Last updated: 27 August 2026
This page lists the sub-processors engaged by FenixMinds B.V. (trading as FenxLabs) for the provision of the FenxARC platform and the Chat App. This list is maintained in accordance with Schedule A (Data Processing Agreement) of the Terms of Service.
Naming. FenxARC™ is the current product name. References in previous versions of this document to “ARC” or the “ARC Platform” refer to FenxARC.
The business and contractual language of FenxLabs is English. The English version of this document is authoritative. Any translation is provided for convenience and accessibility, subject always to mandatory rights and statutory language requirements that cannot lawfully be excluded.
FenxLabs provides at least 30 days' advance notice of any changes to this list. If you object to a new sub-processor, you may contact us at contact@fenxlabs.ai before the change takes effect.
AI Providers to which User queries are routed are not Sub-processors of FenxLabs, regardless of whether you access the Service via the Platform or the Chat App.
FenxLabs operates as routing infrastructure with a zero-access architecture. User queries and AI-generated responses pass through the routing infrastructure in encrypted form. FenxLabs does not access, read, inspect, decrypt, or retain conversation content. FenxLabs processes only the routing metadata necessary for service delivery (timestamps, model selections, token counts, Credit and Subscription consumption).
Platform Users: You select and configure which AI Providers receive your queries through the Platform's routing settings. Where you use the Default Model Baseline, you may change your model configuration at any time.
Chat App Users: FenxLabs determines the AI Provider selection and routing logic for the Chat App in its sole discretion and may change these at any time. The Chat App is built on the same zero-access architecture; FenxLabs does not access or retain conversation content routed via the Chat App.
In both cases, your relationship with each AI Provider is governed by that provider's own terms and data processing practices. You are responsible for reviewing their data protection practices.
For details on FenxLabs's role as routing infrastructure, see Part 2.1 and Schedule A (Section A.3.4) of the Terms of Service.
If you access the Service through a third-party marketplace (such as Microsoft Azure Marketplace, AWS Marketplace, or Google Cloud Marketplace), the marketplace operator processes transaction, billing, and account data under its own terms and privacy policies as an independent data controller. Marketplace operators are not FenxLabs sub-processors. For details, see Part 3.6 of the Terms of Service.
Questions? Contact us at contact@fenxlabs.ai or reach our Data Protection Contact at joe@fenxlabs.ai.