07Privacy & data
Subprocessors
Tajir Global Limited · contact@utajir.com
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Register scope & reading guide
1.1What the register covers
This register covers parties we engage to process Customer Personal Data on behalf under the DPA. A provider may be core to accounts or specific to an optional feature; listing it does not mean it receives all data. Customer-selected direct contractors and parties determining independent purposes are classified by their actual function rather than automatically listed as subprocessors.
1.2Current version status
This register identifies providers for Utajir’s selected functions. Each entry applies to the stated function and data, not automatically to every account. The processing schedule associated with your Order identifies applicable providers, storage and access countries, safeguards and processing start date and is supplied before your data is processed. A function requiring a provider is not activated before those details and necessary contracts and protections are in place. Listing an optional service does not mean it is purchased, operating or receiving your data.
Information for each subprocessor
2.1Entity identity and scope
Each entry identifies the actual legal entity, supplied service, potential data and individual categories and the feature or event triggering access. It includes a relevant information link and addition or update date. A product or brand name alone does not identify the contracting party or role.
2.2Locations and protection
Provider incorporation is distinguished from storage, backup, access and support countries, with transfer mechanisms and applicable restrictions. Where optional regions exist, the entry identifies actual account use and anything remaining outside the region. Headquarters must not be used as evidence of data residency.
Hosting, storage & platform operations
3.1Infrastructure and operations
The services below cover infrastructure, media, backups, monitoring and secrets management to the extent they process personal data on the customer’s behalf. Access is limited to the function’s needs; customer content, passwords and access tokens are not routinely sent to logs or development tools. Software we operate ourselves is not a separate processing entity merely because it is part of the platform.
3.2Component changes
Moving a database, store or log to a new party or region requires assessment of whether it changes subprocessors or transfers and needs notice or additional safeguards. A material change is not hidden merely as maintenance, and old-copy and deletion information is updated after migration.
3.320i — hosting and domains
20i Limited, United Kingdom: infrastructure, WordPress hosting and domain registration and renewal. Processing may include account content, files and operational data; domain registration requires registrant details under registrar and registry rules. The account’s service regions are identified in the processing schedule; headquarters does not establish every server’s location. The registrar may process registration data for independent purposes. DPA: https://www.20i.com/legal/gdpr-data-processing-agreement .
3.4Bunny — media storage and delivery
BunnyWay d.o.o., Slovenia: Bunny Storage, CDN, Stream, image optimization and video protection when enabled, processing files, video and delivery-request data. The documented media-file storage configuration uses Frankfurt with replication in Stockholm; this does not guarantee that CDN delivery or all video, log and access processing is confined to those cities. Other function routes are specified before use. Processing information: https://bunny.net/gdpr/ .
3.5Backblaze B2 — backups
Backblaze, Inc., United States: media-recovery storage and database backups when their separate route is enabled. The documented B2 region for both routes is Europe Central; this does not confine administration, support and all account-related data there. Lock and deletion settings differ between the routes, and each must meet the DPA’s deletion periods. A media backup does not establish database recoverability. Processing information: https://www.backblaze.com/company/policy/dpa-for-eea-eu-residents .
3.6Sentry — application errors
Functional Software, Inc., United States, doing business as Sentry: error and performance monitoring when connected, potentially receiving error details and limited technical identifiers after minimization and secret scrubbing. The EU data region is selected for the account; this does not guarantee all support or administrative processing stays there. Listing Sentry does not activate session replay or form-content collection. DPA: https://sentry.io/legal/dpa/ .
3.7Grafana Cloud — monitoring and logs
Raintank, Inc., doing business as Grafana Labs: resource metrics and limited operational logs when connected. Contact lists, conversation content and access secrets are not sent to ordinary monitoring. The account stack’s region and support locations are identified in the processing schedule before personal data is sent; installing Alloy locally does not itself mean customer data is sent to Grafana Cloud. Provider information: https://grafana.com/legal/privacy-policy/ .
3.8Better Stack — uptime and alerts
Better Stack, Inc., United States: connected uptime, log and alert services using check endpoints, permitted logs and operations-team contacts. The selected log configuration identifies Germany and does not establish that all other processing stays there. Authorization does not include sending customer content to the provider’s AI analysis tools without specifying purpose, processing and safeguards before enabling them. Provider information: https://betterstack.com/terms .
3.9Doppler — secrets management
Doppler Technologies, Inc., United States: service-key and environment-secret management when connected. It is not used as a content store for CRM records or customer messages. If secrets include person-linked tokens or access to personal data, we apply least privilege and the account’s specified processing contract, safeguards and locations. Possession of a key does not authorize independent use of data. DPA: https://www.doppler.com/legal/dpa .
Communications, support & operational services
4.1Communications and support
We use Emailit and Amazon SES for email according to the account or function; neither replaces the other, and not every message passes through both. Twilio supports enabled SMS, voice and number services, while Meta WhatsApp Cloud API supports the direct WhatsApp integration. Data and roles depend on the service and account connection, including a communications provider’s independent processing where required by the service or law.
4.2Operational services with differing roles
Authentication, notifications, billing and support are assessed by data and purpose. A provider may process on behalf for one function and independently control another, requiring separated functions and notices. Utajir's own invoice processing is not automatically treated as processing the merchant's customer database, and support-contractor access is not omitted merely because it does not host the database.
4.3Emailit — email
Emailit: its public terms identify FunFirst s.r.o. in Czechia and mention a US subsidiary, FunFirst, Inc. The account schedule identifies the actual contracting entity and processing locations before customer data is sent. The function covers necessary sender and recipient addresses, email content, attachments, delivery and suppression records. It is used alongside Amazon SES according to account or function for permitted sending; cold outreach support is not assumed. Terms and processing annex: https://emailit.com/terms-of-service/ .
4.4Amazon SES — email
Amazon Simple Email Service (SES): email delivery and processing of necessary content, addresses and delivery data. The standard AWS agreement identifies Amazon Web Services, Inc. for an account whose country is Hong Kong; the processing schedule matches this against the actual service account and identifies its SES region, access locations and safeguards. It is used with Emailit according to function or account; listing both does not mean every message is sent to both. Contract information: https://aws.amazon.com/agreement/ .
4.5Twilio — SMS, voice and numbers
Twilio Inc., United States, is the standard entity identified for a Hong Kong account, with local communications entities where service and country terms apply. Data may include numbers, message content, call metadata and recordings when lawfully enabled. The platform account and subaccounts support services charged through Utajir; these are service fees, not merchant-sales funds. Routes, carriers and locations depend on destination and service. Contract: https://www.twilio.com/en-us/legal/tos . Processing: https://www.twilio.com/en-us/legal/data-protection-addendum .
AI feature providers
5.1Provider and transmitted data
OpenAI API is the selected AI provider for functions using it; the enabled service determines necessary inputs, attachments and outputs. The standard Services Agreement identifies OpenAI OpCo, LLC in the United States for a Hong Kong organizational account. API use alone establishes neither a specific data-residency location nor zero retention. The account route, regions, retention and any human access are specified in the function schedule before data is sent. Contract information: https://openai.com/policies/services-agreement/ .
5.2Retention, training and human review
Retention, training or model-improvement use, human access and security exceptions require evidence from actual contracts and settings. No-training or no-retention claims need scope and evidence and are not copied from a different provider plan. Google and other source restrictions continue to cover derived data where the source policy requires.
Brands & integration-role distinctions
6.1Thrive Connector
Thrive Connector is the Utajir operator's technical brand and domain, so it is not listed as a separate subprocessor company. Other parties processing behind the connector are listed if they actually act as subprocessors, with purposes and permissions identified. White-label neutrality does not conceal legal identity where disclosure is required.
6.2Payment provider and connected services
Under the payment integration model, the customer contracts directly with the payment provider for the financial service, and verification, settlement and the payment account follow that provider’s contract and notice. Ravinto is an independent payment service that is ready for use; naming it here does not appoint its operator as an Utajir subprocessor. Its connection notice identifies the provider, data roles and ownership relationship before the connection is activated. Common ownership or integration depth does not automatically make the financial service processing on Utajir’s behalf.
6.3Other integrations and operating tools
Meta, WhatsApp, Telegram, Google, Microsoft, Zoom, Stripe and PayPal are assessed by function: connecting an independent account may involve a direct contract, while operating a function through our account may require a subprocessor entry. Calling it an integration does not remove that requirement. Cloudflare supplies platform and media DNS in the documented scope, not customer-DNS migration. GitHub code and build tooling is not automatically authorized to receive customer data. The register process applies before expanding a tool into new processing on the customer’s behalf.
Change notification & objections
7.1Notice before processing
We email the account contact directly at least 30 days before an addition or replacement starts processing, identifying provider, function, countries, safeguards and start date. You may object on reasonable data-protection grounds within 30 days of receipt under DPA Annex C. No separate newsletter subscription is required, and the disputed provider does not process your data before the objection is addressed under the Agreement.
7.2Objection and resolution
Customers raise specific data-protection objections within the agreed period. We discuss remediation or feasible alternatives; if no lawful resolution exists, affected processing or Services stop or end under the DPA with proper fee settlement. Silence on an incomplete register does not establish consent to undisclosed details.
Version history & contact
8.1Versions and changes
This register forms part of release 2026-09-12.2 dated 12 September 2026. We retain the list and processing schedule associated with your contract and notices of additions, replacements, removals and material country or function changes. Adding a name in this release identifies a selected service and does not establish prior processing of customer data. Request your account’s applicable record at contact@utajir.com.
8.2Requesting information
Request subprocessor and safeguard information at contact@utajir.com, identifying the account and function. We share necessary information securely after suitable verification, with limited redaction of unrelated secrets or others’ data. We do not promise an entire contract we cannot disclose where another lawful method suffices; this does not withhold mandatory disclosures or audit rights.