1Active subprocessors
These vendors handle personal data on our behalf in the operation of Fluëntry. We will give at least 30 days' notice before adding a new subprocessor that handles identifiable personal data, where reasonably practicable, by updating this page and notifying B2B customers via email.
| Subprocessor | Role and data handled | Jurisdiction | Data residency and transfer mechanism |
|---|---|---|---|
| Vercel (active) | Application hosting, edge runtime, asset CDN. Sees request metadata (IP, user-agent), HTTPS traffic, and any payload our app transmits to the browser. | Vercel Inc., USA (with EU operations) | EU regions for application; static assets served from the global edge. Personal-data flows out of the EU are governed by Standard Contractual Clauses. |
| Supabase (active) | Database, authentication, file storage. Holds all account data, test responses, scores, entitlement state, and consent records. | Supabase Inc., USA (EU subsidiary for European data) | Frankfurt (eu-central-1). Resting and processing inside the EEA. Cross-border parent-level access governed by Standard Contractual Clauses. |
| Lemon Squeezy (pending approval) | Merchant of record. Processes payments, handles VAT/MOSS, issues receipts, manages chargebacks. We receive a customer reference, entitlement state, and country of taxation, never card data. | Lemon Squeezy LLC, USA | Payment processing in line with PCI DSS via partner gateways. Transfers from us to LS are governed by Standard Contractual Clauses. We do not transmit identifiable personal data to LS beyond the email address and any name the customer provides at checkout. |
| PostHog (active) | Product analytics, session replay, feature flags, experiments. Receives behavioural events and a PII-masked replay stream. Configured for EU residency. | PostHog Ltd, UK; EU Cloud operated under separate EEA processor arrangements | EU Cloud, Frankfurt. Resting and processing inside the EEA. Cross-border access controls per PostHog's EU Cloud DPA. |
| Resend (active) | Transactional email (account verification one-time codes, payment receipts, account notifications, DSAR confirmations). Holds the recipient address and the email body. | Resend, Inc., USA (EU operations) | EU (Ireland) region. Cross-border parent-level access governed by Standard Contractual Clauses. |
| Sentry (active) | Error tracking. Receives client and server stack traces, error context, and a session identifier. We scrub identifiable personal data from error payloads at source. | Functional Software, Inc., USA | EU instance where available; cross-border flows governed by Standard Contractual Clauses. |
| OpenRouter (active, content-authoring only) | AI model gateway. Used at content-authoring time to draft candidate test items for human review. Does not process runtime user data: no end-user responses, scores, or account data are sent to OpenRouter. | OpenRouter Inc., USA | No identifiable end-user personal data. Item drafts are reviewed and approved by humans before publication. |
2Standard contractual clauses
For subprocessors with operations outside the European Economic Area, transfers of personal data are protected by the European Commission's Standard Contractual Clauses (Decision 2021/914) under Article 46(2)(c) of the GDPR. Where the subprocessor's jurisdiction has been the subject of additional EDPB guidance (in particular the United States, in light of Schrems II), we apply the supplementary technical measures recommended in that guidance, including encryption in transit and at rest and segregation of EU-resident processing where the subprocessor supports it.
4Subscribe to changes
To be notified when this page changes, either because we add a subprocessor or because the role or jurisdiction of an existing one changes, write to privacy@fluentry.be with the subject line "Subprocessor change subscription". We will send a plain-text email when this page is updated.
5Historical changes
Material changes to this page will be logged here from version 2 onward.
- 26 May 2026: initial publication.