This register lists the third parties ("sub-processors") that process personal data on our behalf in connection with the Stedwatch website, the my.stedwatch.com customer portal, and the optional mobile push channel. The controller is tomventures GmbH (Switzerland, CHE-284.308.806, registered in Windisch AG); contact hello@stedwatch.com; provider details are in the Impressum. It complements the Privacy Policy, which describes what we hold and why.
Local by design. The Stedwatch desktop monitor runs on your own machine and sends its monitoring data to no one. A paid Pro key (and the trial) activates online once per machine (sending only the key and a one-way anonymous machine hash) and is then verified locally; that activation data is held by us on our own EU-hosted server, not passed to any sub-processor below. The free tier performs no activation. The sub-processors below relate only to sales, the customer account, and optional push alerts, never to your monitoring or trading data.
Honesty note. The exact identity of some providers, and a signed data-processing agreement (DPA) with each processor, are still being finalised. Where a data-processing agreement is not yet in place we say so honestly (to be executed) rather than presenting it as settled. This register is updated whenever a sub-processor is added, removed, or changed.
1. Sub-processor register
| Sub-processor | Role / service | Data it receives | Location | Transfer basis | DPA status |
|---|---|---|---|---|---|
| Lemon Squeezy | Payments / merchant of record: sells the licence, takes payment, handles VAT and other applicable taxes, and issues invoices and receipts. Card and payment data are held by Lemon Squeezy and its payment processor, never by us. | Customer name, billing address, card / payment data, email, purchase and invoice data; a reference linking the account to the Lemon Squeezy order. | USA | EU/CH to US: SCCs plus EU-US DPF / Swiss-US DPF as applicable. | To be executed |
| Hetzner Online GmbH | Hosting: the dedicated server where the portal runs and where the MariaDB database and all personal data at rest live. | Everything the portal stores at rest (account email, encrypted licence keys, order reference, marketing-list entries), plus standard server access logs containing IP address and user-agent. | Germany (EU/EEA) | None needed (data stays within the EU/EEA). | To be executed |
| RunCloud | Server management panel: provisions and manages the server on the control plane. It administers the host rather than storing the portal's personal data. | Server and deployment configuration, plus administrative access to the host. | Control plane (region to confirm). | Confirm (SCCs if outside the EU/EEA). | To be executed |
| Transactional email provider (name to confirm) | Email delivery: sends the passwordless sign-in magic-link, the licence-key email, and the double-opt-in confirmation email. | Recipient email address; the sign-in link; the licence key or confirmation link in transit. | Confirm (depends on chosen provider). | Confirm (SCCs / DPF / adequacy, depending on provider and location). | To be executed |
| Marketing email provider (name to confirm) | Newsletter delivery: sends the double-opt-in marketing emails to subscribers who have consented, and handles unsubscribe links. | Subscriber email address, consent record (IP, user-agent, timestamp, source), and unsubscribe status. | Confirm (depends on chosen provider). | Confirm (SCCs / DPF / adequacy, depending on provider and location). | To be executed |
Alert transit is user-directed. When you choose to receive alerts, the transport you pick, Telegram or mobile push via Expo, Apple's APNs, and Google's FCM, carries only the alert text and a push token to your own device. You select and enable these channels, so they are a user-directed carve-out, not a Stedwatch sub-processor for stored personal data. No account or database records live with them; nothing is engaged unless you turn the channel on.
2. Scope notes
- We store, for the customer account, the following: the user's email, sign-in session data (including IP address and browser user-agent, for security), the licence key(s) (encrypted at rest, AES-256-GCM), a reference linking the account to the Lemon Squeezy order, and, for a paid or trial key, the online-activation records described in the next point. No password (passwordless magic-link), no card data.
- A paid or trial key activates online once per machine: we hold, per activation, a one-way anonymous machine hash, the activation IP address and user-agent, and first-seen and last-seen timestamps, for seat enforcement (free-tier keys perform no activation). This activation data sits on our own Hetzner server in Germany (EU/EEA) and is not shared with any sub-processor; a seat is auto-released after 30 days idle, and all of it is deleted when you delete your account. We never receive your monitoring or trading data through activation.
- The database and all personal data at rest sit on a Hetzner server in Germany, inside the EU/EEA, so no third-country transfer applies to that data.
- Card and payment data live with Lemon Squeezy as merchant of record and its payment processor, never with us. That transfer to the United States relies on the safeguards shown in the register (SCCs plus the EU-US / Swiss-US Data Privacy Framework as applicable).
- Alert transit (Telegram, and mobile push via Expo / APNs / FCM) is chosen and enabled by you, and is a user-directed carve-out rather than a Stedwatch sub-processor for stored data.
- Fonts are self-hosted; there is no Google Fonts or other font CDN embed, so no font provider appears here.
3. Changes to this register
We keep this register current and update it whenever a sub-processor is added, removed, or replaced. Material changes are reflected here with a new "last updated" date. For questions about this register or our processors, contact hello@stedwatch.com.