Draft. This document has not yet been reviewed by a lawyer. Highlighted fields like {{…}} are details still to be provided.
BatchDog Subprocessors
Version: draft 3 · Last updated: {{EFFECTIVE_DATE}}
Companies that process personal data for BatchDog on our behalf ("processors" under GDPR Art. 28). Each one works under a data processing agreement and only on our instructions. We will update this page before adding a new processor that handles personal data. If we replace a processor (for example, the AI model provider) while the purpose, the data, the data processing agreement, the no-training commitment, the retention period and the level of protection stay the same, we update this page and announce the change in the app and in the bot at least 14 days before the switch. If the country or transfer safeguards, the retention period or the training terms change, we ask for consent again before sending health data to the new processor. A replaced processor stays listed under Former processors with its dates.
Controller: Maksim Paleyeu (Relax Games Studio), Calle Sant Ignasi de Loiola 27, piso 4, puerta 10, 46008 Valencia, Spain, hello@relaxgames.studio.
Active
| Company | What it does for BatchDog | Personal data | Where | Transfer safeguard | Agreement |
|---|---|---|---|---|---|
| Supabase, Inc. | Database and sign-in (accounts, profiles, families, pantry, recipes, menus, food diary, health data with consent) | All data stored in BatchDog | EU: AWS eu-central-1, Frankfurt, Germany. Support access may come from outside the EU | Standard Contractual Clauses | DPA: https://supabase.com/legal/dpa · Its subprocessors: https://supabase.com/legal/customer-resources/subprocessor-list |
| Cloudflare, Inc. | Hosting of the app and the API (Workers), network delivery, request logs kept 3 to 7 days | Data passing between your device and the database; IP address, device type, request logs | Global network, data processed in the nearest data centre; company in the US | EU-US Data Privacy Framework and Standard Contractual Clauses | DPA: https://www.cloudflare.com/cloudflare-customer-dpa/ |
| Anthropic (Anthropic Ireland, Ltd. for EEA customers; Anthropic, PBC) | AI model provider (current): menu generation and reading recipes from links and photos (Claude) | Menu parameters, food restrictions, pantry items, first names and calorie targets of family members in a family menu; recipe page text or photo. No Telegram ID, weight, diagnoses or diary | United States | Standard Contractual Clauses. Inputs and outputs are deleted within 30 days and are not used for training | Commercial terms and DPA: https://www.anthropic.com/legal/commercial-terms, https://www.anthropic.com/legal/data-processing-addendum · Its subprocessors: https://www.anthropic.com/subprocessors |
| PostHog Inc. | Product analytics (PostHog EU Cloud) on pseudonymous events, only for users who turned on usage statistics | Usage and service statistics events of those users from the time of consent; account, family and object IDs replaced by pseudonyms (HMAC with a key PostHog does not have). No IP address, name, Telegram ID, dishes, nutrition, weight, diary or health answers; no person profiles | EU: Frankfurt, Germany; company in the US | Standard Contractual Clauses in the DPA (EU-US Data Privacy Framework, if PostHog is certified) | DPA: https://posthog.com/dpa |
Planned
| Company | Role | When |
|---|---|---|
| Stripe Payments Europe, Ltd. (or a merchant-of-record provider) | Card payments for BatchDog+ on the web | Web launch |
| Apple Distribution International (App Store) | In-app purchases on iPhone and iPad. Apple is an independent controller for the purchase | iOS launch |
| Google Commerce Ltd (Google Play) | In-app purchases on Android. Google is an independent controller for the purchase | Android launch |
Former processors
When we replace a processor, its row moves here with the dates we used it, so this page lists every recipient your data may have gone to (GDPR Art. 15(1)(c); Washington My Health My Data Act). None yet.
Not processors
- Telegram (Telegram FZ-LLC and affiliates) runs the platform and the bot API. It is an independent controller for your Telegram account and messages, under its own policy: https://telegram.org/privacy. Payments in Telegram Stars are processed by Telegram and the app stores.
- Google Gemini is used only to draw dish illustrations for the shared recipe catalogue. No user data is sent to it.
- ExchangeRate-API (open.er-api.com) supplies the daily exchange rates for prices shown in another currency; as a fallback, the open fawazahmed0/currency-api files on jsDelivr. Our server requests the rates; no user data is sent. Rates By Exchange Rate API: https://www.exchangerate-api.com