Data Processing & Subprocessor Policy
Version 1 · Effective 2026-09-21
This policy governs our current pre-launch submission process. The full policy set will be finalized before creator accounts open.
Effective date: 2026-09-21 · Last updated: 2026-10-12 Operator: Revolution Unlocked ("we," "us"). Full operating-entity and ownership details will be published once the platform is ready for user invites and creator access, following legal review.
1. Purpose
Lists the third parties (subprocessors) that process personal data on our behalf, what they process, and where that processing happens. This is the versioned register referenced by our Privacy Policy.
2. Subprocessors and service status
A vendor is listed as active only after actual runtime use is confirmed. A candidate or planned vendor is not an active subprocessor and is not listed here.
| Vendor | Purpose | Data processed | Region | Status |
|---|---|---|---|---|
| Hetzner | Backend hosting / compute | Platform application data (compute, database) | Helsinki, Finland (provider HQ Germany) | Active — contract/DPA status to confirm |
| Wasabi | Object storage — sole storage provider | Audio masters/derivatives, hero/artwork/merch images, founding-creator submission files, private investor data-room documents | eu-central-2 (Frankfurt) | Active — contract/DPA status to confirm |
| Cloudflare | CDN, DNS, WAF, Pages hosting, edge caching, inbound email routing, access security | Request/CDN metadata; edge-cached copies of publicly served media (rights-gated delivery audio is revalidated against a signed URL on every request, not independently readable from cache); inbound email routing metadata | Global edge network | Active — contract/DPA status to confirm |
| Stripe | Payments / payouts (payment facilitator) | Payment and payout data; we do not store full card numbers | US / global | Active — contract/DPA status to confirm |
| Google OAuth | Sign-in / identity | Auth identity, email address | US / global | Active — contract/DPA status to confirm |
| Google Gemini, OpenAI, Anthropic | SIREN AI responses — provider selected dynamically per task, not routed through one fixed model | Minimum prompt/context needed to generate that response | Provider-dependent | Active — Google Gemini is used on paid-tier terms (confirmed by Marcus, 2026-10-12); provider, DPA, and configuration verification ongoing for OpenAI and Anthropic |
| Google Analytics (GA4) | Platform-wide usage analytics, subject to the visitor's cookie choice (see Cookie Policy) | Device/browser information, IP-derived approximate location, usage and session events | US / global | Active — consent controls since 2026-09-26 |
| Notion | Internal workspace where we review founding-creator submissions, email-update signups and investor applications | Submission details (artist name, contact email, links, submission information); signup email address and date; investor application details (name, email, organization, role, links, location, experience, investment focus, notes) | US | Active — since 2026-09-26; contract/DPA status to confirm |
| Resend | Transactional email: confirmation emails to people who sign up for updates or apply to invest; one-time access codes and confirmation copies (with the signed confidentiality agreement) for invited investors; and internal notifications of new signups, submissions, applications and investor-access activity. Marketing email is not yet activated | Recipient email address; name and submission or application details in internal notifications; for investor access, the invited email address, the access code and the acceptance record | eu-west-1 (Ireland) — sending region | Active — contract/DPA status to confirm |
| Twilio | DMCA-notice informational phone line | Caller phone number and standard call/IVR metadata | US / global | Active — contract/DPA status to confirm |
| YouTube (Google) | Embedded video player on some creator pages, until creator video is hosted on the Platform. In the EEA, UK and Switzerland (and where your browser sends Global Privacy Control) the player loads only after you choose "Load video" | IP address, device/browser information and viewing data when the player loads, under Google's own policies | US / global | Active — embedded third-party content (see Cookie Policy) |
| Consent mechanism | Cookie/tracking consent choice | In-house cookie banner; the choice is stored only in the visitor's own browser (no server-side record, no third party) | Visitor's device | Active — since 2026-09-26 |
3. Safeguards
Written agreements, purpose limitation, security obligations, and international-transfer mechanisms apply where required. Each vendor's actual permitted purposes and restrictions are set by its executed contract and applicable law; this register reflects what is currently and verifiably in use, not a target state.
4. LLM data handling
Only the context necessary to answer a given request is sent to the AI provider handling it. We use Google Gemini, OpenAI, and Anthropic models, selecting the provider dynamically per task rather than routing all requests through one fixed provider — any of the three may be active for a given request. See the AI Training & Usage Disclosure for how creator content is (and is not) used in this process.
5. Changes
We update this list as vendors change, and provide notice where required by law.