Сторонние сервисы
Effective date: 5/22/2026
Last updated: 5/22/2026
This page lists the third-party service providers ("subprocessors") that KungFuMoney uses to deliver the service. Each subprocessor processes personal data on our behalf under a written Data Processing Agreement, and only to the extent necessary to perform the service we have engaged them for.
This page is referenced from our Privacy Policy (section 6) and is part of our commitment to transparency under GDPR Article 28.
KungFuMoney is operated by Vitalii Mashchenko, individual entrepreneur (ФОП) registered in Ukraine. We are the data controller. The subprocessors listed below are data processors.
Current subprocessors
| # | Subprocessor | Role | Personal data processed | Location | Transfer mechanism |
|---|---|---|---|---|---|
| 1 | OVHcloud SAS | Application hosting, primary database storage, server logs | All data held in KungFuMoney's primary database (profile, financial data, sessions, subscription state, invoice records) and server log data (IP addresses, request metadata) | Beauharnois, Canada (BHS datacenter) | EU Commission adequacy decision 2002/2/EC (Canada — PIPEDA-covered commercial organizations). UK ICO adequacy regulations recognise the same. |
| 2 | Paddle.com Market Ltd | Payment processing, Merchant of Record, tax collection and remittance, billing record-keeping | Card data, billing address, billing email, transaction amount, customer ID, VAT region | United Kingdom (registered office in London) | EU Commission adequacy decision for UK data transfers (June 2021). Paddle DPA covers any onward transfers. |
| 3 | Google LLC | Sign in with Google authentication | OAuth subject identifier, email address, name (as shared by Google during sign-in) | Global (primary processing in the United States) | Standard Contractual Clauses (Modules 2 and 3) within Google's standard DPA |
| 4 | Apple Inc. | Sign in with Apple authentication | OAuth subject identifier, email address (or relay address if you chose private email), name (if shared) | Global (primary processing in the United States) | Standard Contractual Clauses (Modules 2 and 3) within Apple's standard DPA |
| 5 | Backblaze, Inc. | Encrypted backup storage (B2 cloud storage) | Full encrypted copies of the production database, retained on a rolling schedule (7 daily / 4 weekly / 6 monthly) | United States (West Coast datacenters) | Standard Contractual Clauses (Modules 2 and 3) within Backblaze's DPA. All backups are encrypted before upload. |
| 6 | Functional Software, Inc. (Sentry) | Error and crash reporting | Application stack traces, request metadata, IP addresses, and (incidentally) user identifiers present in error contexts. PII scrubbing rules are applied at ingest to strip emails and tokens. | United States | Standard Contractual Clauses within Sentry's DPA |
| 7 | PostHog Inc. (PostHog EU region) | Product analytics — feature usage, funnel analysis, debugging UX | Anonymized event data after sign-in, including IP addresses, page views, feature interactions, and an internal user identifier. Users can opt out via in-app settings; opt-out disables PostHog event collection for the user's account on all devices. | Frankfurt, Germany (PostHog EU region) | No transfer outside the EEA — data is stored and processed in the European Union. |
| 8 | Plausible Insights OÜ | Anonymous traffic analytics for our marketing site | Aggregate page-view counts only. No IP addresses, cookies, or personal identifiers are retained. | European Union (servers in Germany; company registered in Estonia) | No transfer outside the EEA. No personal data processed in a form attributable to an individual. |
| 9 | Resend, Inc. | Transactional email delivery (trial reminders, payment notifications, account events) | Recipient email address, name, email content | United States | Standard Contractual Clauses within Resend's DPA |
Additional service providers
The following third parties receive personal data but are not formally subprocessors in the GDPR Article 28 sense — they act either as independent controllers, as platform infrastructure with no access to user content, or in a strictly limited operational role.
- OpenExchangeRates — provides daily foreign-exchange reference rates. Our server fetches rates hourly using an API key; no personal data is transmitted to OpenExchangeRates.
- The Cloudflare network — used for DNS resolution and TLS termination on the marketing site. Cloudflare does not have access to KungFuMoney user data and acts as a network operator. [Confirm and remove if not used.]
- Our accountant — receives the same invoice and billing records that are retained under Ukrainian Tax Code Article 102, for the limited purpose of producing tax filings. Acts as an independent controller for those records under Ukrainian tax law.
How we evaluate and onboard subprocessors
Before engaging a new subprocessor, we assess:
- Whether the subprocessor is necessary — we prefer to do without when we can
- Whether the subprocessor offers an EU-region option, and prefer that option when available (this is why PostHog is on the EU instance, why Plausible is used in preference to Google Analytics, and why OVH was chosen over US-based hyperscalers)
- Whether the subprocessor's DPA includes Standard Contractual Clauses (or relies on an adequacy decision)
- Whether the subprocessor's security posture is acceptable — at minimum, encryption in transit, encryption at rest where applicable, and a public security and incident-response policy
- Whether the data processed is minimized to what the subprocessor actually needs to deliver its service
Notification of changes
We will update this page whenever we add, remove, or replace a subprocessor. Material changes will also be reflected in our Privacy Policy.
For changes that introduce a new subprocessor processing significant amounts of personal data, or that materially change the international transfer profile of our data, we will:
- Update this page at least 30 days before the new subprocessor begins processing personal data
- Notify users by email where the change is significant enough to warrant individual notice (for example, the addition of a new analytics or backup provider)
You can object to a new subprocessor by emailing privacy@kungfumoney.app. If the objection is well-founded and cannot be resolved, you have the right to terminate your account and export your data before the new subprocessor begins processing.
Subscribing to updates
If you would like to be notified whenever this page changes, email privacy@kungfumoney.app with the subject line "Subprocessor updates" and we will add you to a low-volume notification list (no more than a few emails per year). You can unsubscribe at any time.
Contact
For questions about subprocessors, data processing agreements, or international transfers:
Vitalii Mashchenko
Email: privacy@kungfumoney.app
For copies of specific Data Processing Agreements (subject to subprocessor confidentiality terms), email the same address and we will share what we are able to share.