Subprocessors

The vendors we use, and why.

Protocol Wealth works with a small number of third-party service providers ("subprocessors") to deliver advisory services, custody client assets, and operate our platform. This is the full list — each provider's role, the data categories it processes, where it operates, and the security attestations it publicly maintains.

Read the Privacy Policy How we vet our vendors

This list is the public-facing supplement to the "How We Share Information with Third Parties" section of ourPrivacy Policy. The Privacy Policy remains the authoritative description of why we share information, what safeguards apply, and what rightsyou have. This list exists so that you — or your compliance, audit, or legal team — can see the full vendor roster without filing a written request.

Security attestations are shown as the vendor published them at the time this list was compiled. Our own vendor-risk process reviews attestations at engagement, annually thereafter, and on material change. Inclusion here is not an endorsement; it states that the vendor meets our requirements for the role listed and that we have reviewed their attestations within the scope appropriate to that role. Where Client PII would otherwise appear in a vendor's data flow, our PII redaction pipeline removes direct client identifiers before any external AI transmission.

Data categories used below

Client PII.: Name, contact information, government-issued identifiers, account numbers, tax identifiers.
Financial data.: Account balances, transaction history, holdings, fund flows, tax information.
Advisory content.: Advisor-authored analysis, AI-assisted research drafts, Investment Policy Statements, recommendations, notes.
Wallet addresses.: On-chain wallet identifiers; all public blockchain data.
Custody instructions.: Wallet signing requests, trade orders, transfer instructions, MPC key material.
Firm operational data.: Advisor communications, internal documents, firm records not specific to a single client.

Category 1

Artificial Intelligence

Anthropic, PBC

Role: External AI inference via the Claude API, operated under a Zero Data Retention (ZDR) agreement. Used for advisor-supporting research, analysis drafting, and document preparation under human review, per the co-intelligence framework described in our Privacy Policy.
Data processed: Advisory content and redacted research inputs. Client PII is removed via Protocol Wealth's PII redaction pipeline before any data reaches Anthropic.
Location: US-only workspace configuration; US-only inference regions.
Attestations: SOC 2 Type II, ISO 27001, ISO 42001, CSA STAR, HIPAA BAA available, NIST 800-171 (the verified scope for the Claude API tier Protocol Wealth uses). Zero Data Retention (ZDR) became effective for Protocol Wealth on April 21, 2026: zero-day retention of API inputs and outputs, US-only inference, and a no-training exclusion are enforced at the API workspace level, and are independently attestable by Anthropic on regulatory or qualified-partner request. In addition to Anthropic's workspace-enforced ZDR, Protocol Wealth operates a pre-inference PII redaction pipeline that removes direct client identifiers before transmission — two independent controls by design. Anthropic publishes its own subprocessors and current attestations at its trust center (linked below); Protocol Wealth discloses its direct subprocessors here and does not duplicate Anthropic's downstream providers.
Trust center: trust.anthropic.com

Google LLC (Gemini API)

Role: Generative AI via the Gemini API in two brokered, firm-internal roles: (1) image and graphics generation for advisor workflows (an advisor graphics studio surface and an image-generation tool in the advisor chat); and (2) automated source-code-review scans as one of the independent model providers in the firm's heterogeneous Claude + Gemini + Codex pull-request AI-review gate. All Gemini calls are brokered through Protocol Wealth's backend; there is no client-facing Gemini surface. Operational since June 2026 under the firm's documented vendor-governance and AI-use review process.
Data processed: For graphics generation, advisor-authored prompts and generated outputs. For code-review scans, Protocol Wealth's own source-code diffs (Firm operational data; no client data), behind a pre-egress secret/PII scan that blocks credentials and identifiers before transmission. Requests route through the same pre-transmission PII redaction pipeline and egress controls applied to Protocol Wealth's other external AI traffic; Client PII is removed before any data reaches Google.
Location: US (Google LLC). Unlike Protocol Wealth's GCP compute workloads (pinned to US regions by organization policy — see the GCP entry below), Gemini API processing is not contractually region-pinned.
Attestations: The engagement runs on the paid tier of the Gemini API (firm Google Cloud project under the firm's Google Workspace enterprise agreement), which qualifies as a "Paid Service" under the Gemini API terms: Google does not use our inputs or outputs to train its models and does not subject them to human review. Google maintains SOC 1 / SOC 2 / SOC 3 and ISO 27001 / 27017 / 27018 / 27701 across its cloud services. Per-engagement due diligence is maintained in the firm's vendor-risk record.

OpenAI

Role: Firm-internal use only; not client-facing and not client-authenticated. Two roles: (1) automated source-code review via the OpenAI API (reasoning models / Codex) as one of several independent model providers in the firm's heterogeneous Claude + Gemini + Codex pull-request AI-review gate; and (2) voice transcription via the Whisper API for advisor-initiated dictation — advisor voice memos transcribed into the firm's internal idea-capture workflow. OpenAI is not used to process client data.
Data processed: For source-code review, Protocol Wealth's own source-code diffs (Firm operational data; no client data) behind a pre-egress secret/PII scan that blocks credentials and identifiers before transmission. For transcription, advisor-authored voice-memo audio and transcripts — limited to what an advisor dictates; not connected to client accounts, the client portal, or any Financial data feed.
Location: US (San Francisco headquarters).
Attestations: SOC 2 Type II, ISO 27001, ISO 27701; DPA on file. OpenAI does not train on API-submitted data (API default, confirmed at the organization data-controls level). The firm has decided not to pursue a Zero Data Retention arrangement for its OpenAI organization; API inputs/outputs are subject to OpenAI's standard abuse-monitoring retention (up to 30 days) and then deletion — the internal-firm-operational-use-only scope, with no client data, is the controlling safeguard. The firm's external-AI engagements (OpenAI, Google Gemini, Anthropic), including the OpenAI source-code-review use, are covered by the firm's documented vendor-governance and AI-use review records. Protocol Wealth does not currently operate self-hosted AI models; should vendor data-handling conditions change in a way material to client data, we reserve the ability to deploy self-hosted alternatives and will update this list and the Privacy Policy before doing so.

Category 2

Infrastructure and Platform

Google Cloud Platform (GCP)

Role: Primary compute and data platform. Hosts Cloud Run services, Cloud SQL (Postgres) databases, Memorystore (Redis) caches, Cloud Secret Manager for credential custody, and the Workload Identity Federation pool used for CI/CD.
Data processed: All Client PII, Financial data, Advisory content, and Firm operational data that Protocol Wealth processes is stored on GCP or flows through GCP compute. Data is encrypted at rest (AES-256) and in transit (TLS 1.2+).
Location: us-central1 region (Iowa). Production workloads pinned to US regions under organization policy; no non-US region processing.
Attestations: SOC 1 / SOC 2 / SOC 3, ISO 27001 / 27017 / 27018 / 27701, PCI DSS, HIPAA BAA available, FedRAMP High.

Google LLC (Google Workspace)

Role: Firm-wide productivity, collaboration, and communications suite for Protocol Wealth personnel — one entity under a single Google Workspace enterprise agreement and Data Processing Amendment (one Workspace DPA, not a separate contract per product). Services used: Gmail (business email), Google Calendar (scheduling), Google Drive (document storage), Google Docs / Sheets / Slides (document authoring), Google Meet (video conferencing), Google Voice (business telephony — inbound/outbound calls, text/SMS messaging, and voicemail), and Google Vault (retention, legal hold, and eDiscovery across the above). Not used to process client-authenticated advisory data.
Data processed: Firm operational data, including communications data — the content and metadata of firm calls, text messages, and voicemails handled through Google Voice, together with advisor email and calendar data. Client PII appears only to the extent it is included in advisor email correspondence, a call or message, or an internal document; such appearances are subject to our records retention schedule and internal PII handling standards.
Location: US regions.
Attestations: SOC 1 / SOC 2 / SOC 3, ISO 27001 / 27017 / 27018 / 27701, HIPAA BAA available.

Cloudflare, Inc.

Role: DNS resolution, CDN for static sites, web application firewall, and Cloudflare Pages hosting for marketing and informational properties (protocolwealthllc.com, research signals). Protocol Wealth's authenticated advisory surfaces do not transit Cloudflare: the pw-api service is private (internal ingress only), and the public webhooks surface routes via a direct DNS CNAME to Google Cloud Run without Cloudflare proxying.
Data processed: Public website traffic metadata; DNS query metadata. No Client PII, Financial data, or Advisory content transits Cloudflare in the current topology.
Location: Global edge network; US-origin routing preferred. DNS queries resolved on Cloudflare's anycast network.
Attestations: SOC 2 Type II, ISO 27001, ISO 27701, PCI DSS Level 1.

Tailscale (under evaluation)

Role: Zero-trust mesh networking (WireGuard-based) under evaluation for secure firm-internal and administrative network access. If adopted, it provides encrypted device-to-resource connectivity for Protocol Wealth personnel; it is not in the client-data path.
Data processed: Firm operational data — device identity, connection metadata, and access-control policy for firm personnel. No Client PII, Financial data, or Advisory content transits Tailscale.
Location: US (Tailscale Inc.).
Attestations: SOC 2 Type II. Listed here for transparency while under evaluation; this entry will be updated to active on adoption.

Category 3

Client Onboarding and Compliance

Veriff OÜ

Role: Identity verification at client onboarding — document verification, liveness detection, biometric match against submitted government-issued ID.
Data processed: Government-issued identification documents, selfie and liveness captures, identity-match outcome records.
Location: Estonia (corporate headquarters); US data processing performed on AWS US regions.
Attestations: SOC 2 Type II, ISO 27001, GDPR-compliant processing.

Scorechain S.A.S. (via QuickNode)

Role: Onchain compliance — operates two distinct surfaces, both used by Protocol Wealth. Scorechain Free Sanctions API — OFAC, OFSI, MOFA, and NBCTF sanctions screening on submitted wallet addresses. Used at client wallet onboarding and on ongoing pre-execution screening. Scorechain Risk Assessment API via QuickNode — chain-scoped Know Your Transaction (KYT) and Know Your Wallet (KYW) risk scoring on the six Scorechain-supported chains: Bitcoin, Ethereum, Solana, Base, XRP, and Avalanche. Used at client wallet onboarding (history review) and on ongoing transaction monitoring (counterparty risk, mixer-exposure detection, sanctioned-entity proximity, behavioral-risk scoring) on those chains. Activity on chains outside the supported set is reviewed manually by the firm using public block-explorer tools and OpenSanctions.
Data processed: Wallet addresses, transaction hashes, and per-chain risk-scoring outputs. No Client PII is transmitted; Scorechain operates on public on-chain identifiers only. QuickNode acts as the integration substrate for the Risk Assessment API and processes the same address/transaction inputs in transit; QuickNode is also listed as a subprocessor in its own right below.
Location: Luxembourg (Scorechain corporate headquarters); QuickNode marketplace addon infrastructure operates on QuickNode's global edge.
Attestations: Scorechain — vendor attestations under active review as part of Protocol Wealth's annual vendor risk assessment; specifics available on request. QuickNode — SOC 2 Type II.

QuickNode, Inc.

Role: Multi-chain RPC and blockchain-data infrastructure provider. Operates the addon substrate through which Protocol Wealth consumes the Scorechain Risk Assessment API; also serves general-purpose RPC reads for wallet position and transaction lookups on the chains Protocol Wealth operates on.
Data processed: Wallet addresses, transaction hashes, RPC query metadata. No Client PII is transmitted; QuickNode processes only public on-chain identifiers and the request envelope that carries them.
Location: US (New York headquarters).
Attestations: SOC 2 Type II.

Hadrius, Inc.

Role: AI-powered compliance monitoring and supervision — trade surveillance, outbound marketing-communication review, archiving of regulated communications. Integrated via manual export workflow at publication date; no programmatic API integration in place.
Data processed: Firm operational data, including outbound advisor communications, marketing materials, and trade activity. Client PII appears to the extent it is present in the reviewed communications.
Location: US.
Attestations: Vendor attestations under active review as part of Protocol Wealth's annual vendor risk assessment; specifics available on request.

BlockSkunk (Arbiter GRC + Stratum governance ledger)

Role: Governance, risk, and compliance (GRC) platform. Arbiter is the firm's risk register, control inventory, Statement of Applicability, Plan of Action & Milestones, and certification checklists (ISO 27001, NIST CSF 2.0, CIS GCP). Stratum is the tamper-evident governance ledger that backs Arbiter — the firm's own node on a private, permissioned Hyperledger network that timestamps and hash-anchors governance evidence so control state, risk decisions, and the firm's NIST OSCAL risk register are recorded on a ledger that cannot be silently altered after the fact. Protocol Wealth pushes control-, risk-, security-finding-, SDLC-control-, and OSCAL-risk-register metadata to signed / API-key-authenticated connectors, and reads governance state back via the Covenant REST / MCP API.
Data processed: Firm operational data — governance and security metadata only. No Client PII, no financial data, no advisory content, and no wallet, custody, or account data is transmitted. The integration is metadata-only by construction: each outbound payload is built from an allowlisted structured field set (control/risk identifiers, control/finding state, framework and regulation tags, CI/security-finding metadata, and OSCAL risk-register control identifiers, severities, and opaque evidence hashes) and passes a defense-in-depth NPI scan before send; Arbiter additionally rejects any NPI with HTTP 422.
Location: Vendor platform (BlockSkunk / Covenant), US; the firm's Stratum node runs on Google Cloud Platform (us-central1). Region and data-residency confirmation is part of ongoing vendor due diligence.
Attestations: Vendor attestations under review as part of Protocol Wealth's annual vendor risk assessment; the platform maintains a tamper-evident audit trail on a private, permissioned Hyperledger instance. Specifics available on request.

Category 4

Account Data Aggregation

Quiltt, Inc.

Role: Financial account aggregation orchestration platform. Quiltt provides the aggregation API Protocol Wealth integrates against; Protocol Wealth maintains a single integration and contract with Quiltt, and Quiltt provisions downstream connectivity/enrichment providers on PW's behalf. Currently active (Quiltt $100/mo tier): MX for account aggregation and transaction enrichment, and FinGoal for transaction enrichment and profile insights.
Data processed: Account balances, transaction history, holdings, and institution-tokenized credentials for accounts that clients link through Quiltt. Typical flow: financial institution → MX (connectivity) → Quiltt → Protocol Wealth, with FinGoal enrichment applied on the Quiltt backend.
Location: US.
Attestations: SOC 2 Type II (auditor Insight Assurance; examination period 2024-11-01 to 2025-01-31; Trust Services Criteria: Security, Availability, Processing Integrity, Confidentiality; report access-gated via the Vanta trust center at trust.quiltt.io). Governing contract is the Quiltt Master Services Agreement (end users own their data; mutual best-practice encryption; 15-day deletion-on-termination; 24-hour customer breach notice).

MX Technologies, Inc.

Role: Account connectivity and transaction-enrichment provider routed through Quiltt — the firm's currently active aggregation path. Protocol Wealth does not integrate directly with MX; MX data flows reach Protocol Wealth only via the Quiltt platform.
Data processed: Institution-tokenized credentials and account data (balances, transaction history, holdings) for the accounts clients link through Quiltt.
Location: US.
Attestations: SOC 2 Type II.

FinGoal

Role: Transaction enrichment and profile-insight provider routed through Quiltt — currently active. Protocol Wealth does not integrate directly with FinGoal; FinGoal data flows reach Protocol Wealth only via the Quiltt platform.
Data processed: Transaction-level data for accounts clients have linked through Quiltt; enrichment outputs such as merchant categorization, recurring-transaction detection, cashflow classification, and profile insights.
Location: US.
Attestations: SOC 2 Type II.

Category 5

Custody and Brokerage

Altruist Financial LLC

Role: Advisory custodian and billing platform. Handles account custody for traditional-asset accounts and executes Protocol Wealth's advisory-fee billing under a separate services agreement.
Data processed: Client PII required for account establishment, Financial data (balances, trades, fee calculations), advisory-billing records.
Location: US (registered broker-dealer; FINRA / SIPC member).
Attestations: Regulatory oversight by SEC, FINRA, and applicable state securities regulators; SOC 2 Type II (vendor attestation).

Interactive Brokers LLC

Role: Brokerage and custody for client accounts custodied with Interactive Brokers. Interactive Brokers calculates and bills its own fees on IBKR-custodied accounts under a direct client relationship with IBKR; Protocol Wealth's advisory fees on those accounts are billed separately.
Data processed: Client PII required for brokerage account establishment, Financial data (positions, trades, account activity).
Location: US (registered broker-dealer; FINRA / SIPC member), with international regulators for any non-US client activity.
Attestations: Regulated broker-dealer under SEC, FINRA, and corresponding international regulators.

Anchorage Digital Bank, National Association

Role: Qualified digital asset custodian. Holds institutional digital asset positions and provides custodial transaction signing.
Data processed: Client custody instructions, wallet addresses, transaction signing requests, balance and position data for AUM calculation and reporting.
Location: US (OCC-chartered national trust bank).
Attestations: OCC regulatory oversight as a federally chartered national trust bank; SOC 2 Type II.

BitGo Trust Company

Role: Qualified digital asset custodian for institutional digital asset holdings.
Data processed: Client custody instructions, wallet addresses, transaction signing requests, balance and position data.
Location: US (South Dakota trust company charter).
Attestations: South Dakota Division of Banking oversight, SOC 2 Type II.

Fordefi

Role: Multi-party computation (MPC) wallet infrastructure for Protocol Wealth's onchain operational treasury and for client-directed onchain allocations where Protocol Wealth operates as a co-signer.
Data processed: MPC key shares (Fordefi holds one share; remaining shares are held by Protocol Wealth and, where applicable, Coincover as backup), transaction signing requests, wallet addresses, transaction metadata.
Location: US and Israel, with US-region processing for Protocol Wealth workloads.
Attestations: SOC 2 Type II.

Turnkey

Role: Self-custodial wallet infrastructure for client onchain wallets — sub-organization provisioning, passkey (WebAuthn) authentication, and a policy engine. Each client is the sole root user of their own Turnkey sub-organization (1-of-1 root quorum). Protocol Wealth participates only as a non-root "recovery helper" with a per-client API key whose authority is limited by an explicit deny policy to co-approving a client-initiated account recovery (a 2-of-2 consensus that also requires the client's own backup factor). Protocol Wealth holds no client wallet keys, no mnemonic, and no passkey private material, and cannot unilaterally sign transactions, export wallets, or move client assets.
Data processed: Client identifiers used to establish the sub-organization (name, email address), passkey public credentials (Turnkey stores public keys only), wallet and sub-organization metadata (sub-organization IDs, wallet IDs, public wallet addresses), and recovery-event records. Wallet key material is generated and held within Turnkey's infrastructure under the client's sole control; it is never visible to Protocol Wealth.
Location: US (New York headquarters).
Attestations: Vendor attestations under active review as part of Protocol Wealth's annual vendor risk assessment; specifics available on request. Breach-notice terms are in the per-vendor review cycle (Reg S-P Compliance Record §5).

Coincover

Role: Standalone client-engaged disaster recovery service for the client's own self-custodial wallets. Coincover is listed here because Protocol Wealth may facilitate a client's setup of Coincover as part of the onchain onboarding workflow — but the engagement is structurally direct between the client and Coincover. Protocol Wealth does not hold, access, or intermediate the backup key material, and Coincover cannot initiate any transaction unilaterally; recovery requires the client's participation.
Data processed: Encrypted backup key material held by Coincover on the client's behalf. No Protocol Wealth client PII, no financial data, no transaction data flows from Protocol Wealth to Coincover.
Location: United Kingdom.
Attestations: ISO 27001, SOC 2 Type II. Classification note: Coincover is included on this list for full transparency even though, under a strict subprocessor definition, Coincover is better characterized as a client-engaged recovery service. Protocol Wealth prefers over-disclosure on client recovery infrastructure so the full posture is visible to clients and regulators reviewing our onchain operational model.

Category 6

Digital Asset Trading and Settlement

FalconX

Role: Digital asset trading / execution and related institutional-market services. Protocol Wealth uses FalconX in a tri-party arrangement in which the client maintains qualified custody with Anchorage Digital Bank and FalconX provides the trading / execution venue or counterparty service. FalconX is not described by Protocol Wealth as the qualified custodian for this arrangement; Anchorage Digital Bank remains the qualified custodian of record.
Data processed: Client and account identifiers necessary to establish or administer the trading relationship; order, quote, execution, trade, and settlement details; custody account / vault identifiers; wallet addresses and position or balance information needed for execution, reconciliation, reporting, and dispute support. No banking-login credentials are shared.
Location: Global institutional trading platform; legal entity and jurisdiction depend on the product, client location, and final executed agreements.
Attestations: Trust-center and security materials requested / under due-diligence review. Until the vendor packet is filed, Protocol Wealth makes no public claim here about FalconX SOC, ISO, or breach-notification commitments beyond the existence of FalconX's public trust / security intake channels.

Category 7

Firm Operations (Banking and CRM)

Mercury

Role: Firm operating banking. Mercury provides Protocol Wealth's business banking; the platform integration is a read-only API feed of the firm's own accounts (balances, transactions, statements) for internal expense and treasury visibility. The API token is read-only by design — it carries no payment or transfer scope.
Data processed: Firm operational data — the firm's own operating-account balances, transactions, statements, and counterparty details. Mercury is not a processor of client account data; client-related information appears only to the extent it is inherent in firm banking records (for example, the counterparty details of an advisory-fee payment into the firm's account).
Location: US.
Attestations: Vendor attestations under active review as part of Protocol Wealth's annual vendor risk assessment; specifics available on request.

Wealthbox (Starburst Labs, Inc.)

Role: Customer relationship management (CRM) — client contact records, advisory notes, tasks, and workflow for the advisory team. A long-standing Protocol Wealth vendor; this entry formalizes its inclusion on the published list. Platform access is server-side only (credentials never reach the browser); AI-initiated CRM writes are gated behind explicit advisor confirmation with dispatcher-level circuit breakers.
Data processed: Client PII (names, contact information), advisory communications, notes, and workflow records.
Location: US.
Attestations: Data processing agreement on file; vendor security documentation on file (Information Security Policy, Business Continuity Plan, Incident Management Plan, Privacy Policy, Security Overview).

Category 8

Communications and Document Execution

Anvil (Anvil Foundry, Inc.)

Role: Electronic-signature and document-generation platform. Anvil renders and executes Protocol Wealth's signature-required Client Advisory Agreement / Investment Advisory Agreement packet through hosted signing envelopes, with the firm's counter-signature workflow and PDF/A-2b archival to a WORM-locked store. Form ADV Part 2A, Form CRS, Privacy Notice, firm disclosures, and portal AI acceptable-use terms are made available as reference disclosures outside the e-signature envelope; the signed advisory agreement captures disclosure receipt and electronic-delivery consent where applicable. Client-specific Investment Policy Statements remain advisor-delivered or portal-vault records rather than public static links. Anvil is the firm's current e-signature provider (DocuSign was retired May 2026). Execution is governed by the firm's E-Signature Policy.
Data processed: Client PII (signer legal name, email address), the content of the executed advisory agreement packet, signature and envelope-event records, and completed signed PDFs. Because signing requires the client's identity and advisory-agreement content, Anvil processes Client PII in the course of rendering and executing documents; declined-reason detail is held encrypted at rest by Protocol Wealth, not by Anvil.
Location: US.
Attestations: ESIGN/UETA legal-validity compliance per Anvil's compliance representation; formal vendor security attestations under active review as part of Protocol Wealth's annual vendor risk assessment and vendor due-diligence intake; specifics available on request.

Postmark (ActiveCampaign, LLC)

Role: Transactional email delivery for the firm's system-generated messages (for example, onboarding, signing, and account notifications). Postmark is used for transactional mail only; it is not a bulk-marketing platform.
Data processed: Recipient email address and the contents of transactional messages, which may include Client PII to the extent it appears in a notification (for example, a recipient name and the fact of an advisory relationship). No account credentials, financial-account data, or government-issued identifiers are sent to Postmark.
Location: US.
Attestations: SOC 2 Type II; vendor security documentation on file / under active review as part of Protocol Wealth's annual vendor risk assessment; specifics available on request.

Category 9

Onchain Data

DeBank

Role: Multi-chain wallet and DeFi position data aggregator. Primary read-only onchain portfolio visibility source for Protocol Wealth.
Data processed: Public wallet addresses; on-chain transaction and position data (all public blockchain data). No Client PII is transmitted.
Location: Global (headquartered in Hong Kong). DeBank aggregates public on-chain data and does not store Protocol Wealth client information.
Attestations: Not applicable to client-confidential data handling; DeBank processes only public blockchain data that is inherently non-confidential. DeBank does not hold Protocol Wealth client information under any data category.

Octav

Role: Multi-chain wallet and DeFi position data aggregator. Backup/fallback to DeBank for onchain portfolio visibility; deployed for resilience against a primary-aggregator outage and for cross-source reconciliation. Read-only.
Data processed: Public wallet addresses; on-chain transaction and position data (all public blockchain data). No Client PII is transmitted.
Location: US.
Attestations: Vendor attestations under active review as part of Protocol Wealth's annual vendor risk assessment; specifics available on request.

vaults.fyi

Role: DeFi vault data and yield-analytics source. Read-only reference data used by Protocol Wealth for onchain strategy/vault research and curation (APY, TVL, and vault metadata).
Data processed: Public onchain protocol/vault data and public wallet addresses. No Client PII is transmitted.
Location: US.
Attestations: Not applicable to client-confidential data handling; vaults.fyi processes only public onchain/market data and does not hold Protocol Wealth client information.

Tatum (Tatum.io)

Role: Multi-chain RPC / blockchain-data gateway used for read-only onchain balance and position lookups on chains outside the firm's primary RPC coverage.
Data processed: Public wallet addresses, transaction hashes, and RPC query metadata. No Client PII is transmitted; Tatum processes only public onchain identifiers and the request envelope that carries them.
Location: Global (read-only onchain data infrastructure).
Attestations: Vendor attestations under active review as part of Protocol Wealth's annual vendor risk assessment; specifics available on request.

Blockstream Corporation (Blockstream.info / Esplora)

Role: Bitcoin blockchain-data provider used for read-only native-BTC address balance lookup through the public Blockstream.info Esplora API. The integration reads funded and spent transaction-output totals for a supplied address; it does not create wallets, submit transactions, sign, or hold custody authority.
Data processed: Public Bitcoin wallet addresses and HTTP request metadata. No direct Client PII, client name, email address, internal client identifier, account credential, seed phrase, or signing key is transmitted.
Location: Global public blockchain-data infrastructure operated by Blockstream Corporation; the public service does not provide Protocol Wealth a US-only data-residency commitment.
Attestations: No independent attestation for the unauthenticated public endpoint was verified. Blockstream's public Explorer materials state encrypted transport and no persistent logging; Protocol Wealth treats those as provider representations rather than an audit opinion.

Helius Blockchain Technologies, Inc.

Role: Solana RPC and indexed-transaction-history provider used for read-only reconstruction of Solana balances, token and stake-account activity, rewards, transfers, and transaction history for accounting statements. Protocol Wealth uses Helius's standard mainnet endpoint; Helius Gatekeeper is an optional beta edge endpoint from the same vendor using the same API key. The integration does not submit transactions or hold signing authority.
Data processed: Public Solana wallet addresses, token and stake-account identifiers, transaction signatures, requested RPC methods, and request metadata. No direct Client PII, client name, email address, internal client identifier, account credential, or signing key is transmitted. Helius states that automatically collected RPC-method information may be retained for up to 20 weeks.
Location: US-based provider with globally distributed RPC infrastructure; Gatekeeper uses geographically distributed edge locations. The free plan does not provide a US-only data-residency commitment.
Attestations: SOC 2 Type II (independent audit by Sensiba LLP; Helius reported a clean opinion in June 2025). Security materials are available through the Helius Trust Center.
Trust center: security.helius.dev/

Category 10

Onchain Insurance & Real-World Assets

OpenCover

Role: Onchain cover / insurance marketplace and analytics source. Used by Protocol Wealth as a curation and diligence source for onchain cover and real-world-asset (RWA) opportunities, and as a facilitation layer where cover is arranged for client allocations.
Data processed: Public onchain protocol, vault, and cover-product data. Where Protocol Wealth arranges cover for a client allocation, the data limited to that arrangement (e.g., a covered wallet address and cover parameters) may be processed; no banking-login credentials and no client identity documents flow to OpenCover.
Location: Per vendor; read-only data/curation use today.
Attestations: Vendor attestations under active review as part of Protocol Wealth's annual vendor risk assessment; specifics available on request.

Nexus Mutual

Role: Onchain cover (mutual) and real-world-asset access used in a B2B arrangement: Protocol Wealth performs its own client KYC/AML and wallet screening, on which Nexus Mutual relies to permit Protocol Wealth client wallets; Protocol Wealth additionally uses Nexus Mutual as a cover/curation source, may purchase cover on a client's behalf, may facilitate client deposits to and withdrawals from covered vaults, and may offer RWA and other onchain investment opportunities sourced through Nexus Mutual / OpenCover. Any such offering is subject to the firm's suitability and compliance review process, and to the products' own suitability constraints.
Data processed: Public wallet addresses and cover/vault parameters; the outcome of Protocol Wealth's KYC/AML determination on a client wallet (an allow/deny signal Nexus relies on) — Protocol Wealth conducts the underlying identity verification itself and does not transmit client identity documents or government identifiers to Nexus Mutual.
Location: Onchain protocol / per counterparty.
Attestations: Onchain mutual; counterparty diligence maintained in the firm's vendor-risk and third-party register. Classification and any client-facing offering are reviewed under the firm's suitability and compliance process.

Maintenance

Changes to this list

When we engage a new subprocessor or materially change an existing subprocessor's role, we update this list and its effective date, update the Privacy Policy if the change affects the scope of data sharing, and provide at least 30 days' advance notice to clients when the change materially expands the categories of data shared, the geography of processing, or the class of AI service engaged. We retain prior versions of this list for a minimum of seven years.

You may object to a specific subprocessor engagement by contacting your adviser or[email protected]. Where a subprocessor is structurally required to deliver advisory services — a qualified custodian, or the sole integration path for a data category — we will describe the operational implications of declining and any alternative we can substitute.

Effective / Last Revised: July 18, 2026(change reference v1.11) · page last updated July 26, 2026. Companion to our Privacy Policy. Protocol Wealth, LLC is an SEC-registered investment adviser (CRD #335298). See ourForm ADVfor authoritative regulatory disclosures.

Registration with the SEC does not imply a particular level of skill or training. This list is informational; thePrivacy Policy is the authoritative description of our data-sharing practices, safeguards, and your rights. A vendor's inclusion is a statement that it meets our vendor-risk requirements for the role listed — not a security audit, certification, or endorsement of that vendor.

Questions about this list or a specific subprocessor:[email protected], Attn: Chief Compliance Officer.