Sub-processors

Effective from: 14 October 2026. Last updated: October 2026. Previous versions: available on request at legal@complete-solution.eu.

This page lists the sub-processors engaged by Complete solution s. r. o. (IČO 56693371) for the processing of personal data on behalf of our clients. We update this list when sub-processors are added or replaced and notify clients with active Data Processing Agreements at least 30 days in advance. To subscribe to update notifications, email privacy@complete-solution.eu.

1. Vitrina Platform — Sub-processors

Providers that Complete solution s. r. o. engages under its own contracts to run the Vitrina Platform for a client. Each client has a separate deployment and a separate database.

Appendix IV (Part A) to the Data Processing Agreement signed with a client (Schedule 2 to the Master Agreement) is an extract of this section for that client's deployment as at the date of signing, with the rows that are not enabled in the deployment removed. This page is updated before or at the same time as the 30-day notice to clients; until the notice period has expired, the signed Appendix IV prevails over this page.

Sub-processorLocationPurposePersonal Data CategoriesTransfer MechanismWhen engaged
Railway Corp.USA (company); processing region selected per deployment, an EU region where the provider offers itHosting of the back end and the PostgreSQL database, scheduled jobs, nightly backup jobAll client personal dataEU-US Data Privacy Framework (where the provider is certified) or SCC 2021/914 Module 3Always
Vercel Inc.USA (company); function region selected per deploymentHosting of the ordering website and the admin panelIP addresses, request data, data passing through server-side page rendering, session cookies, images uploaded by guests during image optimisationEU-US Data Privacy Framework (where the provider is certified) or SCC 2021/914 Module 3Always
Cloudflare, Inc. — R2 storageUSA (company); buckets without the EU jurisdiction: the storage location is not guaranteed by the provider, even where a location hint is set for the bucketStorage of images and of encrypted database backupsAvatars and photos; all client personal data in encrypted form (backups are AES-256-encrypted before upload)EU-US Data Privacy Framework (where the provider is certified) or SCC 2021/914 Module 3Always
Cloudflare, Inc. — proxy, DNS and TurnstileUSA (company); global networkProxying of traffic to the back end with TLS termination; bot verificationData passing between users' devices and the back end (not stored, except the provider's technical logs); IP addresses; browser or device data; verification tokensEU-US Data Privacy Framework (where the provider is certified) or SCC 2021/914 Module 3Where the DNS of the client's domain and the verification widget are managed in our account
GitHub, Inc.USA; standard GitHub-hosted runners of GitHub Actions, no region is selectedWeekly backup restore test (temporary deployment of a full database copy)All client personal data, temporarily during the testEU-US Data Privacy Framework; SCC 2021/914 incorporated in the GitHub Data Protection AgreementAlways
Sentry (Functional Software, Inc.)USA (company); data stored in the EU (Germany) ingest regionError monitoring and sampled performance tracing of the back end, the website and the appsTechnical error context: user identifier, request URL after scrubbing, device dataEU-US Data Privacy Framework (where the provider is certified) or SCC 2021/914 Module 3Always
Expo (650 Industries, Inc.)USABuilding and signing of the mobile apps; relay of push notificationsPush tokens, text of push notifications; the app builds contain no client personal dataEU-US Data Privacy Framework (where the provider is certified) or SCC 2021/914 Module 3With the guest mobile apps
Google (Google LLC / Google Ireland Limited) — Firebase Cloud Messaging, Google Play ConsoleUSA / IrelandDelivery of push notifications to Android devices; publication of the Android apps under our developer accountPush tokens, text of push notifications; device data in crash reports; names of the authors of public ratings and reviewsEU-US Data Privacy Framework (where the provider is certified) or SCC 2021/914 Module 3With the guest mobile apps
Resend (Plus Five Five, Inc.)USASending of emails (verification codes, receipts, order notifications)Email address, name, email contentEU-US Data Privacy Framework (where the provider is certified) or SCC 2021/914 Module 3Where the sending account is ours (otherwise see section 2)
OpenAIUSAGuest AI assistant; drafting of replies to and translations of reviews; recognition of supplier invoices; transcription of procurement dictationText of the guest's conversation with the assistant, review texts, invoice images and text, audio recordings of procurement dictationEU-US Data Privacy Framework (where the provider is certified) or SCC 2021/914 Module 3With the AI modules, only where the API key is ours (otherwise see section 2)
Anthropic PBCUSADaily analytics report for the owner and managersAggregated daily figures; reasons for cancellations, refunds and write-offs entered by staff, with email addresses, long digit sequences and street addresses replaced by labels before sendingEU-US Data Privacy Framework (where the provider is certified) or SCC 2021/914 Module 3With the analytics report, only where the API key is ours (otherwise see section 2)
Anthropic PBCUSAAI assistant for development and technical support used by our staffFragments of logs, configuration and data of a deployment that our staff open to the tool when resolving incidentsEU-US Data Privacy Framework (where the provider is certified) or SCC 2021/914 Module 3Only where our staff give the tool access to the logs, configuration or database of a deployment
AlphaSMS (Ukraine) or Twilio Inc. (USA)Ukraine / USASMS with one-time codes and notificationsTelephone number, SMS textAlphaSMS: SCC 2021/914 Module 3 (Ukraine has no adequacy decision); Twilio: EU-US Data Privacy Framework (where the provider is certified) or SCC 2021/914 Module 3Where the SMS account is ours (otherwise see section 2)
VisicomUkraineGeocoding and delivery address suggestionsAddress text, coordinatesSCC 2021/914 Module 3 (Ukraine has no adequacy decision)Delivery in Ukraine, where the API key is ours (otherwise see section 2)
Google (Google LLC / Google Ireland Limited) — Places API, Sign in with GoogleUSA / IrelandAddress and place search; sign-in with GoogleAddress queries; Google identifier, email address, profile name and photoEU-US Data Privacy Framework (where the provider is certified) or SCC 2021/914 Module 3Where the API key and the OAuth client are ours (otherwise see section 2)
Telegram Messenger Inc.Outside the EEATechnical notification channel of our staff (errors and alerts of a deployment)Technical error texts and alerts: internal record identifiers, time, amounts, request paths; email addresses, telephone and card numbers, IP addresses and chat identifiers are replaced with labels before sending; no names, delivery addresses or guests' messagesTelegram acts as an independent controller under its own terms; only the filtered technical data described here are sentAlways

2. Vitrina Platform — Services Connected Under the Client's Own Contract

For information only. These services are not our sub-processors: the client (or its establishment) holds the contract and the account or key, and the Platform transfers data to them on the client's instructions. They are listed in Part B of Appendix IV of the client's Data Processing Agreement and in the client's own privacy notice. Only the services enabled in a given deployment are used.

ServiceFunctionNote
LiqPay (JSC CB «PrivatBank»), Stripe, monobank, WayForPayOnline payment, card saving, refundsThe guest enters card details on the provider's page; the provider processes payment data as a controller under payment services law
Acquiring bank of the client — payment terminalCard payment at the outletCard data are read by the terminal and are not received by the Platform
Checkbox, Nine Digit eKasa, fiskaly, efstaFiscalisation of payments (by country)Receipt data are transmitted to the tax authority as required by law
AlphaSMS, TwilioSMS with one-time codes and notificationsWhere the SMS account belongs to the client
VisicomGeocoding and delivery address suggestionsWhere the API key belongs to the client
Google — Sign in with Google, Places API, Business ProfileSign-in; public reviews and replies to themWhere the OAuth client and the API key belong to the client
Meta Platforms Ireland LimitedSign in with FacebookWhere the Meta app belongs to the client
Apple (Apple Inc. / Apple Distribution International Ltd.)Publication of the iOS app, push notifications to iOS devices, Sign in with AppleUnder the client's Apple Developer Program account, to which we have access within the role granted
Telegram Messenger Inc.The client's bots: guest support, ordering, staff botsTelegram acts as an independent controller under its own terms
OpenAI, AnthropicAI modules (assistant, reviews, invoices, analytics report)Where the API key belongs to the client — the default configuration of a deployment
Wolt Drive, Glovo On-Demand, Bolt DeliveryDelivery of the client's orders by the aggregator's couriersThe guest's name, telephone number, delivery address and coordinates are transferred
Glovo Partners, Wolt Merchant, Bolt FoodReceiving orders placed on marketplacesMenu, prices, stop list and order statuses are sent; order data are received from the marketplace

3. Custom Development Projects

Engaged on a per-project basis, only where a custom development engagement requires. The sub-processors actually used in a given project are documented in the Principal Agreement or Statement of Work. Clients may request alternative sub-processors or restrict transfers to specific regions during contract negotiation.

Sub-processorLocationPurposePersonal Data CategoriesTransfer MechanismWhen engaged
Amazon Web Services EMEA SARLEU (eu-central-1 Frankfurt by default; other regions on request)Cloud infrastructure, storage, computeAll client-defined data categoriesEU controller; data residency in EUPer project
Cloudflare, Inc.Global edge network, EU regions prioritizedCDN, DDoS protection, edge computeIP addresses, request metadataSCC 2021/914 + EU-US DPFPer project
Sentry (Functional Software, Inc.)USA (with EU region available on request)Error monitoring and performance trackingStack traces, IP addresses, user IDsSCC 2021/914 + EU-US DPFPer project
Neon Inc. / Railway Corp.USA (with EU region)Managed PostgreSQL hostingAll client-defined data categoriesSCC 2021/914Per project
OpenAI Ireland Ltd. (EU entity)EU (with US fallback)LLM API for AI featuresPrompt and response content as configured by clientEU controller relationship; SCC 2021/914 for US fallbackPer project
Anthropic PBCUSA (with EU data processing zone)LLM API (Claude) for AI featuresPrompt and response content as configured by clientSCC 2021/914 + EU-US DPFPer project

4. Our Own Website

For the website complete-solution.eu (analytics, hosting, contact forms and newsletter) Complete solution s. r. o. acts as controller, not as processor for clients. The services used there are described in our Privacy Policy.

Personnel

Client personal data are accessed only by personnel of Complete solution s. r. o. (Slovak Republic) who are bound by confidentiality obligations. Where personnel or sub-processors outside the EEA are engaged, this list is updated under the 30-day notice procedure and the transfer relies on Module 3 of the SCC 2021/914 supplemented by a transfer impact assessment, which is provided on request.