Subprocessor Register

#

Provider

Purpose

Data category

Region / place of processing

Transfer mechanism

Layer

1

Vercel Inc.

Hosting / serverless / frontend delivery (including aggregated web telemetry "Vercel Analytics")

App data, lead at collection where applicable

EU region (fra1); US parent

EU-US DPF (listed, as at 16.09.2026) + SCC fallback

Platform + [Lead]

2

Clerk Inc.

Authentication / identity and delivery of all profile emails (double opt-in, account creation, password reset, reward) via the sub-processor SendGrid (#10)

Email, account ID, consent flags

USA (EU residency is not available – no product feature, no commitment)

EU-US DPF (certified; dispute resolution JAMS) + SCC fallback in the DPA; EU representative: VeraSafe Ireland Ltd.; TIA maintained

Platform

3

Supabase Inc.

Database / backend and media storage (object storage) for image output

App data, consent log, lead, stylised images

EU (eu-central-1, Frankfurt); US parent

DPA + SCC 2021/914 (no DPF listing of its own – not relied on under DPF) + EU region

Platform + [Lead]

4

(discontinued – platform only)

Cloudinary Ltd. – decommissioned for the platform, no processing any more. For the website ultido.com Cloudinary continues to run, see #9c. Since the switch, image output runs via Supabase Storage (#3). The entry remains for the record.

–

–

–

–

5

Google LLC – Cloud / Vertex AI

AI image stylisation (inference), model imagen-3.0-capability-001

Photo (transient, not stored)

us-central1 (USA)

EU SCCs via the Google Cloud DPA ("Cloud Data Processing Addendum", accepted 22.07.2026)

Platform (AI) – not active in the pilot

6

GPU host (self-hosted inference) – planned entry

Planned second inference route for some style classes. No such system exists today; no processing takes place over this route. The entry will be completed with provider, region and DPA before it goes live, which then triggers the 30-day notice.

– (none at present)

(to be completed before going live)

(to be completed before going live)

Platform (AI) – not in operation

7

CCM19 (Papoo Software & Media GmbH)

Consent management (cookies, § 25 TDDDG)

Consent status, technical data

Germany

DPA (EU)

Platform

9

SnapNext GmbH + Co. KG

Operation/development of the live platform (service contract + DPA), Google Workspace tenant (Ultido as its own organization/OU), delivery of the media of ultido.com via its Cloudinary tenant

App/operational data depending on the activity; DSAR/contact mailbox

Germany (Pulheim)

DPA Ultido↔SnapNext with flow-down under Art. 28(4)

Platform + [Lead]

9b

└ Google LLC (Workspace)

Mail/docs/DSAR mailbox (max@ultido.com in the SnapNext tenant, own OU) – guest personal data possible in support/DSAR emails

Email correspondence

USA

EU-US DPF + SCC fallback

Platform + [Lead]

9c

└ Cloudinary (SnapNext tenant)

Delivery of the media of ultido.com; connection data of website visitors. Does not concern the guest app – its image output is stored in Supabase (#3)

IP, connection data

EU

via the DPA Ultido↔SnapNext (signed 22.09.2026)

Website

10

└ Twilio Inc. (SendGrid)

Technical delivery of all profile emails triggered by Clerk – double opt-in, account creation, password reset – and of the reward emails

Email, name

USA

EU-US DPF; sub-processor of Clerk (#2), passed through via its DPA

[Lead] + Reward

Annex – internal tools without guest personal data (for transparency, not sub-processors in the strict sense)

Tool

Purpose

Region

Note

Slack

Internal communication only. No product integration, no automated delivery of reports, no guest personal data (as of 18.09.2026)

US (DPF)

If an automation later writes to a Slack channel, this entry will be reassessed

Change history

Every version of this text is archived together with its checksum. All versions

Version

Date

Change

4.3.1

26.09.2026

Date reference in the annex harmonised.

4.3.0

25.09.2026

English version translated as a complete table; it now matches the German version (email delivery via Clerk and SendGrid).

4.2.2

23.09.2026

No change to the published text.

4.2.1

23.09.2026

No change to the published text.

4.2.0

22.09.2026

English version corrected: website media are delivered through the SnapNext tenant in the EU. Two open entries closed.

3.1.0

16.09.2026

Open entries replaced by the actual current state.

3.0.0

16.09.2026

Cloudinary removed. Supabase now also stores media. Region for Google Vertex AI named. The GPU provider remains only as a planned entry with no processing.

2.0.0

10.08.2026

Earliest archived version.

Version 4.3.1 · Last updated 26.09.2026