Pacely sub-processors

1. What this is

A processor (or *sub-processor*, as defined under the GDPR) is an external party that processes personal data on our instruction, not for its own purposes. With every processor we have a data processing agreement (DPA) that sets out how they handle your data.

On this page you can read which processors Pacely engages today, what they do for us and where they process that data. If a processor is added or drops away, we update this list before the change takes effect. For important changes we also send a notice, see article 13 of our privacy notice.

For completeness, this page also lists the app store that sells in-app subscriptions (see 2.7). It is the seller (Merchant of Record), not a processor, so no data processing agreement applies to that channel.

2. Our processors today

2.1 Google Cloud / Firebase

• Party: Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland), as main contracting party. Underlying also Google LLC for parts delivered by the parent company in the United States.
• Services for Pacely: Firebase Authentication (logging in), Cloud Firestore (database), Cloud Functions (server code), Cloud Storage (file storage), BigQuery (access log), Vertex AI / Gemini (AI processing for generating observations, see privacy notice article 4.2).
• Categories of data: account data, health data, technical and log data, as described in article 4 of the privacy notice. For the Vertex AI component we send only the specific data needed to generate an observation; the output is an observation that we show to you, not to third parties.
• Storage location:

- Cloud Firestore (both health data and administrative data): Belgium and the Netherlands. In Finland there is a small technical replica with only administrative metadata, no copy of your data. - Cloud Storage for files: the Netherlands and Finland. - Cloud Functions, BigQuery and Vertex AI / Gemini run in the Netherlands (Eemshaven). - All within the European Union. Management and support access from Google's global infrastructure falls under the Standard Contractual Clauses mentioned in article 8 of the privacy notice.

• Data processing agreement: Google Cloud Data Processing and Security Terms, accepted via our Google Cloud account.

2.2 Sentry (error monitoring)

• Party: Sentry GmbH, Floßgasse 6/3, 1020 Vienna, Austria. We contract with the EU entity of Sentry; data is hosted in Frankfurt (Germany).
• Services for Pacely: capturing and analysing error reports from the website, the app and our server code. Concretely: stack traces, browser and operating-system information, and a short trail of technical events just before an error.
• Categories of data: technical error data and an opaque user id for logged-in users (no email address, no name). The content of your activities, days, baselines and notes explicitly does not fall under this, our SDK is configured so that this data is not sent along, and on Sentry's side additional scrubbing rules are active as a second safety net.
• Storage location: Frankfurt (Germany), within the European Union. No transfer to the United States in the standard configuration.
• Data processing agreement: Sentry Data Processing Addendum.

2.3 Mollie (payment services)

• Party: Mollie B.V., Keizersgracht 313, 1016 EE Amsterdam, Netherlands.
• Services for Pacely: handling payments for our monthly subscriptions. Concretely: hosted checkout (iDEAL, card payment, direct debit) and reporting back payment status.
• Categories of data: data necessary for the transaction, name, email address, the amount to be paid, and the chosen payment method. The full payment-instrument data (account number, card number) you enter directly with Mollie; Pacely receives only the confirmation and the status of it.
• Storage location: Netherlands, within the European Economic Area.
• Data processing agreement: Mollie Data Processing Agreement.

2.4 Calendly (introductory calls for care providers and researchers)

• Party: Calendly LLC, 271 17th Street NW, Suite 1000, Atlanta, Georgia 30363, United States.
• Services for Pacely: scheduling introductory calls (30 minutes) with care professionals, patient organisations and researchers. A link to Calendly is on `pacely.nl` (the "For care providers" section) and on the login page of the care-provider portal. Only when a professional schedules a call via that link does Pacely receive the booking data via Calendly; if you do not use this flow, Pacely shares no data with Calendly.
• Categories of data: name, email address, the chosen date and time, and any free-text answers in the booking form, for business contact only. No health data of app users, no account or energy-planning data from Pacely itself is shared via this route.
• Storage location: United States. For this transfer outside the European Economic Area we apply the Standard Contractual Clauses and the additional safeguards Calendly offers alongside them; see also article 8 of the privacy notice.
• Data processing agreement: Calendly Data Processing Addendum.

2.5 Google Workspace (business email, calendar and video calls)

• Party: Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). The same legal entity as under 2.1, but a different product line with its own data processing agreement than the Google Cloud / Firebase services.
• Services for Pacely: Gmail (the mailbox behind @pacely.nl and our internal work mail), Google Calendar (appointments scheduled via Calendly land here), and Google Meet (the video calls Pacely holds with care professionals, patient organisations and researchers).
• Categories of data: the content of incoming and outgoing email (email address, name, subject, message text, any attachments), calendar items, and metadata of video calls (participants, time, duration). If you email from a Pacely account with a question or complaint, your message may contain health information that you have included yourself; that processing falls under the same explicit consent for health data that you gave when creating your account (article 4.2 of the privacy notice). Pacely does not store recordings of Google Meet calls by default.
• Storage location: within the European Union (Google Workspace EU tenant). Management and support access from Google's global infrastructure falls under the same Standard Contractual Clauses as described under 2.1.
• Data processing agreement: Google Workspace Data Processing Addendum, accepted via the Google Workspace account.

2.6 Sinch Email B.V. / Mailgun (transactional email)

• Party: Sinch Email B.V. (Netherlands), trading as Mailgun. Sinch Email B.V. is the EU contracting party; the underlying operational entity is Mailgun Technologies, Inc. in the United States.
• Services for Pacely: sending transactional email on behalf of Pacely. Concretely: confirmation mail on account creation, password-reset mail, emails about your subscription or an invoice, and (when a care provider invites you to try Pacely) the invitation email. We do not use Mailgun for newsletters or marketing mail; Pacely sends no marketing mail at this time.
• Categories of data: recipient email address, name (when present in the message), subject and message text of the outgoing email, and delivery metadata (sent, delivered, bounced). The content is limited to what the specific email needs (a reset link, an invoice link, an invitation text); we send no health data via this route.
• Storage location: EU region of Mailgun, with servers in Germany (Frankfurt). Management and support access from the US parent entity (Mailgun Technologies, Inc.) falls under the Standard Contractual Clauses included in the Sinch/Mailgun DPA.
• Data processing agreement: Mailgun / Sinch Data Processing Agreement.

2.7 Google Play (in-app subscriptions on Android)

• Party: Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland).
• Role and services: for in-app subscriptions in the Android app, Google is the seller (Merchant of Record), not a processor of Pacely. Google enters the payment agreement directly with you, handles the payment, collects and remits VAT, and manages refunds and chargebacks. Pacely receives only an opaque `purchaseToken` and status events (purchased, renewed, in grace period, cancelled, expired).
• Categories of data: the opaque `purchaseToken` and its status events. Not received: card or account number, billing details, or the identity of your Google account. The payment data itself falls under Google Play's own privacy policy.
• Storage location: we store the token and status at Google Cloud (see 2.1, multi-region `eur3`, within the European Union). The payment data itself is managed by Google Play under its own policy.
• Data processing agreement: not applicable for in-app billing, because here Google is the seller, not a processor. The technical exchange of status notifications (Real-time Developer Notifications via Google Cloud Pub/Sub) falls under the Google Cloud Data Processing and Security Terms under 2.1.

3. Future processors

At this moment we are not preparing any new processors. If a new party is added, we place it here before the associated feature goes live, so you can always read about it here before it affects you.

4. Not on this list

For completeness: these parties or categories we do not currently use. If that changes, they appear first in article 3 before they are deployed in production.

• Advertising or tracking networks, we do not work with them and do not intend to.
• External analytics (such as Google Analytics, Mixpanel, PostHog), not in use. If this is added, you will see it here and a cookie bar will appear in which you can choose per category.
• External ticketing services for support (such as Zendesk, Intercom, Help Scout); we currently handle mail@pacely.nl manually in Gmail (article 2.5), without a ticketing system on top. If we engage a service for this, it will appear on this list.
• Other error monitoring or observability tools (such as Datadog, New Relic, Honeycomb), not in use. For error monitoring we use Sentry; see article 2.2.

5. Changes to this list

For a new processor, a change to the categories of data they process, or a change in the location of processing, we update this page. At the top you see the version number and the date of the last change.

6. Contact

Questions or remarks about our processors, or about the way Pacely shares personal data? Get in touch via mail@pacely.nl.