Skip to content
Legal

Subprocessors

Last updated · October 16, 2026

This page lists the providers that process personal data in connection with TruSend. The first section lists the subprocessors that process personal data on your behalf under our Data Processing Agreement; each is engaged under a data processing agreement. The second section lists providers that we use for our own processing on the marketing site, for billing and for product analytics. For each provider we state the purpose of the processing, the location where the processing takes place and, where data is processed outside the EEA, the transfer safeguard that applies.

The first section forms Annex III to the Data Processing Agreement. In accordance with article 28(2) GDPR and section 4.4 of the Data Processing Agreement, we inform you in advance of any intended addition or replacement of a subprocessor, and you may object to that change as described below.

Subprocessors under the Data Processing Agreement

Hetzner Online GmbH

  • Purpose — Hosting of the servers on which the platform runs
  • Processing location — Nuremberg, Germany (EU)

Databricks, Inc. (Neon)

  • Purpose — Managed PostgreSQL hosting for the application database and the identity database
  • Processing location — AWS eu-central-1, Frankfurt (EU)
  • Transfer safeguard — Databricks, Inc. is a US company; Standard Contractual Clauses in the Databricks data processing addendum, which applies to the Neon service, cover any access from outside the EEA

Cloudflare, Inc.

  • Purpose — Edge delivery and proxying of traffic to the platform and the marketing site, bot protection, R2 object storage for attachments and knowledge-base files, processing of image, video and audio attachments to produce previews and playable versions, and page-speed measurement on the marketing site for visitors who accept audience measurement
  • Processing location — R2 object storage: European Union (bucket created in the EU jurisdiction). Edge delivery, bot protection and attachment previews: Cloudflare's global network, including locations outside the EEA. Video and audio transcoding: European Union
  • Transfer safeguard — Standard Contractual Clauses in Cloudflare's data processing addendum

Functional Software, Inc. (Sentry)

  • Purpose — Application error monitoring
  • Processing location — European Union — Sentry's EU region
  • Transfer safeguard — Functional Software, Inc. is a US company; any access from outside the EEA is covered by the EU-U.S. Data Privacy Framework and, as a fallback, the Standard Contractual Clauses in Sentry's data processing addendum

Raintank Inc. (Grafana Labs)

  • Purpose — Operational monitoring and alerting: infrastructure metrics, application logs and request traces, kept for 14 days. Logs contain the IP address of each request and account and workspace identifiers; request bodies are not logged and email addresses are masked
  • Processing location — London, United Kingdom
  • Transfer safeguard — Covered by the European Commission's adequacy decision for the United Kingdom, renewed in December 2025; the United Kingdom is on the Serbian Government's list of countries ensuring an adequate level of protection (Law on Personal Data Protection, art. 64); Standard Contractual Clauses in Grafana Labs' data processing agreement cover any access from outside the EEA and the United Kingdom

Lettermint B.V.

  • Purpose — Delivery of platform email, such as invitations, password resets and notifications, and receipt and delivery of messages in the email channel of your workspace, including their content and attachments
  • Processing location — European Union — Lettermint's European email infrastructure

Google Cloud EMEA Limited (Google Workspace)

  • Purpose — Email for our trusend.ai addresses: support, privacy and security correspondence, including any information about your workspace that you send us
  • Processing location — Google's data centres, including in the United States; no Google Workspace data region is selected
  • Transfer safeguard — Standard Contractual Clauses in Google's Cloud Data Processing Addendum

OpenRouter, Inc.

  • Purpose — Routing of requests to the AI models used for replies, the AI assistant for your team, translation, conversation summaries, embeddings and reranking, and for the description, transcription and text recognition of images, voice messages, videos and scanned documents that customers send. The models reached through it include Claude Haiku for replies, GPT models, Gemini, a speech recognition model, and embedding and reranking models
  • Processing location — United States. Our OpenRouter account is configured to route requests only to the following upstream providers: Amazon Web Services, Inc. (Amazon Bedrock) and Google LLC (Vertex AI) for Claude Haiku 4.5; Google LLC (Vertex AI) for Gemini 3.5 Flash-Lite; Microsoft Corporation (Azure) for GPT-5.4 nano, GPT-4.1 nano, text-embedding-3-small and MAI-Transcribe 2 (speech recognition); Cohere Inc. for Rerank 3.5. Amazon Web Services, Google and Microsoft process a request in the United States or in another region in which they operate the model, which can include the European Union; Cohere processes requests in the United States
  • Transfer safeguard — Standard Contractual Clauses in OpenRouter's data processing agreement, which forms part of its terms of service. The upstream providers are OpenRouter's subprocessors under that agreement. Our account allows only providers that do not train models on submitted content. Requests to Claude, GPT, Gemini, embedding and speech recognition models are routed only to endpoints with a zero data retention policy; Cohere retains reranking requests for up to 30 days. Prompt and completion logging is switched off in our OpenRouter account. Email addresses, phone numbers, card numbers and IP addresses detected in content sent to AI models are removed before it is sent. Images, voice messages, videos and scanned documents that customers send are sent to an AI model as they are; the removal applies to the text produced from them

Providers for our own processing

The providers below process personal data for which we, or in the case of Paddle the provider itself, act as controller. They do not process the data you entrust to us under the Data Processing Agreement.

PostHog Inc.

  • Purpose — Product usage analytics for the platform: events recorded by our servers showing which features are used and when, without the content of those actions, and, for users who consent to analytics in the app, screens opened and page-load performance. Events are linked to pseudonymous account and workspace identifiers and do not include names, email addresses or conversation content. IP addresses are not retained
  • Processing location — Frankfurt, Germany (EU) — PostHog's EU cloud
  • Transfer safeguard — PostHog Inc. is a US company; Standard Contractual Clauses in PostHog's data processing agreement cover any access from outside the EEA

Paddle.com Market Ltd

  • Purpose — Merchant of record for subscriptions: it concludes the sale, issues the invoice and collects and remits applicable taxes. Paddle processes billing and payment data as an independent controller under its own privacy notice and is not a subprocessor of the data you entrust to us under the Data Processing Agreement
  • Processing location — United Kingdom
  • Transfer safeguard — Covered by the European Commission's adequacy decision for the United Kingdom; the United Kingdom is on the Serbian Government's list of countries ensuring an adequate level of protection (Law on Personal Data Protection, art. 64)

Google Ireland Limited

  • Purpose — Audience measurement on the marketing site (Google Analytics, loaded through Google Tag Manager). It is loaded only after a visitor consents and is not used on the platform
  • Processing location — European Union; Google LLC in the United States may also process the data
  • Transfer safeguard — Standard Contractual Clauses in the Google Ads Data Processing Terms

Channels and integrations you connect yourself

When you connect Telegram, WhatsApp, Facebook Messenger or Instagram to your workspace, messages sent and received through those channels pass through the channel provider. These providers are not our subprocessors: you engage them directly, and they process data under their own terms with you. The same applies to your own email provider when you forward email to your workspace. Within TruSend, messages in the email channel are received and sent through Lettermint B.V., listed above.

The same applies to Shopify and WordPress when you connect them: we receive customer and order data from your Shopify store, and the page on which a chat is opened and the visitor’s user role from the TruSend plugin on your WordPress site. Neither Shopify nor the host of your WordPress site is our subprocessor.

Changes to subprocessors

We will update this page and email workspace owners at least 20 days before a new subprocessor starts processing personal data under the Data Processing Agreement. If you object on reasonable data protection grounds, we will work with you in good faith to find an alternative; if we do not agree one within a reasonable time, you may terminate the affected subscription, as set out in section 4.4 of our Data Processing Agreement.

Questions

Questions about this list may be sent to privacy@trusend.ai. Our handling of personal data is described in the Privacy Policy and our security measures on the security page.