Legal

Sub-processors

The providers that process personal data on our behalf, with what each does and where.

In effect from

Effective 14 October 2026. This list is dated so that a change to it is visible rather than announced.

These are the providers that process personal data on our behalf. Everything else Victano reads is public procurement data, which involves no processor.

ProviderWhat it doesWhere it runsOutside the EEA
Hetzner Online GmbHHosting. The application, the corpus and the account database run on one virtual machineGermanyNo
Cloudflare, Inc.DNS and TLS termination in front of the site and the MCP endpoint, and forwarding of messages sent to our addressesGlobal edge networkYes, standard contractual clauses
Resend (Plus Five Five, Inc.)Sends sign-in codes, deletion confirmations and account emailSent from its EU region (Ireland); Plus Five Five, Inc. is a US companyYes, standard contractual clauses
Functional Software, Inc. (Sentry)Receives application errors so faults are found before customers report themEU data region (Germany); Functional Software, Inc. is a US companyYes, standard contractual clauses
Google (Google Workspace)The mailbox where messages sent to our addresses arriveData may be processed in the United States and other countriesYes: the EU-U.S. Data Privacy Framework and the EU standard contractual clauses, under Google's data processing terms
Google Ireland LimitedGoogle Analytics 4, and only for visitors who opt inEU and United StatesYes, standard contractual clauses
Umami, self-hosted by the operatorCookie-free page counting. Runs on a server the operator rents from Hetzner, not a third-party analytics service; it stores no personal dataUnited States (Hetzner, Ashburn)Yes. Page requests reach that server; the counter keeps no identifier

What is deliberately absent

There is no CRM, no advertising network, no data enrichment provider, and no marketing automation platform. Personal data is not sent anywhere except to run the service.

Changes

We will add a provider to this list before it starts processing, not after. Material changes are announced on this page with the date of the change, rather than by quietly replacing it.