Sub-processor: Anthropic
Why Anthropic is involved
When the Agreely scanner discovers cookies on your website, a first deterministic pass compares them against a reference list of known cookies. For unknown or ambiguous cookies, Agreely uses the Claude Sonnet 4.6 model (Anthropic) to propose a categorization and bilingual purpose descriptions.
This processing happens at scan time, outside the real-time consent flow. Anthropic is not involved in:
- Recording consent decisions.
- The hash chain or on-chain anchoring.
- The banner displayed to your site's visitors.
Communication outside Québec
Anthropic (PBC) is established in the United States. The request is designed to carry no personal information: a cookie's name, domain and attributes, the third-party hosts and the page title, never a cookie value or information about a visitor. Only the title of a scanned page, sent up to 300 characters, could exceptionally contain some. The rules on communication outside Québec concern personal information: before communicating it outside Québec, or entrusting a person outside Québec with collecting, using, communicating or keeping it on its behalf, an organization must conduct a privacy impact assessment, and the communication must be the subject of a written agreement (P-39.1 s. 17; for a public body, A-2.1 s. 70.1). This page documents the request; it does not stand in for that assessment or that agreement.
What is sent to Anthropic
The model receives only value-free metadata:
- Cookie or storage object name.
- Cookie domain.
- Attributes (expiry,
httpOnly,secure,sameSite, third-party or not). - Third-party hosts co-present during the scan.
- Title (up to 300 characters) and language of the scanned page.
What is never sent:
- The value of the cookie (never stored for the model, never transmitted).
- Visitor personal information.
- Data from the production consent flow.
The absence of cookie values removes the main risk of visitor personal information reaching the LLM request.
Mandatory human review
No categorization produced by the model is served automatically: a person on your team publishes each banner version from the Publishing page, which shows what the version will cover. Low-confidence entries block publishing until a person confirms or corrects them (see Inventory and categorization). Manually edited entries are permanent: the automated pipeline never touches them again.
The model can never classify a third-party cookie "strictly necessary". For a first-party cookie, it may propose it: review those entries, because the decision is your organization's.
Written agreement (upcoming)
Agreely is bound by Anthropic's terms of service, which include confidentiality and use-limitation commitments. A formal Data Processing Agreement (DPA) with Anthropic is planned for the commercial launch. It is not yet in effect at the time of this documentation.
Anthropic acts on Agreely's behalf and receives only value-free metadata, solely for cookie scanning and categorization. If personal information were communicated to it in that context, the mandate would have to be given in writing and set out the confidentiality, use-limitation and non-retention measures (P-39.1 s. 18.3; for a public body, A-2.1 s. 67.2, which further requires naming the applicable provisions of the Act and obtaining confidentiality undertakings).