Sub-processors

To operate the Plenimo platform we engage sub-processors acting on our behalf — for example for hosting, database, email delivery and payment processing. The list below sets out the sub-processors we currently engage, the purpose of their activity, where processing takes place, and — where processing occurs outside the European Economic Area (EEA) — the transfer safeguard applied.

We have entered into a data-processing agreement compliant with GDPR Art. 28 with each sub-processor. Transfers outside the EEA take place subject to appropriate safeguards: certification under the EU–US Data Privacy Framework (DPF) or the Standard Contractual Clauses (SCC) adopted by the European Commission.

We give studios (as controllers) notice by email of any intended change to this list at least 30 days before it takes effect, in accordance with the Data Processing Addendum (DPA).

Activity: providing the database, authentication (auth), file storage and serverless ("edge") functions.

Place of processing: Amazon Web Services (AWS), eu-west-1 region (Ireland), within the EEA.

Safeguard: processing takes place within the EEA, so no separate international-transfer safeguard is required.

Activity: hosting and content delivery network (hosting / CDN), serving the Platform and the studios' websites.

Place of processing: global edge network, with a provider based in the USA.

Safeguard: EU–US Data Privacy Framework (EU–US DPF).

Activity: payment processing — collecting subscription fees, and payments between studios and their clients (Stripe Connect).

Place of processing: Ireland (EEA), with US processing (Stripe, LLC).

Safeguard: EU–US Data Privacy Framework (EU–US DPF).

Activity: delivery of transactional (system) emails.

Place of processing: United States.

Safeguard: EU–US Data Privacy Framework (DPF) certification, together with Standard Contractual Clauses (SCC).

Activity: electronic invoicing (issuing invoices) in accordance with Hungarian accounting and tax law.

Place of processing: Hungary, within the EEA.

Safeguard: processing takes place within the EEA, so no separate international-transfer safeguard is required.

Activity: electronic invoicing (issuing invoices) in accordance with Hungarian accounting and tax law.

Place of processing: Hungary, within the EEA.

Safeguard: processing takes place within the EEA, so no separate international-transfer safeguard is required.