Loonine relies on a small number of carefully selected third-party service providers ("sub-processors") to operate the Service. This page lists every sub-processor that processes personal data on our behalf, the role they play, and the legal mechanism that governs the data transfer.

Disclosure of this list is required by GDPR Article 28(2), Brazil's LGPD Article 39, the UAE Personal Data Protection Law (Federal Decree-Law 45/2021), and California's CCPA.

1. Notice of changes

We commit to publishing any new sub-processor on this page at least 30 days before they begin processing personal data. Existing business customers under an active Data Processing Agreement may object to a new sub-processor during the notice window by writing to [email protected]. If we cannot accommodate a reasoned objection, the customer may terminate the Service without penalty in accordance with the DPA.

2. Active sub-processors

Apple Inc.

United States

Role: iOS push notifications (APNs), App Store in-app purchase processing, Apple Wallet pass delivery
Personal data received: Push notification tokens, in-app purchase receipts, pass payload data
Transfer mechanism: Apple's Standard Contractual Clauses (incorporated by reference in the Apple Developer Program License Agreement)
Provider's privacy policy: https://www.apple.com/legal/privacy/

Cloudflare, Inc.

United States (with EU edge nodes operated by Cloudflare Ireland Limited)

Role: Content delivery network, DDoS protection, TLS termination for api.loonine.com and loonine.com
Personal data received: IP addresses, request metadata, encrypted traffic in transit
Transfer mechanism: Cloudflare's Customer Data Processing Addendum incorporating Standard Contractual Clauses (Module 3)
Provider's privacy policy: https://www.cloudflare.com/privacypolicy/

iDrive Inc. (e2 storage)

United States (US East region)

Role: Object storage for business logos and loyalty card images
Personal data received: Uploaded image files, associated business identifier
Transfer mechanism: iDrive Data Processing Addendum incorporating Standard Contractual Clauses
Provider's privacy policy: https://www.idrive.com/privacy

BroadNet Technologies s.a.r.l

Lebanon (Beirut)

Role: SMS welcome message delivery to customers when they first join a loyalty program
Personal data received: Customer phone number (E.164 format) and SMS message body containing customer name, business name, and loyalty card link
Transfer mechanism: Data Processing Agreement signed under GDPR Article 28; Standard Contractual Clauses (Module 3) for transfers outside the EEA
Provider's privacy policy: https://www.broadnet.me/

Functional Software, Inc. (dba Sentry)

United States (Delaware), with EU operations through Sentry GmbH (Vienna, Austria)

Role: Application error monitoring and crash reporting (backend exceptions, iOS crash reports). Configured with send_default_pii=false and a before_send filter that drops 4xx HTTP responses to minimise the personal data ever reaching Sentry.
Personal data received: Stack traces, error fingerprints, transaction names, user role tag, business UUID tag, environment tag, sampled transaction metadata. No request bodies, headers, cookies, or IP addresses by default.
Transfer mechanism: Sentry's Data Processing Addendum incorporating Standard Contractual Clauses (Module 3) and a Transfer Impact Assessment available on request.
Provider's privacy policy: https://sentry.io/privacy/

3. What is NOT on this list

For clarity, the following providers are part of our internal stack but do not process personal data of Loonine users, and therefore are not sub-processors:

GitHub (Microsoft Corporation) - source code repository. No user data is committed to or stored in our repositories.
Phase - internal secrets manager. Stores operational credentials only (API keys, database passwords). No end-user data.
Harbor - internal container registry. Stores compiled application images only.

4. Contact

Questions about this list, or to request a copy of the underlying DPAs and Standard Contractual Clauses, write to [email protected].

Sub-processors