Maps where personal data actually ends up
Data protection obligations follow personal data wherever it goes, including to every subprocessor your own processors engage. Almost nobody can produce that map. They can list their vendors — that is a procurement record — but the layer below is a set of web pages each vendor maintains separately and can change without asking.
The gaps are consistent. A processor used with no data processing agreement at all, usually because a team adopted the tool rather than procuring it. An agreement that predates the current scope, covering a service that has since expanded. Personal data reaching a country the agreement never contemplated. A vendor's subprocessor list changed while nobody watched, because the contract only required them to publish the change rather than notify anyone.
And the record of processing itself — the register most regimes require you to maintain — was written once during a compliance project and has described a fictional company ever since.
This agent builds the chain from your own records, compares the register against what is actually in use, and names every gap. It gives no legal advice and makes no compliance determination: it reports what the documents say and what is missing, and whether that amounts to a failure is a lawyer's judgement about a specific regime.
"Where does our customer data go?" — asked by every enterprise buyer.
Or before a customer's diligence finds them for you.
Which is the point of having one.
Your processors' own processors. A set of web pages they can change without telling you.
Usually a tool a team adopted rather than procured. The most common gap and the easiest to prove.
The agreement is real and signed, and describes a service that has since expanded past it.
Personal data reaching a country the agreement never contemplated, via a subprocessor you never chose.
Most records of processing were written once and have described a fictional company ever since.
It reports the gaps. Whether one is a breach is a judgement about a specific regime, for a lawyer.
Why Legal in particular. You know your vendors; the layer below is web pages each vendor can change without telling you. And the register most regimes require has described a fictional company since the day it was written.
Runs unattended
Started by you or by an event, and it finishes on its own. Nothing waits for someone to be at a desk.
The same standard every time
The two-hundredth item is held to the bar the first one was. Consistency is the part people cannot sustain.
It cannot act on its own
Subprocessor Chain Auditor has no path to sending, spending or committing. That limit is why its output is safe to act on.
This agent runs server-side through the PROMIVO runtime. Each run is logged step by step and every tool call is permission-checked before it executes.
Read-only by design. This agent has no path to sending, spending, publishing or committing anything. Where that limit is the product, removing it would remove the reason to trust the output.
Demo dataIllustrative sample output, abridged.
{
"asAtDate": "2026-09-02",
"processors": [],
"reviewWindowMonths": 12
}{
"chain": [
{
"vendor": "Support ticketing platform",
"usedFor": "Customer support correspondence",
"agreement": "scope-outgrown",
"locations": [
"US",
"IN",
"EU"
],
"subprocessors": [
"A cloud host (US)",
"An email delivery provider (US)",
"A translation provider (IN)"
],
"dataCategories": [
"Name",
"Email",
"Free-text customer messages"
],
"listCapturedOn": "2025-04-11"
}
],
"escalate": true,
"disclaimer": "A map built from the records supplied. Not legal advice, no compliance determination, no assessment of whether any transfer mechanism is valid, and no vendor has been contacted. The chain is reported to the depth your records allow and continues beyond it.",
"staleLists": [
"Two subprocessor lists were captured over 16 months ago and describe a chain that has almost certainly changed."
],
"noAgreement": [
"A transcription tool has been processing recorded customer calls for 14 months with no agreement on record. Adopted by a team, never procured."
],
"depthReached": "Two layers: your processors and their published subprocessors. Below that the chain continues and is not visible from any record you hold.",
"scopeOutgrown": [
"The ticketing agreement was signed for support correspondence only. The platform is now also used for onboarding forms, which collect data the agreement does not mention."
],
"escalationReason": "Recorded customer calls are processed by a vendor with no agreement on record, and personal data reaches a location the ticketing agreement does not contemplate.",
"registerMismatches": {
"happeningNotInRegister": [
"Call transcription. Not mentioned anywhere in the register."
],
"inRegisterNotHappening": [
"A marketing automation activity that was discontinued in 2024 is still listed."
]
},
"questionsForVendors": [
"Confirm the current subprocessor list as at today's date, and confirm the notification mechanism for changes.",
"Confirm whether the translation provider processes ticket content, and under which transfer mechanism."
],
"unexpectedLocations": [
"A translation subprocessor in India appears in the ticketing chain. The agreement contemplates the US and EU only."
],
"canChangeWithoutNotice": [
"Three vendors may add subprocessors by publishing the change rather than notifying you. That is a standing gap, not a one-off finding."
]
}No integrations required.
What is actually processing data, against what the register says.
The chain, ready before a buyer asks for it.
What their own chain adds to yours.
Which of your data was in reach, through which link.
$399/month
Billed monthly through your PROMIVO subscription. Cancel at any time.
Runs consume your plan allowance for agent executions and tokens. See plan limits.
No, and it gives none. It reports what your documents say and what is missing. Whether a gap is a breach of a specific regime is a question for your own counsel.
It works from what you supply. Vendor subprocessor pages change without notice, so it reports the date of the list you gave it and flags anything older than the review window you set.
No. It produces the questions to send; sending them is yours.
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