Subprocessors
Who handles your data when we don’t
The named list of third parties Recoupex shares data with — what each one processes, the category of data it sees, the region the processing happens in, and the legal basis that governs the transfer.
Effective date: 2026-08-16
1 — Why this page exists
The artifact prospects ask for before they sign
Mid-market and enterprise buyers ask the same question before signing Recoupex: who else is going to touch my data? This page is the answer — it is the named subprocessor list referenced from our privacy policy, and we update it before any new subprocessor starts receiving production data.
The names below are the processors that touch customer data today. If a new one is added or an existing one is replaced, we will announce the change in-product and update the effective date at the top of this page.
2 — The subprocessor list
Processors, purposes, regions, basis
Each row names the processor, what they process, the category of data, where the processing happens, and the legal basis that governs the transfer.
| Processor | What they process | Data category | Region | Basis |
|---|---|---|---|---|
| Stripe | Payment processing for one-time purchases and recurring subscriptions. | Checkout receipt + subscription metadata (amount, currency, plan id, billing interval). | US — Stripe, Inc. | Stripe DPA + EU Standard Contractual Clauses (SCCs) for transfers from the EEA / UK. |
| Better-auth (via the Polsia auth proxy) | Session issuance and verification for sign-in. | Hashed credentials + session metadata (sign-in email, session id, expiry). | EU — Polsia-managed Postgres in the EU region. | Data Processing Agreement with Polsia as the controller’s processor; no sub-data export. |
| Polsia AI proxy | Draft generation — the LLM call that produces outbound message drafts. | Per-tenant prompt content: the lead row, segment definition, and prior drafts the operator elected to reference. | US — model endpoints reached through Polsia’s AI proxy. | No provider key held by the app; prompts are routed through the proxy, no training on customer data. |
| Polsia email proxy | Transactional and outreach email delivery and reply threading. | Message bodies + recipient addresses + the `replyToEmailId` that threads a reply back onto its lead. | EU — Polsia-managed egress. | Data Processing Agreement with Polsia as the controller’s processor. |
| Managed Postgres (Polsia) | Application data storage for the workspace. | Tenant-scoped workspace rows: leads, segments, message drafts, message history, billing metadata. | EU by default; US per the region you selected at signup. | Data Processing Agreement with Polsia as the controller’s processor; transport-encrypted (TLS) at rest. |
Stripe operates the payments surface for EU customers as Stripe Payments Europe Ltd., which is the EU-controller leg of the same Stripe data-processing relationship.
3 — DPA summary
Retention, breach notification, and processor commitments
Retention. Per-tenant workspace data is retained while the account is active and for a 30-day export window after account deletion, after which the rows are hard-deleted on our side. Billing receipts are retained for the longer of (a) the period required by our payment processor to support chargebacks and refunds, or (b) the period required by applicable tax and corporate record-keeping law.
Breach notification. We notify affected customers without undue delay, and in any case within 72 hoursof becoming aware of a personal-data breach affecting their tenant, with the information required under GDPR Art. 33(3) — the categories of data affected, the approximate number of records, the likely consequences, and the measures taken or proposed to address it.
Processor commitments.Every subprocessor on the list above is bound by a written data-processing agreement (DPA) and, where data crosses borders outside the EEA / UK, by the European Commission’s Standard Contractual Clauses (SCCs) or an equivalent transfer mechanism. Subprocessors process only on our documented instructions, may not use the data for their own purposes, and are subject to confidentiality, security, and audit obligations at least equivalent to those we owe our customers.
4 — Changes to this page
How updates ship
We update the effective date at the top of this page whenever the subprocessor list changes. We will not on-board a new subprocessor without first updating this page and announcing the change in-product; for material additions we give a reasonable heads-up before the new processor starts receiving data.
Non-material changes (a clearer description, a corrected URL, a regional clarification) update silently with the effective date bumped at the top.
5 — Contact
Questions about a processor or this list
For anything on this page — a question about a processor, a request for the underlying DPA, a transfer-mechanism detail, or a complaint — write to recoupex-ni4aa2@polsia.app. We reply from the same address and aim to acknowledge within two business days.
This page is offered in English. If translations are added later, the English version here stays the source of truth.