List of Sub-processors and Other Providers
This English translation is provided for convenience only. The Czech version is legally binding; in case of any discrepancy, the Czech version prevails.
Last reviewed October 19, 2026 · This list forms part of Annex No. 1 to the Terms of Service (Data Processing Agreement), Article 9.
To operate Snaprime, we use the services of third-party providers. Some of them process the personal data of enquirers on our behalf and are sub-processors within the meaning of Article 28 GDPR; others act in a different role or process only data about Snaprime customers or advertising content. This overview lists both groups. The authorisation, notification of changes and the right to object under Article 9 of the Data Processing Agreement apply only to sub-processors.
How you will learn about a change of sub-processor. Before we engage a new sub-processor or replace an existing one, we will notify you at least 14 days in advance by e-mail or by a notice in the application. If you do not agree with the new sub-processor, you may raise a reasoned objection at info@snaprime.com and, if we fail to reach an agreement, terminate the Service under the conditions of Article 9 of the Data Processing Agreement.
Providers that may have access to your lead data
| Provider | What we use it for | What data | Where | Transfer mechanism |
|---|---|---|---|---|
| Meta Platforms Ireland Ltd. Ireland |
Running ad campaigns and collecting leads through lead forms | All data entered by the prospect in the form | EU | Meta is not a sub-processor of Snaprime here. Leads from lead forms are provided within the relationship between the Customer as advertiser and Meta under Meta’s terms; Snaprime subsequently processes them on the Customer’s behalf under the Data Processing Agreement. Any transfers outside the EU are governed by Meta’s terms and mechanisms. Processing via the Meta Pixel on Snaprime’s own website is described in the Privacy Policy. |
| eLead.agency s.r.o. Czech Republic |
Operation of advertising accounts on Meta. Its Business Manager holds the system access credentials through which Snaprime launches and manages campaigns and receives leads from lead forms | All lead data from lead forms; data about ad accounts and campaigns | EU | Processing in the EU (Czech Republic); a related entity bound by the same obligations under Article 28(4) GDPR |
| Cloudflare, Inc. USA / Cloudflare Ltd., United Kingdom |
Application hosting, network, traffic protection, file storage | All data passing through the application; uploaded files | EU + third countries | EU Standard Contractual Clauses; EU–U.S. Data Privacy Framework certification |
| Neon, Inc. USA |
Managed database in which leads are stored | All lead and account data | EU (region) + third countries | EU Standard Contractual Clauses |
| Scaleway SAS France |
Data storage | Lead and account data; uploaded files | EU | Processing in the EU (France) |
| Google Ireland Ltd. (Google Workspace) Ireland / Google LLC, USA |
Google Sheets to which we send leads for Customers who enable this option | Lead data written to the spreadsheet | EU + third countries | EU Standard Contractual Clauses; EU–U.S. Data Privacy Framework certification |
| Plus Five Five, Inc. (Resend) USA |
Sending transactional e-mails: login links, new lead notifications | Name, e-mail, phone number and the content of the notification | Third countries | EU Standard Contractual Clauses |
| Functional Software, Inc. (Sentry) USA |
Monitoring of application errors and stability | Technical error records; may exceptionally contain identifiers | Third countries | EU Standard Contractual Clauses |
| PostHog, Inc. USA |
Usage analytics for the application and the snaprime.com website: how visitors navigate them, and in the application also session recordings with contact details masked. On the website only after consent to cookies. | Data about application users (the Controller and its team), website visitors who have consented to measurement, technical identifiers | Third countries | EU Standard Contractual Clauses |
| Salesforce, Inc. (Slack) USA |
Internal operational alerts and support | Operational alerts; personal data only to the extent strictly necessary | Third countries | EU Standard Contractual Clauses; EU–U.S. Data Privacy Framework certification |
Other providers that do not have access to your lead data
These services process data about you as our customer or the content of your ads, not the personal data of prospects from leads. We list them for completeness.
| Provider | What we use it for | What data | Where | Transfer mechanism |
|---|---|---|---|---|
| Stripe Payments Europe, Ltd. Ireland |
Processing of subscription payments | Customer billing and payment data | EU | Processing in the EU; Stripe acts here as an independent controller for the purposes of payment services |
| OpenAI Ireland Ltd. Ireland / OpenAI, L.L.C., USA |
Generating suggested ad copy and website content | Information about the customer’s business: name and company name, industry and focus, a summary of the website content, location and the campaign brief. Personal data of prospects from leads is not passed to the models. The provider does not use this data to train its models. | EU + third countries | EU Standard Contractual Clauses |
| Anthropic Ireland, Ltd. Ireland / Anthropic PBC, USA |
Generating and reviewing suggested ad copy and concepts (Claude models). Also analysis and management of ad campaigns in the ad accounts we run for you: evaluating performance and making approved campaign changes via the official Meta Ads connector. | Information about the customer’s business: name and company name, industry and focus, a summary of the website content, location and the campaign brief. Also data about ad accounts and campaigns: account and campaign names and identifiers, budgets, spend, targeting settings and aggregate results (numbers of impressions, clicks and leads). Personal data of prospects from leads is not passed to the models. Only aggregate results are read from the ad accounts, not individual leads or audience lists containing names or contact details. The provider does not use this data to train its models. | EU + third countries | EU Standard Contractual Clauses |
| Google Ireland Ltd. Ireland / Google LLC, USA |
Generating ad visuals and concepts (Gemini models) | The visual brief and information about the customer’s business: industry and focus, location, scene description. Personal data of prospects from leads is not passed to the models. The provider does not use this data to train its models. | EU + third countries | EU Standard Contractual Clauses |
| Cloudinary Ltd. Israel / USA |
Hosting and conversion of images and videos used in ads | Media files uploaded by the customer | Third countries | European Commission adequacy decision (Israel); EU Standard Contractual Clauses |
| Bright Data Ltd. Israel |
Retrieving the customer’s public website when preparing a campaign | Publicly available content of the customer’s website | Third countries | European Commission adequacy decision (Israel) |
| Klaviyo, Inc. USA |
E-mail communication with Snaprime customers (news, onboarding) | Name and e-mail of the Snaprime customer | Third countries | EU Standard Contractual Clauses; EU–U.S. Data Privacy Framework certification |
Information under the Data Act
Where the rules for data processing services under Regulation (EU) 2023/2854 (Data Act) apply to Snaprime, the ICT infrastructure used for individual parts of the Service may be subject to the jurisdiction of the countries indicated for the relevant providers in the tables above. The Service uses infrastructure in the European Union and, depending on the individual component, also providers subject to the jurisdiction of third countries, in particular the United States, the United Kingdom and Israel.
To protect non-personal data stored in the European Union against international access or transfer that would conflict with the law of the European Union or of the relevant Member State, Snaprime applies appropriate technical, organisational and contractual measures, in particular encryption of data in transit and at rest, access rights management, use of European regions where available, and contractual safeguards with the providers involved. Requests from public authorities of third countries for access to such data are assessed under the applicable law, and data is not provided voluntarily where such access or transfer would conflict with the law of the European Union or of the relevant Member State.
Questions?
Write to us at info@snaprime.com. We will be happy to show you which legal instrument we use with a specific provider.