BotSubscription Sub-Processors List
This page lists the sub-processors that BotSubscription engages to process personal data on behalf of our customers (Bot Owners) as part of providing the Platform. This list is maintained in accordance with our Terms of Service and Data Processing Addendum.
What is a Sub-Processor?
A sub-processor is a third-party service provider that processes personal data on our behalf to help us deliver the Platform. Under GDPR Article 28, we are required to maintain a list of sub-processors and notify you of changes.
Not sub-processors (typically):
- Your chosen payment processors (e.g., Stripe, PayPal, NowPayments) are generally not our sub-processors for your Subscriber transactions—they are independent controllers/processors with whom you (the Bot Owner) have a direct relationship.
- Telegram and Discord are platforms you use directly; we integrate with their APIs but they are not processing data on our behalf as our sub-processors.
Current Sub-Processors
Infrastructure, Hosting & Delivery
| Sub-Processor | Purpose | Data Processed | Location |
|---|---|---|---|
| Hetzner Online GmbH | Cloud hosting, servers, databases | Platform data including Bot Owner account data and Subscriber-related data required to deliver the service | Germany (EU) |
| Amazon Web Services, Inc. (AWS) | Infrastructure services (e.g., compute, managed databases, serverless functions) | Platform data processed/stored in connection with the workloads and regions we use | Global (US-based; region-dependent) |
| OVHcloud | Cloud hosting / servers | Platform data processed/stored in connection with the workloads we run on OVH infrastructure | EU (France) |
| Fly.io | Application hosting / compute services | Application data and logs required to operate services deployed on Fly infrastructure | United States (per Fly privacy disclosures) |
| bunny.net | CDN, edge delivery, storage/backups and related services (as used) | IP addresses, request metadata, cached content and files depending on configuration | EU-based with global network (location depends on configuration) |
| Cloudflare, Inc. | CDN, DDoS protection, WAF/security, DNS, edge proxying/workers (as used) | IP addresses, request metadata, security logs; content and configuration data depending on features enabled | Global (US-based; global data centers) |
Business Operations
| Sub-Processor | Purpose | Data Processed | Location |
|---|---|---|---|
| Stripe, Inc. | Platform billing (BotSubscription's own billing to Bot Owners) | Bot Owner billing/contact details and payment metadata for our platform fees (not Subscriber checkout processing unless you separately use Stripe) | United States |
Data Transfer Safeguards
For sub-processors located outside the EEA/UK, we rely on appropriate safeguards including:
- Standard Contractual Clauses (SCCs) approved by the European Commission (and UK addendum where applicable)
- Data Processing Agreements with each sub-processor
- Adequacy decisions where applicable
- Data Privacy Framework participation where applicable (for certain providers)
Details of specific safeguards are available upon request.
Change Notification
We will notify you of intended changes to this sub-processor list at least 30 days before the change takes effect, unless a shorter period is required for urgent security, legal, or operational reasons (in which case we will provide notice as soon as reasonably practicable).
Notifications may be sent via:
- Email (if you have provided one) — primary notification method
- Dashboard notification — for all users
- Public channels (Discord, Telegram announcements) — supplementary notice
If you object to a new sub-processor and we cannot reach a mutually acceptable resolution, you may terminate the Service before the sub-processor is engaged, as described in our Terms of Service.
Change Log
| Date | Change | Effective Date |
|---|---|---|
| 22 January 2026 | Initial publication | Immediate |
Questions?
If you have questions about our sub-processors or data processing practices, contact us at [email protected].
Last updated: