gov, GSA, the SBA, or the U.S. Government, and nothing on the Service is, or should be read as, an official communication, determination, or prediction by any of them.