Sub-processors
Last updated: 1 September 2026
This page lists every provider that touches personal data in connection with the WalletWallet Service, what each one does, and the legal mechanism that covers it. It is the authoritative list referenced by our Data Processing Agreement and mirrors Section 5 of the Privacy Policy.
Sub-processors of Customer Content and End-User data
Providers that process pass content and End-User device data on our behalf and on our instructions, under Article 28 GDPR:
| Sub-processor | Activity | Location | Transfer mechanism |
|---|---|---|---|
 Cloudflare, Inc. |
Hosting, database (D1), object storage (R2), delivery | EU storage, global edge processing | EU SCCs (Cloudflare DPA); EU Cloud Code of Conduct verification |
Customer and pass data is stored at rest in Cloudflare’s European Union region: the primary database and the pass object store both run in Cloudflare’s EU location, with no replicas outside it. Request processing runs on Cloudflare’s global edge network, so compute is not EU only, and traffic is encrypted in transit throughout.
Wallet platforms (independent controllers)
Apple and Google receive pass data because that is where your End Users install their passes. They act under their own terms, not as our sub-processors:
| Provider | Data received | Location | Transfer mechanism |
|---|---|---|---|
 Apple Inc. |
Device push tokens, pass identifiers | US | Apple terms (SCCs / EU-US DPF) |
 Google LLC |
Pass object data | US | Google terms (SCCs / EU-US DPF) |
Providers for our own controller-side data
These providers process data for which WalletWallet is the controller (your account, billing, and analytics), never your pass content:
| Provider | Role | Data | Location | Transfer mechanism |
|---|---|---|---|---|
 Polar |
Independent controller, merchant of record | Email, card and billing details | US | Provider terms (SCCs / DPF) |
 Loops |
Processor | Email address (transactional email) | US | EU SCCs |
 PostHog |
Processor | Email (as identifier), usage and technical data | EU (EU-hosted) | EU hosting; SCCs where applicable |
Change notifications
We update this page, with a dated entry in the changelog below, at least 30 days before a new or replacement sub-processor begins processing Customer Content or End-User data. To receive these notices by email, write to [email protected] with the subject “Sub-processor notifications”. Customers may object on reasonable data-protection grounds as set out in the DPA.
Changelog
- August 2026: Pass content and signed pass files moved to Cloudflare R2 object storage in Cloudflare’s EU region, making all customer and pass data EU-located at rest. No change of provider.
- June 2026: Google Wallet support launched. Google LLC added as a wallet platform (independent controller).
- April 2026: PostHog added for product analytics (EU-hosted, processor, controller-side data only). Polar added as merchant of record for paid subscriptions (independent controller).
- February 2026: Baseline: Cloudflare, Inc. for hosting, database, and object storage (processor); Apple Inc. as wallet platform (independent controller); Loops for transactional and verification email (processor).