Sub-processors — Subnotice

Processor: MINISAGE TECH LTD
URL: https://subnotice.com/sub-processors
Version: 1.5 · 18 July 2026 — supersedes v1.4 (5 July 2026)

Notify merchants 30 days before adding a new sub-processor. Update this file and the DPA Annex 2 simultaneously.

Pending addition — UNREVIEWED DRAFT, added 2026-08-02, awaiting counsel review. The Shopify row's "Data processed" column below has been extended to disclose that Subnotice sends Shopify billing-attempt instructions (not only OAuth/session data) once the native billing engine is enabled. This is drafting only — it is not adopted as part of the live v1.5 disclosure, and the version number above is deliberately not bumped, pending the same sign-off gate as DPA_TOS_AMENDMENTS_Q9_02-08-2026.md (§4(b)) and Q9_COUNSEL_REVIEW_PACK_02-08-2026.md. Do not treat the added text as accurate, complete, or in effect until counsel/founder sign off and this file's version is formally bumped. No other row in this file has been changed.


Current sub-processors

Sub-processor Service Location Data processed
Neon Tech Inc. PostgreSQL database (encrypted at rest) EU — Frankfurt region Shopify session and shop operational data; customer subscription snapshot; exact notice artifacts; terms observations; provider receipt payloads; pseudonymous contract/HMAC identifiers; event hashes and delivery/engagement timeline; WooCommerce site/reminder records
Vercel Inc. Application + website hosting, serverless functions (compute, TLS termination) US (region per project config) Same application data in transit during compute/export; policy text submitted to the audit API (processed in memory, not stored by Subnotice); standard platform HTTP request logs (IP, path, timestamp)
Resend Inc. Transactional reminder email delivery, delivery/open-event webhooks US Customer name and email address; reminder subject/body; provider message/event identifiers; delivery/bounce/open events, subject to Resend's service retention terms
Shopify Inc. Platform OAuth, API, webhooks, App billing Canada / global Merchant staff session via OAuth; Shopify acts as independent controller for its own platform data. [UNREVIEWED DRAFT addition, 2026-08-02 — pending counsel review, not yet in effect] Where the Controller enables Subnotice's native billing engine, Subnotice also sends Shopify billing-attempt instructions — subscription contract reference, billing-cycle date, requested charge amount/currency, and an idempotency key — via Shopify's subscriptionBillingAttemptCreate API, and separately queries Shopify for the resulting attempt status (succeeded / failed / requires action) and, on success, the resulting order reference and amount actually charged. Subnotice does not send or receive card data in this call; see DPA §2 (as amended, pending)
Freemius Inc. WooCommerce plugin licensing/billing (paid "Compliance Complete" tier only, not yet released for purchase) US Merchant site URL, hashed API token, declared jurisdiction, reply-to email (once released)

Evidence for the pending Shopify-row addition above (verified in code as of 2026-08-02, not asserted as legally sufficient): the only file in the codebase that calls a charge-triggering Shopify API is app/uk-subscription-guard/app/lib/billing/shopify-billing-executor.server.ts. Its submit() method (lines 251–288) calls the subscriptionBillingAttemptCreate GraphQL mutation (defined lines 71–125), sending contractId, idempotencyKey, originTime, and billingCycleSelector.date as input; its pollStatus() / findRecentAttempt() methods (lines 290–346) query Shopify for the resulting attempt state, order id, and charged amount/currency. app/uk-subscription-guard/app/lib/billing/charge-executor.ts (lines 1–17) records this as the sole locked production charge path (SHOPIFY_BILLING_ATTEMPT_AUTHORITY, 2026-07-18). No raw card fields (cardNumber, cvv, pan, or equivalents) are constructed or sent anywhere in this file or elsewhere under app/lib/billing/.


Removed / never used

Sub-processor Reason
Fly.io Not selected
Supabase Inc. Not selected; using Neon instead
Render Services Inc. Listed in v1.1 in error / superseded — hosting is Vercel; never processed production data

Change log

Date Change
2026-05-19 Initial skeleton v1.0
2026-05-26 v1.1 — filled in MINISAGE TECH LTD; confirmed Neon EU + Render US; removed unused Fly/Supabase; moved Resend to planned
2026-07-02 v1.2 — corrected hosting: Render → Vercel Inc. (actual host of app.subnotice.com, subnotice.com, and the /api/audit endpoint); added policy-text-in-transit + platform request logs to Vercel data column (checker/Woo plugin flows). 0 live merchants at time of change — no 30-day notice cycle triggered
2026-07-04 v1.3 — Resend Inc. moved from "planned" to current/active (reminder-email + delivery/open-tracking features shipped and live); this file was stale relative to Privacy Policy v1.2 §4 and DPA v1.1 Annex 2, which already listed Resend as current. 0 live merchants at time of change — no 30-day notice cycle triggered
2026-07-05 v1.4 — added Freemius Inc. (WooCommerce paid-tier licensing/billing, not yet released for purchase — added now so this file and DPA Annex 2 aren't stale relative to Privacy Policy v1.4 the moment it published); corrected Neon's data column to include the customer subscription snapshot and WooCommerce site record (both were already disclosed in Privacy Policy/DPA but missing here); corrected stale "read live, not persisted" framing on Resend's row (customer data is persisted upstream in Neon; Resend itself still doesn't persist it, wording just clarified). 0 live merchants at time of change — no 30-day notice cycle triggered
2026-07-18 v1.5 — added Evidence Assistant categories (exact notice artifacts, terms observations, provider receipt payloads, pseudonymous identifiers and hashes); removed the unsupported claim that Resend never persists message content; no new sub-processor added
2026-08-02 DRAFT NOTE (not adopted, no version bump): Shopify row's "Data processed" column drafted to disclose billing-attempt instructions (Q9 native-billing gate); pending counsel review — see DPA_TOS_AMENDMENTS_Q9_02-08-2026.md §4(b). File remains live at v1.5 until this is reviewed and formally adopted. No new sub-processor added — Shopify was already listed