Three, all established in the EU or EEA. No sub-processor sits in the path of asset content in self-hosted deployments, and none is outside the EU in any deployment.
Current as of 12 August 2026Changes announced 30 days in advanceSubscribe to changes
UUpCloud OyLedger replica and checkpoint storageFI · HELSINKISINCE 2026
DATA IT TOUCHES
Ledger entries and checkpoint proofs only
LEGAL BASIS
Art. 28 DPA, EU establishment
IF YOU SELF-HOST
Not used — replica stays in your cluster
MMollie B.V.Payment processing for card and SEPANL · AMSTERDAMSINCE 2025
DATA IT TOUCHES
Billing contact and payment reference
LEGAL BASIS
Art. 28 DPA, PSD2 licensed
IF YOU SELF-HOST
Still used if you pay by card
There is no US-based sub-processor anywhere in the platform, including for email, error reporting or analytics. Transactional email is sent from our own infrastructure in Nuremberg.
01CHANGE HISTORY
12 AUG 2026ADDEDUpCloud Oy for the Finnish ledger replica, after 30 days notice with no objections.
4 MAR 2026REMOVEDA US email provider, replaced by self-hosted transactional mail in Nuremberg.
18 NOV 2025ADDEDMollie B.V. for billing, replacing a manual invoicing process.