Trusted Codes

Sub-processors

Current as of 2026-10-01

These are the third parties that process data on behalf of Trusted Codes. The list carries its own date, because it changes when a supplier changes rather than when a contract does.

It is also Annex 2 of the Data Processing Agreement, and Section 12 of the Privacy Policy. All three are rendered from one source, so they cannot disagree.

Core service

Engaged for every customer of the hosted service.

ProviderPurposeLocationData sharedTransfer basis
SupabaseDatabase, authentication, server functions and file storageEuropean Union (Stockholm); operator established in the United StatesAll account, verification and billing data held by the serviceStandard Contractual Clauses (2021/914)
InfisicalCustody of the keys that protect data at restEuropean UnionEncryption keys only — no personal dataInside the EEA
VercelHosting of the public website, the pages and server functions of app.trusted.codes, and the web portalsServer functions in the European Union (Frankfurt); static files from Vercel’s global network; operator established in the United StatesRequest metadata: IP address, user agent, requested path; the content of forms and requests handled by server functionsStandard Contractual Clauses (2021/914)
ResendDelivery of transactional electronic mailEuropean Union (Ireland); operator established in the United StatesElectronic mail address and message content, decrypted for the moment of sendingStandard Contractual Clauses (2021/914)
OpenAIThe in-app assistant on Trusted Codes’ own key: understanding requests, composing answers, and search vectors for help texts and questionsUnited States (Standard Contractual Clauses); API data kept up to 30 days for abuse detectionThe text of the request, which can contain whatever the user typed, and excerpts from the help texts. Not used to train models.Standard Contractual Clauses (2021/914)
SentryError reports from the mobile application, the desktop application, the web portals, the administration console and the websiteEuropean Union (Germany); operator established in the United StatesStack trace, application version, device model or browser, account identifier. No electronic mail address and no IP address.Standard Contractual Clauses (2021/914)
StripePayment processing and subscription billingStripe Payments Europe Ltd, Ireland; processing also in the United StatesBilling name and address, tax identification number, subscription state. Card data never reaches Trusted Codes.Standard Contractual Clauses (2021/914)
ExpoRelay of push notifications to the Apple and Google delivery services, and delivery of updates to the mobile applicationUnited StatesPush token, notification content, IP address of the deviceStandard Contractual Clauses (2021/914)
MaxMindFraud check at sign-in and registrationUnited StatesIP address, electronic mail address, user agent. Trusted Codes keeps the result: a risk score and a location to city level. Request and response content is not logged.Standard Contractual Clauses (2021/914)
Hetzner Online GmbHRented server on which Trusted Codes operates Plausible Analytics, Metabase and the MCP relayGermany (Nuremberg)The data of those three services, as described in their rowsInside the EEA
Plausible AnalyticsUsage statistics for the website and the applications of the serviceGermany, on a server rented from HetznerPage viewed and referrer, with no cookies. The IP address is processed only in memory, to form a hash that changes every day.Operated by Trusted Codes
MetabaseInternal analytics, used only by the operatorGermany, on a server rented from HetznerFigures queried from the service databaseOperated by Trusted Codes
MCP relay (mcp.trusted.codes)Passing requests between an AI client and the user’s desktop applicationGermany, on a server rented from HetznerNo content is stored. Connection logs (user name derived from the electronic mail address, IP address, time) are kept for 7 days.Operated by Trusted Codes

Optional and user-chosen

Engaged only where the end user chooses the feature, or where the component is configured.

ProviderPurposeLocationData sharedTransfer basis
AppleSign-in, where the end user chooses itUnited StatesName and electronic mail address, or the relay address Apple issues insteadStandard Contractual Clauses (2021/914)
GoogleSign-in, where the end user chooses itUnited StatesName and electronic mail addressStandard Contractual Clauses (2021/914)

Store test programme

Engaged while the mobile application is distributed through a store test programme.

ProviderPurposeLocationData sharedTransfer basis
Google (Workspace)Tester group for the store test of the Android applicationUnited StatesElectronic mail address of the tester. It is removed when the account is deleted.Standard Contractual Clauses (2021/914)

Public website only

These handle visitors to trusted.codes, not users of the service.

ProviderPurposeLocationData sharedTransfer basis
Google (Sheets and Apps Script)Receiving the website contact form and the waiting list form, during the test period onlyUnited StatesName, electronic mail address, subject and message. The sheet is deleted when the test period ends.Standard Contractual Clauses (2021/914)

A new sub-processor is announced at least 30 days before it begins processing, by electronic mail to the administrative contact of each business customer and by an update to this page.