Draft — to be reviewed by counsel before publication

Subprocessors

Draft list for MB Tobuli. Contact [Contact email]. Company code [Company code]. Address [Registered address]. VAT [VAT number]. Counsel confirms every row before publication. "To confirm" means this repository does not show the integration as live.

The email service keeps message content, recipient addresses, and event payloads in eu-central-1. That Region lock is separate from the EEA transfer rule.

A party in another EU country does not by itself need a transfer tool. It still must not receive those fields. A party outside the EEA needs a transfer tool before it processes personal data. The tool is to confirm by counsel. See the Data processing agreement.

Stripe transfer

The Stripe data-transfer addendum, page dated 2025-11-18, describes the Data Privacy Framework and standard contractual clauses toward Stripe, LLC. Counsel confirms the tool. This draft does not say we have signed it. Do not send message bodies, recipient lists, or event payloads to Stripe.

Changes

Counsel posts a dated change to this list before a new party processes personal data. The notice period is to confirm by counsel.