Trust / Subprocessors
Subprocessors
The third parties we use to run the service, each one named, with where it sits. All processing subprocessors in the table below are incorporated and hosted in the EU. This list matches Annex III of our data processing agreement.
| Subprocessor | Purpose | Location and safeguard |
|---|---|---|
| Hetzner | Cloud hosting and managed database | Germany. EU-incorporated company, EU-hosted. No transfer outside the EEA. |
| Cubbit | Object storage and backups | Italy. EU-incorporated company, data stored across the EU. No transfer outside the EEA. |
| Tensorix | EU-sovereign model gateway for inference on open-source models | Ireland. EU-incorporated company, inference on EU infrastructure with zero data retention. No transfer outside the EEA. |
| mailbox.org | Email mailboxes and inbound (receiving) email | Germany. EU-incorporated company, EU-hosted. No transfer outside the EEA. |
| Scaleway | Transactional email sending (waitlist, onboarding, notifications) | France. EU-incorporated company (Scaleway S.A.S., Paris, Iliad group), EU-hosted (Paris fr-par). No transfer outside the EEA. |
| Plausible | Cookieless website analytics | Estonia. EU-incorporated company, EU-hosted. No cookies, no personal data, no transfer outside the EEA. |
| Mouseflow | Heatmaps and session recordings (consent-gated) | Denmark. EU-incorporated company, EU-hosted. No transfer outside the EEA. |
Payments
Paddle.com Market Ltd (United Kingdom) acts as our merchant of record, handling checkout, billing, VAT, and invoicing. Paddle is an independent controller for the payment and tax data it handles under the UK adequacy decision, not a subprocessor under our data processing agreement, so it sits outside the table above and is governed by its own terms.
Changes
We keep this list current. Before we add or replace a subprocessor, we give reasonable prior notice by updating this page, and customers may object on reasonable data-protection grounds within 15 days, as set out in our data processing agreement. To be notified of changes, email privacy@paperclip.inc.