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Sub-Processors

Every document that governs the Aopy platform, published in full rather than summarised. English is the canonical text. Written for a B2B service operated from Romania under EU law.

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01Privacy Policy02Terms of Service03Cookie Policy04DPA05DPA Contacts06SMS Compliance07Data Deletion08Data Export09Sub-Processors10Data Processing Guidelines11SLA12Accessibility13Acceptable Use14Security

Easy Life Tech SRL

Șos. București-Ploiești, Nr. 15, Imobilul 2 — Spațiu Comercial, Etaj 5, Sector 1, București, România

CUI 54742254
Reg. Com. J2026033503008
EUID ROONRC.J2026033503008

privacy@aopy.com

English — canonicalLast updated 16 September 2026
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About This RegisterSub-Processor RegisterInternational TransfersCustomer-Directed IntegrationsChanges to This RegisterContactLanguage

About This Register

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.

Sub-Processor Register

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.

Sub-processorPurposePersonal data processedLocation / regionTransfer safeguard
Amazon Web ServicesEmail delivery and message-queue infrastructureContact email addresses, message content, engagement eventsEU (Ireland)Processing within the EEA
Twilio SendGridEmail delivery failoverContact email addresses, message contentUSAStandard Contractual Clauses (SCCs)
SupabaseDatabase and authenticationAll platform dataEU (Ireland)Processing within the EEA
Vercel Inc.Application hosting and CDNPlatform data in transit through the application layer, plus request metadata, IP addresses and user-agentEU edge + US control planeSCCs
StripePayments and subscriptionsBilling identity and payment references (we store only Stripe reference identifiers and masked card details — brand and last four digits; we never store card numbers)EU / USASCCs
UpstashRate limiting and background job queueingTransient request keys; queued job payloads for creative generation, which carry storage paths, generation prompts and organisation identifiersEU (Ireland)Processing within the EEA
SmartBill (Intelligent IT SRL)Issuing your invoices — SmartBill is our invoice issuer of recordBilling identity: company name, fiscal identification code (CUI), registered address and billing contact detailsRomania (EU)Processing within the EEA
Google Fonts (Google Ireland Limited / Google LLC)Web-font delivery for the sign-up popup we render on customers' storefronts and for the fonts used in campaign emailsThe IP address and browser user-agent of the storefront visitor or email recipient whose browser or email client requests the font fileEU + USASCCs and the EU-US Data Privacy Framework
Easy Life Tech SRL — internal CRMFollowing up on enquiries submitted through Aopy's own public marketing forms (see note below)Name, email address, phone number, company website and questionnaire answers of people who complete a form on aopy.comEasy Life Tech SRL (internal system), EUInternal — same controller, no transfer outside the EEA
SentryError monitoring and session diagnosticsError traces and partial request metadata; privacy-masked session replays of the Aopy application interface, recorded only when an error occurs (all text and media are masked; request and response bodies are not recorded); and any screenshot you choose to attach to a feedback reportUSASCCs
SMSO.roSMS delivery (Romania)Phone numbers, SMS message content, delivery receiptsRomania (EU)Processing within the EEA
OpenAIAI generation features — image generation, analysis of an uploaded brand guide, and marketing-copy drafting — and the in-app support assistant, which drafts a first answer to a support message you send us (optional; all of them disabled when your organisation's US-AI processing setting is off)Generation prompts, product images and brand assets you upload; and, for the support assistant, the text of the support message you write together with configuration facts about your own workspace — sending domain and its DNS status, SMS credit balance, active modules with their price, billing interval and trial state, which billing rail charges you, onboarding step and account-health warnings — no Contact Data, no campaign or message content, and nothing about your own customers or their ordersUSASCCs
remove.bg (Canva Austria GmbH)Image background removal (optional feature; disabled when your organisation's US-AI processing setting is off)Uploaded imagesAustria (EU); the provider states it may also process at facilities its affiliates or service providers maintain in other countriesProcessing within the EEA by the contracting entity; an adequacy decision or Standard Contractual Clauses for any onward transfer, per the provider's published privacy policy
ANAF e-FacturaMandatory Romanian electronic invoicing (when billing is active)Invoice and fiscal dataRomania (state authority)Legal obligation — independent public-authority recipient (see note below)
Meta, TikTok, Google Ads/GA4, Shopify, WooCommerceOptional integrations that you connect; data flows only on your instructionAdvertising audiences, product and order data; and, for the ad platforms' conversion APIs, hashed identifiers of the buyer (email address, phone number, name and address, hashed with SHA-256) together with the buyer's unhashed IP address and browser user-agent, which those APIs require in that form — depending on the integrationPer providerCustomer-directed transfers (see "Customer-Directed Integrations" below)

Note on the internal CRM: Easy Life Tech SRL operates its own EU-hosted CRM system and writes the enquiries submitted through Aopy's public marketing forms into it. Because it is a system of the same legal entity, it is not a sub-processor within the meaning of Article 28 GDPR and its use is not subject to the objection mechanism. It is listed here, and named as a recipient in our Privacy Policy, for transparency. It never receives Contact Data that customers hold on the platform.

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.

International Transfers

Our primary infrastructure is located in the European Union (AWS and Supabase in 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. The AI features are optional: image generation, analysis of an uploaded brand guide, marketing-copy drafting, image background removal, and the in-app support assistant. An organisation-level setting lets each customer disable all of them; when that setting is off, no data is sent to any of these providers for any of these features — a support message then goes straight to a person on our team, as it did before. What is transmitted is the prompt, product image or brand asset supplied for the feature, or — for the support assistant — the support message you wrote and configuration facts about your own workspace. Never Contact Data.

Web fonts. The sign-up popup we render on customers' storefronts, and the templates used for campaign emails, load their typefaces from Google's font service. Requesting a font file discloses the storefront visitor's or email recipient's IP address and browser user-agent to Google. Nothing else is sent: the request carries no Aopy cookie and no Contact Data.

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

Customer-Directed Integrations

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.

Changes to This Register

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".

Contact

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.

Language

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

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Easy Life Tech SRL

Șos. București-Ploiești, Nr. 15, Imobilul 2 — Spațiu Comercial, Etaj 5, Sector 1, București, România

CUI 54742254 · Reg. Com. J2026033503008 · EUID ROONRC.J2026033503008

2026 Easy Life Tech SRL. All rights reserved.ANPC — SALEU ODR