1Password

No foundation model. 1Password does not run one, so there is no model provenance to record. An end-to-end encrypted credential vault and secrets manager that stores passwords, passkeys, SSH keys and API tokens for people, machines and AI agents, with autofill, policy-governed vaults and audit logging. It runs no foundation model of its own. Established from the product’s own public documentation and what it does. If that is out of date, tell us at right of reply.

This page gives the finding and links the document it comes from. The AI Subprocessor Jurisdiction Report ($299) quotes the clause this finding rests on, and the clause for each other vendor in your stack where the report can quote one, in one dated document you can hand to an auditor.

Training and retention posture varies by plan. What we publish above describes the vendor’s default plan; enterprise, team and API agreements frequently differ, often materially, and a contract can override the published default entirely. Check your own plan and contract before relying on this row.

On U.S. CLOUD Act reach specifically: the statute reaches a provider subject to U.S. jurisdiction over data in its possession, custody or control. Corporate control is a strong indicator of that and it is what we can evidence from published documents — but it is not the whole test. A company founded outside the U.S. can still contract through a U.S. entity or run substantial U.S. operations. Treat this as a starting point for your own review, not a legal determination, and take advice on anything that matters.

• 13 Sep 2026 · the record changed. Changed: what the answer depends on. Why: we corrected our reading.
• 11 Sep 2026 · the record changed. It now reads: “Contracts with AgileBits Inc. (Canada), under a governing law that depends on whether the customer is a business or an individual.” Before: “Contracts with AgileBits Inc. (Canada).” Changed: what the answer depends on. Why: we corrected our reading.
• 29 Jul 2026 · first recorded: “Contracts with AgileBits Inc. (Canada).”

This is the history of our record of this vendor: when we first recorded it; each time one of these changed: the determination sentence, the contracting entity, its country, the governing law, the US-control finding, what the answer depends on, the note beside the finding, or the cited document; and each time the vendor's document was read again and none of them changed. A change only in capitals, punctuation or spacing is not a line, and neither is a first document title. A line names what changed and does not repeat what those fields said before; the determination above says what they say now. Where the determination sentence itself changed, the line shows the earlier sentence too, marked as before, with why it changed. The automated re-check's latest result is not a line here; it is printed beside the clause above. A change here may be the vendor changing its document or us correcting our reading of it, and a line says which only where the record shows it; otherwise it says the cause is not established. Each line is today's reading of the record as it stood on that date. A reading we later found its citation does not carry was withdrawn, and is not repeated here. This history as data.

The vendor's published or catalog-recorded posture — the concrete facts this entry is built from. A full audit verifies each against the vendor's current documentation.

1Password publishes a list of the other companies it uses as sub-processors. It lists 20 entries. Each is shown below with the location the vendor lists it under, in the vendor’s own words.

1Password marks some of those entries and qualifies them below the table. Its words, kept with the entries because the qualification is part of the answer:

2 For EPM services, the location for this Sub-Processor will depend on the region chosen for your 1Password account, with the exception of when using item sharing, which will be temporarily hosted in the EU by default as long as the item share lasts. 1Password SaaS Manager services are hosted in the EU or the US depending on the region chosen by the account owner during sign up. Apono Services are hosted in the US. Privileged Access Management services are hosted in the US.

3 The location for this Sub-Processor is defaulted to the US, except for 1Password SaaS Manager services made prior to 2025, which are hosted in the EU region.

Taken together those entries name at least Canada, EU, UK, US. That is what our place list could match in the vendor’s own words above, so treat it as a floor rather than the whole of it — the entries themselves are the record.

These are other companies, not 1Password. Where a sub-processor is listed as operating is a fact about that company. It is not a statement about where 1Password keeps your data, which Vannus publishes separately and only from a document in which the vendor says so.

The same document also lists 4 entries for 1Password’s own corporate group, or for companies that carry its name. They are counted separately from the entries above, which are other companies.

Read from 1password.com on 2026-09-26, from the page the vendor titles “1PASSWORD LIST OF SUB-PROCESSORS”. Every entry above is a verbatim span of that page.

This is the vendor’s own disclosure, reproduced. Vannus has not audited what any of these companies do with your data, and a list can change without notice. Treat it as a starting point for your own review, not a legal determination, and take advice on anything that matters.

1Password: “Contracts with AgileBits Inc. (Canada), under a governing law that depends on whether the customer is a business or an individual.”
Vannus, https://vannus.co/tool/1password
1password.com · read 2026-07-29

How you may reuse this record

Vannus records, from the vendor's own published documents, the legal entity a customer contracts with, the country that entity sits in, and the governing law of its terms — and whether the vendor runs its own model or resells someone else's. Each finding is quoted to its source and dated, or marked not disclosed where the vendor publishes nothing. No paid placement on a record, in the catalog or in search — affiliate status is walled off from the record, enforced by a test in the build. See the methodology →