Intercom

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.

Applies to: The Terms of Service (effective September 8, 2026) bind “the entity or person placing an order for, or accessing, any Services”. §3.2 is “Subject to the terms of this Agreement”, which incorporates the Additional Product Terms and the Data Processing Addendum.

From the Terms of Service §3.2 (effective September 8, 2026): “Subject to the terms of this Agreement, Customer hereby grants to Intercom a non-exclusive, worldwide, royalty-free right to access, use and display the Customer Data during the Term in order to provide and improve our Services, including for Intercom AI model training.” 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.

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.

• 16 Sep 2026 · the vendor’s document was read again; none of the fields this history tracks changed
• 14 Sep 2026 · the record changed. Changed: the contracting entity and its country. Why: the vendor changed its document.
• 8 Aug 2026 · first recorded: “Contracting entity depends on your region or order form — read the clause.”

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.

Intercom publishes a list of the other companies it uses as sub-processors. It lists 36 entries, and some name the same company more than once, under different locations, for different purposes or in more than one of its lists. Each is shown below with the location the vendor lists it under, in the vendor’s own words.

Under its heading “EU Data Hosting”: For customers participating in EU data hosting (AWS hosting is in Dublin, Ireland - AWS region eu-west-1), the following subprocessors apply.

Under its heading “Australia Data Hosting”: For customers participating in Australian data hosting (AWS hosting is in Sydney, Australia - AWS region ap-southeast-2), the following subprocessors apply.

Intercom qualifies one of those entries in a line nested beneath it. Its words, kept with the entry because the qualification is part of the answer:

Amazon Web Services (AWS) · Australia, except as set forth below: AI processing via models hosted on AWS Bedrock services occurs in the USA.

Taken together those entries name at least Australia, 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.

The same document also lists 4 entries for Intercom’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 intercom.com on 2026-09-18, from the page the vendor titles “Third Parties | Intercom”. 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.

Intercom: “Contracting entity depends on your region or order form — read the clause.”
Vannus, https://vannus.co/tool/intercom
intercom.com · read 2026-09-16

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 →