Sub-processor List
Last updated: June 2026
Maintained by: Creobyte Ltd (trading as ClearFact)
Under Article 28 of the UK GDPR, we are required to maintain a list of sub-processors engaged to process personal data on behalf of our customers (Data Controllers). This page is kept up to date and customers are notified of any changes with a minimum of 14 days’ notice.
Current Sub-processors
| Sub-processor | Purpose | Data Processed | Location | Their DPA / Privacy Policy |
|---|---|---|---|---|
| Amazon Web Services (AWS) | Document and file storage | Client documents, uploaded files | UK , eu-west-2 (London) | aws.amazon.com/compliance/gdpr-center |
| Vultr Holdings LLC | Application server hosting | All platform data in transit/processing | UK , London | vultr.com/legal/dpa |
| Stripe Payments Europe Ltd | Payment processing | Adviser billing details, payment card data | Ireland (EU) | stripe.com/gb/privacy |
| Resend Inc | Transactional email delivery | Adviser and client email addresses, email content | EU | resend.com/legal/privacy-policy |
| The SMS Works | SMS notifications | Client phone numbers, SMS message content | UK | thesmsworks.co.uk/privacy-policy |
Analytics (Marketing Site Only)
The following providers process anonymised, aggregated analytics data from our marketing website only. No personal data from the ClearFact application is shared with these providers.
| Provider | Purpose | Location | Privacy Policy |
|---|---|---|---|
| PostHog | Product analytics (anonymised) | EU | posthog.com/privacy |
| Google (via GTM) | Website analytics (anonymised) | US (SCCs in place) | policies.google.com/privacy |
Change History
| Date | Change |
|---|---|
| June 2026 | Initial sub-processor list published |
Objecting to Sub-processor Changes
If you wish to object to a change in sub-processors, please contact us at [email protected] within 14 days of receiving notification. We will work with you to find a resolution. If no resolution is possible, you may terminate your subscription in accordance with the Terms of Service.
Contact
Creobyte Ltd (trading as ClearFact)
71-75 Shelton Street, Covent Garden, London, WC2H 9JQ
Company number: 17228907
Email: [email protected]