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.
This list is the public-facing supplement to the "How We Share Information with Third Parties" section of our Privacy Policy. The Privacy Policy remains the authoritative description of why we share information, what safeguards apply, and what rights you 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, HIPAA BAA available.
Google LLC (Gemini API)
- Role
- Generative AI via the Gemini API in a brokered, advisor-facing role — image and graphics generation for advisor workflows (an advisor graphics studio surface and an image-generation tool in the advisor chat). All Gemini calls are brokered through Protocol Wealth's backend; there is no client-facing Gemini surface. Operational since June 2026 under an engagement approved by the Chief Compliance Officer on June 3, 2026.
- Data processed
- Advisor-authored prompts and generated outputs. 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
- Voice transcription via the Whisper API for advisor-initiated dictation — advisor voice memos transcribed into the firm's internal idea-capture workflow. OpenAI chat and reasoning models are not used; there is no client-facing or client-authenticated OpenAI surface.
- Data processed
- Advisor-authored voice-memo audio and the resulting transcripts. Content is limited to what an advisor dictates; client information can appear only to the extent an advisor speaks it. Whisper is not connected to client accounts, the client portal, or any Financial data feed.
- Location
- US (San Francisco headquarters).
- Attestations
- SOC 2 Type II; data processing agreement on file. Protocol Wealth does not currently operate self-hosted AI models. Should external ZDR conditions change, 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 Workspace
- Role
- Business email, document storage (Drive), calendar, and identity services for Protocol Wealth personnel. Not used to process client-authenticated advisory data.
- Data processed
- Firm operational data. Client PII appears only to the extent it is included in advisor email correspondence or internal documents; 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, HIPAA BAA available.
Cloudflare, Inc.
- Role
- DNS resolution, CDN for static sites, web application firewall, and Cloudflare Pages hosting for Protocol Wealth's marketing and informational properties (protocolwealthllc.com, protocolwealth.io). Protocol Wealth's authenticated advisory surfaces do not transit Cloudflare.
- 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, PCI DSS Level 1.
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 CCO 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.
Category 4
Account Data Aggregation
Quiltt, Inc.
- Role
- Financial account aggregation orchestration platform. Quiltt provides the aggregation API Protocol Wealth integrates against; underlying connectivity to financial institutions is handled by MX, Finicity, and Akoya as Quiltt-routed connectivity providers, with FinGoal as the Quiltt-routed enrichment provider. Protocol Wealth maintains a single integration and contract with Quiltt; Quiltt provisions the downstream aggregators on PW's behalf.
- Data processed
- Account balances, transaction history, holdings, and institution-tokenized credentials for accounts that clients link through Quiltt. Typical flow: financial institution → MX / Finicity / Akoya (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 provider routed through Quiltt. 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 for the accounts clients link through Quiltt.
- Location
- US.
- Attestations
- SOC 2 Type II.
FinGoal
- Role
- Data cleaning and transaction enrichment provider routed through Quiltt. 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, and cashflow classification.
- Location
- US.
- Attestations
- SOC 2 Type II.
Finicity, Inc. (a Mastercard company)
- Role
- Account connectivity provider routed through Quiltt, enabled to reach financial institutions not served by MX (notably USAA). Protocol Wealth does not integrate directly with Finicity; Finicity data flows reach Protocol Wealth only via the Quiltt platform. Connection consent is bank-hosted OAuth (redirect to the institution); no institution credentials are stored by Protocol Wealth.
- Data processed
- Institution-tokenized credentials and account data (balances, transaction history, holdings) for the accounts clients link through Quiltt via Finicity.
- Location
- US (Salt Lake City, Utah; Mastercard Open Banking).
- Attestations
- SOC 2 Type II (Mastercard Open Banking / Finicity). Pass-through data-protection terms (Quiltt Finicity addendum): AES-256 minimum at rest, written information security program, GLBA-aligned handling, 6-year compliance-record retention, 48-hour incident notice.
Akoya LLC
- Role
- Token-based account connectivity provider routed through Quiltt, enabled as a secondary/fallback path for coverage gaps. Protocol Wealth does not integrate directly with Akoya; Akoya data flows reach Protocol Wealth only via the Quiltt platform. Akoya uses a credential-free, tokenized (FDX-aligned) data-access model with bank-hosted consent.
- Data processed
- Tokenized account-access grants and account data (balances, transaction history, holdings) for the accounts clients link through Quiltt via Akoya. No institution credentials are stored by Protocol Wealth.
- Location
- US (Akoya is owned by a consortium of US financial institutions; Fidelity-affiliated).
- 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 confirmed in the per-vendor review cycle.
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
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 7
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.
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 version number, 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 compliance@protocolwealthllc.com. 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.
List version 1.4 · compiled June 11, 2026 · page last updated June 26, 2026. Companion to our Privacy Policy. Protocol Wealth, LLC is an SEC-registered investment adviser (CRD #335298). See our Form ADV for authoritative regulatory disclosures.
Registration with the SEC does not imply a particular level of skill or training. This list is informational; the Privacy 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: compliance@protocolwealthllc.com, Attn: Chief Compliance Officer.