Sub-processor List

When this list changes, Subscribers are notified at least 30 days before the change takes effect (Data Processing Agreement §5.3).

1. Sub-processors

• Hetzner Online GmbH — Service: Server and database hosting · Data processed: All Business Data and account data · Location: EU — Falkenstein, Germany · Transfer basis: None (within the EU)
• Hetzner Online GmbH (Object Storage) — Service: Storage of personnel documents and profile photos · Data processed: Personnel file documents, profile photos · Location: EU — Falkenstein, Germany · Transfer basis: None (within the EU)
• Google Ireland Ltd. / Google LLC — Service: Firebase Cloud Messaging — mobile notification delivery · Data processed: Device notification token, notification title and body · Location: EU / USA · Transfer basis: Standard Contractual Clauses; EU-US Data Privacy Framework while certified
• Resend — Service: Sending notification and transactional email · Data processed: Recipient name and email address, message content · Location: USA · Transfer basis: Standard contractual clauses (GDPR art. 46(2)(c))
• Nivorbit Teknoloji Limited Şirketi (Nivorbit, Türkiye) — Service: Operation and support of the Service by the processor's own staff · Data processed: What a support case requires · Location: Türkiye · Transfer basis: Standard Contractual Clauses, module two

A note about notification content. The title and body of a notification pass through Google's infrastructure and may contain personal data such as an employee's name or a shift time. Notifications can be turned off in Settings; once they are off, no data enters this channel.

2. Parties that are not sub-processors

The following are not sub-processors of Nivorbit; for the service they themselves provide they are independent controllers. Nivorbit is not responsible for their processing, and their own privacy policies apply to you.

• Google, Apple, Microsoft — Role: Identity provider (signing in to Vardify) · Why it is not a sub-processor: They authenticate you through your own account with them; only a verified identity is returned to Nivorbit.
• Paddle.com Market Ltd — Role: Online reseller and Merchant of Record for subscription orders · Why it is not a sub-processor: Paddle sells in its own name and processes the payment and billing data as a controller in its own right; it has no access to Business Data.
• Accountant, auditor, legal counsel — Role: Nivorbit's own obligations · Why it is not a sub-processor: They relate to Nivorbit's account data; they have no access to Business Data.

3. Technologies deliberately not used

The following are deliberately absent, and that choice is structural to the product:

• Biometric data and facial recognition — special category data under art. 9; clock-in verification is done with device binding, a consent-based one-shot location read and anomaly signals.
• Continuous location tracking — location is read only at the moment of the scan.
• Third-party advertising and tracking cookies — none in the panel or the mobile app.
• Behavioural analytics / session replay — not used.