Legal
Sub-processors
Last updated: 20 August 2026
01
1. What this list is
This is the complete list of third parties that process personal data on our behalf, published under Art. 28(2) GDPR. It is also the notification mechanism our Data Processing Agreement points at: when we add a processor we publish it here before it starts processing, and a customer may object.
Every entry names what the provider actually receives. "Everything" means everything, and we say so where it is true rather than writing "infrastructure services".
Subscribe to changes, or object to one, at [email protected].
02
2. Infrastructure
Where the platform runs and where the data lives.
| Provider | Country | What it receives |
|---|---|---|
| Hetzner Online GmbH | Germany (EU) | Hosting for the application, the database and the geo stack — in practice every piece of data in TOVR |
| Cloudflare, Inc. | US company, EU edge | Ingress tunnel: all HTTP traffic and client IP addresses |
| Amazon Web Services | Germany, eu-central-1 (EU) | SES for transactional email; S3 for uploaded documents, organisation logos and support attachments |
03
3. Billing and product analytics
| Provider | Country | What it receives |
|---|---|---|
| Stripe | Ireland and United States | Organisation name, billing address, VAT number, invoices and payment status |
| PostHog EU Cloud | Germany (EU) | Product analytics, error tracking and session replay — only where the user has consented |
04
4. AI and machine learning
This is the section that matters most, because it is where the widest range of data leaves our infrastructure. None of these providers may use our data to train their models; that is contractual, not a hope.
| Provider | Country | What it receives |
|---|---|---|
| Anthropic | United States | The primary LLM: chat transcripts, freight data, contact names and email addresses, negotiation email bodies, carrier-contact profiling |
| Google (Gemini) | EU and United States | Document embeddings |
05
5. Voice and telephony
Used where a customer runs outbound or inbound calls through the platform.
| Provider | Country | What it receives |
|---|---|---|
| Telnyx | United States | Telephony: phone numbers and call audio |
| Deepgram | United States | Speech-to-text on call audio |
| ElevenLabs | United States | Text-to-speech |
| Cartesia | United States | Text-to-speech |
06
6. Messaging and connected mailboxes
Only where a user connects the channel.
| Provider | Country | What it receives |
|---|---|---|
| Telegram | Outside the EU | Messaging identifiers, including phone numbers, and message contents |
| WhatsApp / Meta | Ireland and United States | Messaging identifiers, including phone numbers, and message contents |
| Google Workspace APIs (Gmail, Calendar, Drive) | EU and United States | Where a user connects their mailbox: message contents, calendar entries and files |
| Microsoft Graph | EU and United States | Where a user connects their mailbox: message contents and calendar entries |
07
7. Freight exchanges and market data
Connected by the customer, using the customer's own credentials.
| Provider | Country | What it receives |
|---|---|---|
| TIMOCOM | EU | Shipment and vehicle listings, company identity |
| LKW Walter | EU | Shipment listings, company identity |
| Trans.eu / Teleroute | EU | Shipment and vehicle listings, company identity |
| Lardi-Trans | EU | Shipment and vehicle listings, company identity |
| Cargopedia | EU | Shipment listings, company identity |
| Saloodo | EU | Shipment listings, company identity |
| CargoRadar | EU | Vehicle availability and shipment listings |
| Transporeon / Trimble | EU | Shipment listings; geocoding fallback, which receives addresses |
| VIES (European Commission) | EU | VAT numbers, for validation |
08
8. Telematics
Connected by the carrier. These are the sources of vehicle positions and of driver records including tachograph hours — see the notice for drivers and contacts.
| Provider | Country | What it receives |
|---|---|---|
| Frotcom | EU | Vehicle identifiers; supplies positions and driver records |
| Mapon | EU | Vehicle identifiers; supplies positions and driver records |
| Wialon | EU | Vehicle identifiers; supplies positions |
| OBS | EU | Vehicle identifiers; supplies positions and match data |
| Volvo | EU | Vehicle identifiers; supplies positions |
| ZF Transics | EU | Vehicle identifiers; supplies positions and driver records |
09
9. What never leaves our infrastructure
Two things that most platforms buy as a service, we run ourselves — and it is a privacy advantage, not only a cost one:
• Address search and geocoding runs on our own Photon instance. When you type an address into TOVR, that address is not sent to Google, HERE or Mapbox.
• Route calculation and distances run on our own Valhalla instance. Origins, destinations and route geometry are not sent to a routing provider.
Both are built from OpenStreetMap data — see Attributions. Transporeon/Trimble appears in section 7 as a geocoding FALLBACK only, used when our own lookup cannot resolve an address.
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10. Changes
We publish a new processor here before it starts processing personal data. Customers under a DPA may object, and we will either address the objection or allow the customer to terminate the affected part of the service.
The date at the top of this page is the date of the current list.