Sub-processors

Last updated: 2 May 2026

Stack Seven AS engages a limited number of sub-processors to deliver Policy Confirm. This page lists each sub-processor, the services provided, the location of processing, applicable transfer mechanisms, and the role of each party.

This list forms part of our Data Processing Agreement and is referenced in our Privacy Policy.

Current sub-processors

Google Cloud EMEA Limited

Role
Sub-processor
Service
Application hosting, database, file storage, and serverless infrastructure.
Categories of personal data
Customer account data, recipient data, policy metadata, confirmation records, system logs.
Location
EU
International transfers
Personal data may be accessed from outside the EU in connection with operational support, subject to appropriate safeguards.
Transfer mechanism
EU Standard Contractual Clauses, EU-US Data Privacy Framework, UK Extension to the EU-US DPF

Stripe Payments Europe Limited

Role
Independent controller
Service
Payment processing, billing, and subscription management.
Categories of personal data
Billing information, payment details, transaction data, limited customer account data.
Location
EU
International transfers
Stripe may transfer personal data outside the EEA in accordance with its own obligations as a controller.
Transfer mechanism
As determined by Stripe in its role as independent controller
Documentation
stripe.com/privacy

Microsoft Ireland Operations Limited

Role
Sub-processor
Service
Business email used for customer correspondence and support.
Categories of personal data
Customer contact data, communication content, support-related information.
Location
EU
International transfers
Personal data may be accessed from outside the EU in connection with operational support, subject to appropriate safeguards.
Transfer mechanism
EU Standard Contractual Clauses, Microsoft EU Data Boundary commitments where applicable

Astrodon Corporation

Role
Sub-processor
Service
Transactional and marketing email delivery.
Categories of personal data
Recipient name and email address. No policy content, names, version numbers, or confirmation details are transmitted via this service.
Location
US
International transfers
Personal data is processed in the United States.
Transfer mechanism
EU-US Data Privacy Framework, UK Extension to the EU-US DPF, EU Standard Contractual Clauses

How sub-processors are selected

Sub-processors are engaged where necessary to deliver Policy Confirm. Each is assessed for security posture, data protection commitments, and ability to support international transfer requirements before engagement.

International transfers

Where personal data is transferred outside the EEA or the UK to a country without an adequacy decision, appropriate safeguards are in place.

These include:

  • EU Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914)
  • EU-US Data Privacy Framework, where applicable
  • UK Extension to the EU-US Data Privacy Framework, where applicable
  • Other lawful transfer mechanisms recognized under applicable data protection law

Notification of changes

Stack Seven AS will provide at least thirty (30) days' prior written notice before adding or replacing a sub-processor.

Customers may object on reasonable data protection grounds. If no reasonable alternative can be provided, the customer may terminate the affected service in accordance with the Data Processing Agreement.