Sub-Processors

When you use the Aopy platform to store your contacts and send them email or SMS messages, you act as the data controller of that Contact Data, and Easy Life Tech SRL ("Aopy", "we", "us") acts as your data processor, as set out in our Data Processing Agreement (the "DPA").

A sub-processor is a third-party service provider that Aopy engages to process personal data on behalf of our customers in order to deliver the Service — for example, cloud infrastructure, email delivery or error monitoring. Under Article 28(2) and 28(4) GDPR, we may use sub-processors only with your authorisation and under a written contract that imposes data-protection obligations equivalent to those we owe you.

This page is the canonical register of the sub-processors we use. Under the DPA, customers grant a general written authorisation for the sub-processors listed here. We give advance notice of intended additions or replacements, and you may object through the mechanism described in the DPA.

The table below lists each sub-processor, the purpose for which we engage it, the categories of personal data it processes, its processing location and the transfer safeguard that applies.

Note on remove.bg: we are confirming the contracting entity, processing region and transfer safeguard for this optional feature. This entry will be updated as soon as the confirmation is complete.

Note on ANAF: ANAF (the Romanian tax authority) receives invoice data because Romanian law obliges us to transmit it. Strictly speaking, ANAF acts as an independent recipient — a public authority — rather than a sub-processor within the meaning of Article 28 GDPR. It is listed here for transparency, and this transmission is not subject to the objection mechanism.

Our primary infrastructure is located in the European Union (AWS and Supabase in the eu-west-1 region, Ireland). Where a sub-processor processes personal data in the United States or otherwise outside the European Economic Area, the transfer is safeguarded by the European Commission's Standard Contractual Clauses (Decision (EU) 2021/914) or another valid transfer mechanism under Chapter V GDPR.

Control over US AI processing. AI image generation (Google Gemini and OpenAI) is an optional feature. An organisation-level setting lets each customer disable all AI image generation through US providers; when that setting is off, no data is sent to these providers. Only image-generation prompts are transmitted for this feature — never Contact Data.

To request a copy of the transfer safeguard applicable to a specific sub-processor, contact privacy@aopy.com.

The Service offers optional integrations with Meta, TikTok, Google Ads/GA4, Shopify and WooCommerce. These providers are not sub-processors engaged at our initiative: personal data flows to or from them only when you, the Customer, connect and configure the relevant integration. Those flows take place on your documented instruction, and each provider processes the data under its own terms.

The data involved depends on the integration — for example, advertising audiences for ad platforms, and product or order data for e-commerce platforms. Before connecting an integration, you should satisfy yourself that you have a lawful basis for the resulting transfer and review the provider's own privacy documentation. Practical guidance is available in our Data Processing Guidelines.

Separately from the customer-directed integrations above, Aopy uses Google Analytics, the Meta Pixel and the TikTok Pixel on its own public marketing website (aopy.com) for its own analytics and advertising, as an independent controller of site-visitor data. This does not involve Customer platform data and is not sub-processing under this register; see our Cookie Policy for details.

This page is the authoritative, current version of our sub-processor register. Each revision updates the "Last updated" date shown on this page.

Before we add or replace a sub-processor that will process personal data on your behalf, we will give you advance notice in accordance with the DPA, so that you can object within the window stated there. To receive change notifications by email, write to privacy@aopy.com with the subject line "Sub-processor notifications".

Questions about this register or our sub-processing arrangements can be addressed to our Privacy Team at privacy@aopy.com.

Easy Life Tech SRL, CUI 54742254, Trade Register No. J2026033503008, registered office: Șos. București-Ploiești, Nr. 15, Imobilul 2 - Spațiu Comercial, Etaj 5, Sector 1, București, Romania. See also our Privacy Policy and Data Processing Agreement.

This register is published in English and Romanian. In the event of any inconsistency between the two versions, the English version prevails.