Subprocessors / International Data Transfers
Legal document versionsVersion: 2026-11-06-ai-availability-7 · Effective date: November 6, 2026
A consolidated convenience copy of the current published documents. Each document retains its own version and effective date. The versioned legal pages and archive remain authoritative.
On this page
Providers and recipients
This supplement identifies the services used by Soteria and the information involved. Core hosting, files, recovery and email services are distinguished from feature-dependent Maps, AI, Paymob and browser/device push, and operational monitoring. Not every record is sent to every provider. Selected optional content, technical network traffic and provider account/administrative data can have different flows. Paymob can receive checkout contact/order information even in restricted test mode; the earlier assertion that no payment provider processes platform-billing data no longer describes the integration. Browser push also uses a device-selected delivery service. Neither listing a recipient nor enabling a feature supplies consent, merchant approval or a transfer permit.
Processing roles
A subprocessor processes relevant Organization data on Soteria's behalf under applicable written duties. Some recipients also determine their own payment, fraud, network, account-security or legal purposes and may be independent controllers for that processing. The actual operation and applicable terms determine the role, not merely inclusion under this page's title. The descriptions below identify those distinctions without asserting that all contracts or legal entities have been verified. The Organization DPA governs Soteria's obligations for directed processing. Your Organization's own recipients, public sharing and exports are separate instructions; public links and recipient/device copies can extend beyond server access controls.
What is known about locations
Non-secret live metadata checked on 29 October 2026 identified the app/database server as Hetzner hel1-dc2 in Helsinki, Finland, SMTP delivery as AWS eu-central-1 in Frankfurt, Germany, and the backup endpoint as Backblaze eu-central-003. Backblaze documents EU-Central file storage in Amsterdam, Netherlands; that mapping is a provider-supported inference. The configured Zoho .com endpoints correspond to its US data-center domain under provider guidance, without independently confirming every tenant/support location. R2 bucket jurisdiction/placement, relevant AI and monitoring project settings, payment and browser-push processing countries and additional provider/support/onward destinations are not all verified. Provider marketing, an endpoint region, encryption or a European application server does not prove exclusive residency for every data category. Configuration is not a complete inspection of actual traffic or every stored copy.
Provider terms and evidence
Published privacy policies, processing terms and technical guidance are linked as references, not proof that Soteria has verified every applicable agreement, account, version, legal entity or required schedule. Some providers incorporate processing terms into service terms automatically; others offer an account-specific DPA process. A separate handwritten signature is not universally required, but applicable and retained evidence is still necessary. We must verify the appropriate contractual duties, recipients and countries and required safeguards for the actual processing, including onward providers. Public EU standard clauses, provider certifications or a general Organization acceptance are not themselves an Egyptian transfer authorization. No particular signed agreement, completed audit, registration, licence or transfer permission is asserted where it has not been verified.
Transfers outside Egypt
The service can involve processing outside Egypt, including the confirmed/inferred locations and unverified destinations described here. Egyptian requirements for international processing and sensitive/child data must be assessed for the actual purpose and recipient, including required regulatory permissions and destination protection. Other applicable laws may impose additional safeguards. The Privacy Notice, this list, general contract acceptance, browser permission, encryption or guardian consent alone does not complete those requirements. A feature must not be used for processing lacking the required authority merely because the software allows it. Contact [email protected] about the relevant destination, role and safeguards before introducing sensitive processing.
Changes and Organization objections
The reviewed version freezes this provider information; earlier frozen lists remain accessible with their original document versions. Later facts are not silently inserted into an older snapshot. An earliest version that did not store a provider list is identified as such and links to the current supplement. For proposed subprocessor additions/replacements, Soteria must follow the applicable Organization DPA's direct notice, meaningful objection and resolution requirements. Merely editing this public list is not direct notice. An unresolved objection or missing legal permission cannot be treated as consent to move the affected Organization's data. Independent-recipient or purpose changes also require the appropriate assessment and notice/authority.
Questions and privacy requests
Contact Daniel Ashraf Ekdawi at [email protected] for provider, location, safeguard or privacy questions. Identify the relevant Organization/function with safe references; do not send passwords, recovery codes or unnecessary sensitive records. A Person does not need an Account or new contractual acceptance to raise a privacy request. This is a service-provider disclosure, not a claim that every outstanding compliance task has been completed. The Privacy Notice explains rights and retention; the Organization DPA explains instructed processing and operational obligations. Historical content remains evidence of what that version said, not a guarantee that a past configuration is still current.
Provider list
Core services
Hetzner · Active
Application hosting and PostgreSQL.
Processing role: Processor for hosted customer content; separate provider purposes may apply to its own account, billing and security data.
Information involved: Scoped community records, Account/service data and operational traffic stored or processed on the server.
Processing location: Live host metadata hel1-dc2, verified 29 October 2026; Hetzner identifies HEL1 as Helsinki, Finland. This confirms this server location, not every provider support or administrative processing country.
Cloudflare · Active
R2 public/private files and DNS.
Processing role: Processing depends on the service and data. R2 content processing and independently determined network/security purposes must be assessed under the applicable terms.
Information involved: Media, private uploads and stored files; DNS/network metadata for the relevant services. Public URLs can be accessed by authorized recipients or the public as configured.
Processing location: Production uses the standard R2 service endpoint. Actual bucket jurisdiction/placement and all support/metadata locations are not verified; a Helsinki app server does not prove R2 data stays in Finland or the EU.
Backblaze B2 · Active
Encrypted independent database and object recovery copies.
Processing role: Processor for stored customer files; its own account/administrative data can have separate purposes. Published terms incorporate a DPA, whose applicable account/version evidence still needs verification.
Information involved: Encrypted backup contents and recovery history, plus relevant storage/account metadata. Soteria retains the recovery encryption secret separately.
Processing location: Configured endpoint eu-central-003 verified 29 October 2026; Backblaze documents EU-Central file storage in Amsterdam, Netherlands. This is a provider-supported regional inference, not independent inspection of every copy or support location.
Amazon Web Services SES · Active
Transactional email delivery.
Processing role: Processor for customer content under applicable AWS terms; separate account/security purposes may also apply. AWS publishes automatically incorporated processing terms; account and applicability evidence remains to be checked.
Information involved: Recipient and sender addresses, message content/attachments where sent, and delivery/security metadata. Email inherently reaches the recipient and their mail infrastructure.
Processing location: Live SMTP region eu-central-1, Frankfurt, Germany, verified 29 October 2026. That selected delivery region is not an exclusive-country guarantee for every email destination or provider operation.
Zoho Mail · Active
Support mailbox, correspondence, synchronization and mail/reply operations.
Processing role: Mailbox/content processing and the provider’s own account/security purposes have distinct roles. The appropriate Zoho account DPA must be obtained/verified rather than inferred from a policy link.
Information involved: Sender/recipient details, correspondence and attachments retained in the mailbox; related delivery and account metadata.
Processing location: The configured Zoho API/account endpoints are .com. Zoho identifies .com as its United States data-center domain; the actual tenant, support/onward locations and accepted agreement evidence are not independently verified.
Feature-dependent recipients
Google Maps Platform · Conditional on feature use
Maps, Places and geocoding when those interfaces/services are used.
Processing role: Relevant Google services may process controller data as an independent controller under their applicable terms. Do not classify every Maps operation as instructions-only subprocessing.
Information involved: Location/address queries, map interactions, browser/network metadata and coordinates where supplied. Loading a map can transmit technical data before you enter a search; device geolocation has a separate browser permission.
Processing location: Actual service/project processing and support countries are unverified; global provider infrastructure is not a specific residency guarantee.
OpenAI · Conditional on feature use
AI-assisted analysis of selected imports/content when requested and configured.
Processing role: API customer-content processing follows the applicable service/DPA and data controls. Training defaults and retention are different matters; this list makes no account-specific zero-retention or training-consent finding.
Information involved: Submitted import data and prompts needed for the requested analysis; not every Person record is sent automatically. Users must avoid unnecessary sensitive/child data.
Processing location: Project countries, approved retention and training/data-sharing settings remain unverified. Responses requests now explicitly set store:false; this reduces application-state retention and is not a Zero Data Retention guarantee. AI analysis follows scoped import permissions, available allowance and recorded Organization AI restrictions; missing manual approval history does not disable the feature. Organizations remain responsible for applicable data authority and provider/transfer arrangements.
Paymob · Conditional on feature use
Hosted one-time platform checkout, including restricted test-mode use, and payment verification.
Processing role: May determine payment, fraud-prevention and legal purposes independently; any processing performed on behalf of Soteria must be assessed separately. Test mode is not an exemption from privacy duties or proof of live merchant approval.
Information involved: Payer name, email, phone, order/transaction reference, amount and currency sent by Soteria; Paymob handles hosted payment details and its relevant fraud/network/legal data. Soteria does not collect full card numbers/CVV in this checkout.
Processing location: The verified production credentials identify Egypt/test mode on 29 October 2026. That merchant/integration region does not establish exclusive Egyptian storage; processing, support and onward destinations and applicable merchant terms remain unverified.
Browser/device push services · Conditional on feature use
Optional delivery of enabled browser/device push notifications.
Processing role: These are device-dependent recipients, not one named company or a single signed subprocessor agreement. Browser permission is distinct from general processing authority; applicable provider roles and safeguards require review.
Information involved: Subscription endpoint and routing identifiers, encrypted delivery payload and technical metadata; displayed notification content can be visible on the recipient’s device/lock screen.
Processing location: The delivery endpoint/service is selected by the browser/device. Mozilla, Google or Apple infrastructure may be involved depending on the platform. Actual recipients and countries require service-specific verification; no universal region is asserted.
Operational services
Better Stack · Operational service
Sanitized exception monitoring, uptime and scheduled-job heartbeats.
Processing role: Operational monitoring can still involve personal data; minimization does not remove applicable processing duties or make the provider legally irrelevant.
Information involved: Sanitized stack/release metadata, static tags and availability signals. Application user/request payloads are removed; remaining technical/network metadata is not guaranteed anonymous.
Processing location: Better Stack publishes EU-default storage with possible custom locations. Soteria’s actual project region, support/onward processing and account terms have not been verified.