Sub-processors
These companies process personal data on our behalf to provide Wholetally. They are bound by data processing agreements with us. We tell customers by email at least 30 days before we add or replace a sub-processor (see section 5 of the DPA).
| Sub-processor | Purpose | Data | Location and transfer safeguard |
|---|---|---|---|
| Cloudflare Cloudflare, Inc. (USA) | Hosting of the website, dashboard and API (Workers), database (D1), network security and bot filtering. | All service data: account data, site settings and analytics records. Request data (IP address, user agent) in transit. | Database created in the EU jurisdiction (data stored in the EU). Requests are handled at the Cloudflare location nearest to the visitor, which can be outside the EEA. Cloudflare DPA with EU Standard Contractual Clauses; Cloudflare participates in the EU-US Data Privacy Framework (and UK/Swiss extensions). |
| Resend Resend (Plus Five Five, Inc., USA) | Sending password reset links and the optional weekly report email. | Recipient email address, email content (password reset link or aggregated report), delivery metadata. | Sending region eu-west-1 (Ireland). Resend uses its own sub-processors, some in the USA. Resend DPA (executed on account signup) with EU Standard Contractual Clauses; Resend also participates in the EU-US Data Privacy Framework. |
| Stripe Stripe Payments Europe, Ltd. (Ireland) | Subscription billing, invoices and payments, including iDEAL and cards. | Name, email, billing address, VAT number, payment details, transaction history. | EU, with transfers to Stripe, Inc. (USA). Stripe DPA; EU-US Data Privacy Framework and Standard Contractual Clauses. Stripe is an independent controller for some payment data. |
| OpenRouter OpenRouter, Inc. (USA), routing to the model host (currently OpenAI models hosted by Microsoft Azure) | Generating AI answers, explanations, funnel suggestions and the weekly AI summary. | The question you type and aggregated statistics (counts, page paths, sources, event names). No visitor-level records, IP addresses or hashes. | USA; EU-region routing is possible and under review. OpenRouter DPA with Standard Contractual Clauses (Module 2). We have not opted in to training. Requests are sent with zero-data-retention routing enabled where OpenRouter supports it; see the AI-use statement. |
| Hetzner (planned, not in use yet) Hetzner Online GmbH (Germany) | Planned: analytics database (ClickHouse) for large sites. | Analytics records (no IP addresses, no cookies or IDs). | Germany or Finland (EU). No transfer outside the EU. |
Customers who connect their own Stripe account for revenue attribution use Stripe under their own agreement with Stripe; we only read the payment events needed to attribute revenue. Last updated: 5 November 2026.