Legal
Sub-processors
The providers that process personal data on our behalf, with what each does and where.
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.
| Provider | What it does | Where it runs | Outside the EEA |
|---|---|---|---|
| Hetzner Online GmbH | Hosting. The application, the corpus and the account database run on one virtual machine | Germany | No |
| Cloudflare, Inc. | DNS and TLS termination in front of the site and the MCP endpoint, and forwarding of messages sent to our addresses | Global edge network | Yes, standard contractual clauses |
| Resend (Plus Five Five, Inc.) | Sends sign-in codes, deletion confirmations and account email | Sent from its EU region (Ireland); Plus Five Five, Inc. is a US company | Yes, standard contractual clauses |
| Functional Software, Inc. (Sentry) | Receives application errors so faults are found before customers report them | EU data region (Germany); Functional Software, Inc. is a US company | Yes, standard contractual clauses |
| Google (Google Workspace) | The mailbox where messages sent to our addresses arrive | Data may be processed in the United States and other countries | Yes: the EU-U.S. Data Privacy Framework and the EU standard contractual clauses, under Google's data processing terms |
| Google Ireland Limited | Google Analytics 4, and only for visitors who opt in | EU and United States | Yes, standard contractual clauses |
| Umami, self-hosted by the operator | Cookie-free page counting. Runs on a server the operator rents from Hetzner, not a third-party analytics service; it stores no personal data | United 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.