In plain language
The list is short on purpose. Hosting, payments and e-mail. That is the lot.
None of them can see your sessions. Session content never reaches our servers in a readable form, so it never reaches theirs either.
You get thirty days’ notice before we add one, and you can object.
This summary is for convenience only. The numbered clauses below are the agreement.
1. About this list
A sub-processor is a third party that processes personal data on our behalf in order to deliver the Service. This page is the list referred to in clause 8 of the Data Processing Addendum, and maintaining it is a contractual obligation we owe to our business customers.
Every sub-processor is bound by a written agreement imposing data-protection obligations no less protective than those we owe you, and we remain fully liable to you for what they do.
2. Current sub-processors
| Sub-processor | What it does | Data it can reach | Location |
|---|---|---|---|
| Our hosting and database provider | Runs the coordination server, the management API and the SQL database that holds accounts, devices and session metadata. | Account data, device registration data, session metadata, audit logs. Not session content. | Pakistan |
| SafePay getsafepay.com | Processes card payments and subscription charges. Card details are entered on SafePay’s own hosted page and never pass through our systems. | Name, e-mail address, billing amount and currency, payment card data (held by SafePay, not by us), transaction references. | Pakistan |
| Our e-mail delivery provider | Delivers verification codes, billing notices, contact-form notifications and service announcements. | Name, e-mail address, and the content of the message sent. | United States |
None of these parties is given access to session content, because none exists in a readable form outside the two devices taking part. See section 3 of the Privacy Policy.
We will identify the specific legal entity and registered address of any sub-processor on request to [email protected], and will provide a copy of the Standard Contractual Clauses in place where a transfer requires them.
3. Relays are not sub-processors
Where a session cannot be connected directly it is carried by a relay, which may be a server we operate or another user’s device (see the Network Participation Terms).
A relay is not a sub-processor of personal data, because it forwards encrypted bytes it cannot decrypt and holds no key to them. It performs a purely automatic, technical and passive transmission function: it does not initiate the transmission, select the receiver, or select or modify what is transmitted.
We say this openly rather than quietly, because it is a reasonable thing for a customer to ask about and we would rather answer it before being asked. If your own assessment reaches a different conclusion and you need relay participation restricted for your estate, tell us and we will arrange it.
4. Who is not on this list
We deliberately do not use, and therefore do not have to list:
- third-party web analytics;
- advertising networks or data brokers;
- customer-relationship or marketing-automation platforms holding your users’ data;
- third-party font or script content delivery networks on this website;
- session recording or heat-mapping tools.
5. Notice of changes
We will give at least thirty (30) days’ notice before engaging a new sub-processor or replacing an existing one. Notice is given by:
- updating this page and the date at the top of it; and
- e-mailing the account owner of every organisation with an active paid subscription.
To receive notifications at a different address — a legal or compliance mailbox, for example — write to [email protected].
Emergency replacement. If a sub-processor must be replaced urgently — because of a security incident, insolvency or sudden termination of service — we may do so with shorter notice, and will tell you as soon as we reasonably can with the reason.
6. Objecting
If you have reasonable data-protection grounds to object to a new sub-processor, write to [email protected] within the notice period, setting out your grounds.
We will work with you in good faith to address the concern, which may mean:
- explaining the safeguards in place;
- configuring the Service so that your data does not reach that sub-processor, where possible;
- finding an alternative.
If we cannot resolve it, you may terminate the affected part of the Service without penalty and we will refund the unused portion of what you have paid, pro rata.
7. How we choose them
Before engaging a sub-processor we assess:
- its security posture and the technical and organisational measures it applies;
- where it processes data, and what transfer mechanism is needed;
- its own sub-processing arrangements;
- its history of incidents and how it handled them;
- whether it will accept the contractual terms we must pass down.
We prefer fewer sub-processors to more. Each one is a party that has to be trusted, audited and explained, and the simplest way to protect data is not to hand it to anybody.
8. Contact
Trendifyr Tech (Private) Limited
Pakistan
[email protected]