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Sub-processors and recipients

Version 0.2 · updated October 1, 2026

English translation provided for information only: the French version is binding.

Draft text

This text is awaiting legal review (L11). It may still change.

What this is

A sub-processor processes personal data on our behalf and on our instructions. This list is generated from our technical register: a provider that is not on it receives no data, and a test blocks any release that would call an undeclared service.

Any change of sub-processor is announced by email to club admins 30 days ahead; a club may object, as the data processing agreement provides.

Sub-processors

  • netcup GmbH

    Role
    Server hosting (VPS).
    Location
    Germany
    Transfer safeguards
    No transfer outside the EU.
  • Amazon Web Services EMEA SARL (Amazon S3)

    Role
    Storage of the backups, encrypted before upload: the provider cannot read them (the decryption keys never leave our devices).
    Location
    Ireland (eu-west-1 region)
    Transfer safeguards
    Data stored in the EU. US parent company (Amazon Web Services, Inc.): EU–US Data Privacy Framework and the European Commission’s standard contractual clauses.
  • Scaleway SAS

    Role
    Delivery of transactional emails.
    Location
    France
    Transfer safeguards
    No transfer outside the EU.
  • Brevo (Sendinblue SAS)

    Role
    Transactional emails, only if our technical choice picks it instead of Scaleway.
    Location
    France / EU
    Transfer safeguards
    No transfer outside the EU.
    Status
    Used only if our technical choice picks it.
  • Stripe Payments Europe Ltd

    Role
    Billing of the Store and Brand plans (processor for part of the data, independent controller for payment, fraud and identity-check data).
    Location
    Ireland (and Stripe, Inc., United States)
    Transfer safeguards
    EU–US Data Privacy Framework and the European Commission’s standard contractual clauses.
  • OVH SAS (OVHcloud, Zimbra)

    Role
    The mailbox behind privacy@ and bonjour@: it receives your data-protection requests and support messages.
    Location
    France
    Transfer safeguards
    No transfer outside the EU.

Independent recipients

These services receive data but decide for themselves how to use it; they are not our sub-processors.

  • Stripe (Connect)

    Role
    Dues paid to a club: Stripe is the club’s own provider under its own contract (Standard account) and an independent controller of payment data.
    Location
    Ireland / United States
  • Apple Push Notification service, Google Firebase Cloud Messaging, Mozilla autopush, Microsoft WNS

    Role
    The push services chosen by your browser, if you turn notifications on: they relay an end-to-end encrypted message they cannot read and which carries no location; they see a technical endpoint, a time and a size.
    Location
    United States and EU

Providers that receive no personal data

  • GitHub, Inc. (GitHub Container Registry)

    Role
    Storage of the application’s software images before they are installed on the server (no personal data).
    Location
    United States
  • healthchecks.io

    Role
    Heartbeats of our scheduled jobs (no personal data).
    Location
    EU (to be verified)
  • UptimeRobot

    Role
    Uptime probe that calls our public health endpoint.
    Location
    To be verified
  • OVH SAS (OVHcloud)

    Role
    Domain registrar and DNS.
    Location
    France
  • Let’s Encrypt (ISRG), ZeroSSL

    Role
    Certificate authorities that automatically issue the site’s HTTPS certificate (ACME protocol); they only see the domain name.
    Location
    United States / EU (to be verified)
  • IndexNow / Bing

    Role
    Tells search engines about new public pages (public URLs only).
    Location
    United States

Never recipients

  • Artificial-intelligence tools and coding agents (Claude, Codex, ChatGPT…) never receive production personal data.

  • No Google form or spreadsheet is used for runners’ data.

  • Map data (OpenStreetMap, the Protomaps basemap) is downloaded once, when the site is built: no map or routing request leaves our server.