01What this page is
This page lists the sub-processors that CellDelta (Krzysztof Dalewski, sole proprietor, ul. Capri 4/18, 02‑762 Warsaw, Poland) engages to operate CellGuard and the celldelta.ai website. A sub-processor is a third party we use to process personal data on behalf of our customers, or to run our own business.
It complements our Privacy Policy. Where we act as a processor for customer workbook content on the managed service, this list satisfies the Article 28 GDPR requirement to identify our sub-processors; the customer remains the controller of that content.
02Controller / processor split
For data where CellDelta is itself the controller (for example, the work email you submit through the website to request access, and account details), the same sub-processors may be involved, on the legal bases set out in our Privacy Policy.
03Current sub-processors
The following vendors process personal data on our behalf, under data-processing terms, strictly to run the service. We keep this set small and review it before adding to it.
| Sub-processor | Purpose | Personal data processed | Location | Transfer safeguard |
|---|---|---|---|---|
| Railway Corporation | Cloud hosting, compute, ephemeral artifact storage and durable storage for the hash-chained audit archive for the managed service, the MCP server and the website endpoint that receives access requests. | Work email and any optional details from an access request; client IP for security; transient workbook artifacts submitted for a full-file check (1-hour sliding TTL, then evicted); durably retained audit digests and metadata (24 months, configurable). No persisted cell values. | United States | EU‑US Data Privacy Framework (certified) and/or EU Standard Contractual Clauses. |
| Cloudflare, Inc. | CDN, edge and DNS proxy in front of the website and service. | Visitor IP address and standard request metadata, processed at the edge for delivery, security and rate-limiting. | United States | EU Standard Contractual Clauses, and the EU‑US Data Privacy Framework where the recipient is certified. |
| Brevo (Sendinblue) | Transactional email / SMTP relay for the access-request notification and account email. | Recipient and sender email addresses and message content for the notification and account messages. | European Union | Processed in the EU; for any US leg, Sendinblue Inc. is covered by the EU‑US Data Privacy Framework and SCCs. |
| GitHub, Inc. (Microsoft) | Source-code hosting. Not part of the customer-content processing path in normal operation. | No customer workbook content and no website visitor data. Developer account metadata only. | United States | EU‑US Data Privacy Framework (certified). |
| Business email / mailbox provider | Receives the access-request notification email at [email protected] and holds our business correspondence. | The work email and any optional details from an access request, as they rest in our mailbox; our replies. | US / EU | EU‑US Data Privacy Framework and/or EU Standard Contractual Clauses, as applicable to the provider. |
Locations and safeguards reflect the position at the "last updated" date above. The EU‑US Data Privacy Framework remains valid: the EU General Court upheld it on 3 September 2025 in Latombe (T‑553/23); a CJEU appeal is pending.
04No model providers on this list
CellGuard is deterministic: it produces every verdict from fixed, versioned rules and never runs a language model. The verification path makes no outbound network call and no call to any AI provider (such as Anthropic, OpenAI, Google or Microsoft). Outside that path, the system makes only a few operational calls that carry no model data, such as delivering the access-request notification email (Brevo's HTTPS API, with an SMTP relay as fallback). As a result, no AI or model-hosting provider acts as our sub-processor, and your content is never passed to a model by us.
05Self-hosted deployments
In a self-hosted deployment, CellGuard runs inside your own cloud account or on-premises environment. Your workbooks, edits, verdicts and audit records stay within your perimeter, and none of the sub-processors above receives that content. The list on this page applies to the managed service and the celldelta.ai website.
06Changes & notification
We operate on the Article 28 general-authorisation model. We may add or replace a sub-processor as the service evolves, and when we do we update this page with a new "last updated" date.
For customers under a Data Processing Agreement, we give advance notice of any intended addition or replacement of a sub-processor that handles customer content, so you have a reasonable opportunity to object before it takes effect. Where you have a contract or DPA with us, the notice period and objection process in that agreement apply.
To be notified of changes, or to ask for a copy of the relevant transfer safeguard (SCCs or DPF certification), email [email protected].
07Contact
Questions about this list, our processing, or a Data Processing Agreement:
Krzysztof Dalewski (CellDelta)
ul. Capri 4/18, 02‑762 Warsaw, Poland
NIP 5214160761 · REGON 544460460
[email protected]
You can also contact the Polish supervisory authority — Prezes Urzędu Ochrony Danych Osobowych (UODO), ul. Stawki 2, 00‑193 Warsaw, uodo.gov.pl.