Legal
Sub-processors
Last updated: [EFFECTIVE DATE]
MKYCAPITAL LTD ("Keyrail") uses the following sub-processors to process personal data on behalf of its customers under the Data Processing Agreement. We notify account owners by email at least 30 days before adding or replacing a sub-processor.
Sub-processors of customer personal data#
| Sub-processor | Purpose | Data processed | Location of data | Transfer safeguards |
|---|---|---|---|---|
| Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA | Hosting of the service (Cloudflare Workers), database (Cloudflare D1), content delivery, protection against attacks | All customer data stored by the service (see the Data Processing Agreement, section 3) | Database stored in the EU (D1 EU jurisdiction). Requests may be processed in Cloudflare data centres worldwide. | Cloudflare's EU-US Data Privacy Framework certification (and UK Extension), with Standard Contractual Clauses in the Cloudflare Data Processing Addendum as fallback [TO VERIFY ON PUBLICATION DATE] |
| Sendinblue SAS (trading as Brevo), 9-17 rue Salneuve, 75017 Paris, France [TO VERIFY ON PUBLICATION DATE] | Delivery of transactional emails: sign-in links, licence key emails to end customers, service notifications | Recipient email address and name, email content (which may include a licence key and product name) | European Union (Brevo states that its servers are in France and Germany with OVH, and data stored on Google Cloud in Belgium) | EU company, data in the EU; Brevo Data Processing Agreement |
Other third parties (not sub-processors of customer data)#
These services do not process your end customers' data on our behalf, but are listed for transparency.
| Third party | Role | Data |
|---|---|---|
| Paddle.com Market Limited, 30 Old Bailey, London EC4M 7AU, United Kingdom (company number 8172165); for buyers in the United States, Paddle.com Inc.; in Canada, Paddle.com (Canada) Ltd. [TO VERIFY ON PUBLICATION DATE] | Reseller and merchant of record of Keyrail's paid plans: sells the plan to you, collects the payment, issues invoices, handles VAT, sales taxes, refunds and chargebacks. Independent controller for the data it collects at checkout and in its customer portal, under the Paddle Privacy Notice. | Billing details of Keyrail's customers (account owner email, name or company name, billing address, tax number, payment details). Keyrail sends Paddle only the account owner's email and Keyrail account identifier, and receives subscription identifiers, plan, status and billing period. Never your end customers' data. |
| Your own payment provider (for example Paddle Billing or Lemon Squeezy) | Chosen and contracted by you, separately from Keyrail's own Paddle account above. It sends webhooks to Keyrail on your instruction. It is your processor or an independent controller under your own agreement with it, not Keyrail's sub-processor. | Data you configure it to send |
| GitHub, Inc. | Hosting of the open-source SDKs and their issue trackers | None of your customer data. Public contributions only. |
Changes#
| Date | Change |
|---|---|
| [EFFECTIVE DATE] | Initial list |
To be notified of changes, keep the email address of your account owner up to date. Questions: privacy@keyrail.tech.