Intercom
Vannus has not established which model this vendor runs, and does not infer one. Every finding below is quoted to the vendor’s own document, or marked not disclosed where the vendor publishes nothing.
Customer messaging platform for support and growth
It's a brand new model for Fin trained by our AI Group called Apex
Applies to: Written for Fin and Intercom's AI features generally, across Essential/Advanced/Expert; Fin is priced per resolution rather than gated to a tier
From the security page: “Intercom’s LLM providers implement a zero data retention policy on customer messages and returned responses, and we mandate that no data is used for training or fine-tuning of their LLMs.” intercom.com ↗
Training and retention posture varies by plan. The default-plan row above describes the vendor’s free or standard tier; the paid-plan row is quoted from the document linked beside it. A negotiated contract can override either. Check your own agreement before relying on this.
This is a separate question from the grade above. The grade measures resilience — whether the tool endures and whether you could leave it. This describes who controls the vendor. A tool can score modestly on one and strongly on the other, and many do.
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.
The vendor's published or catalog-recorded posture — the concrete facts this grade is built from. A full audit verifies each against the vendor's current documentation.
Intercom publishes a list of the other companies it uses to process customer data. It names 16 of them in 24 entries, because some appear more than once under different locations, each shown below with the location the vendor lists it under, in the vendor’s own words.
Taken together those entries name at least EU, Ireland, USA. 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 Intercom. Where a sub-processor is listed as operating is a fact about that company. It is not a statement about where Intercom keeps your data, which Vannus publishes separately and only from a document in which the vendor says so.
Read from intercom.com on 2026-09-16. 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.
Taken from the vendor’s own published material. Vannus does not hold these reports and has not reviewed their scope or dates — ask the vendor for the current report before relying on any of them.
Vannus publishes a nine-dimension trust framework — data sovereignty, training privacy, compliance posture, operational resilience, exit portability, and more. The heaviest criterion asks whether the tool builds its own AI or resells someone else's model; where the vendor discloses it, the grade cites the vendor's own documentation. No paid placements — scoring is walled off from affiliate revenue. See the methodology →