Subprocessors

CustomJS, operated by TechnologyCircle GmbH, engages the third-party subprocessors listed below to provide the Service. This list corresponds to Annex IV of our Data Processing Agreement and is maintained separately so that changes can be published without re-issuing the DPA.

SubprocessorPurposeLocationTransfer mechanism
Amazon Web Services EMEA SARL / AWS Ireland Services Ltd. Infrastructure (hosting, data processing)AWS EU (Frankfurt), GermanyWithin the EU, no transfer required
Amazon Web Services, Inc.Support & administrationUnited States EU-U.S. Data Privacy Framework (AWS is actively DPF-certified); EU Standard Contractual Clauses as a fallback

Transfer Impact Assessment

Primary storage and processing is in Frankfurt (Germany); data is encrypted at rest (AES-256) and in transit (TLS); the Service allows no sensitive data; the US entity is subject to the DPF. The parties conclude that the safeguards are sufficient and the residual risk to data subjects is negligible.

Notice of changes

We notify customers of any intended addition or replacement of a subprocessor, giving you the opportunity to object as set out in Clause 6.8 of the DPA. To be notified of changes to this list, email info{at}technologycircle{dot}io.

Last updated: June 2026