Sub-processors

Last updated: 11 October 2026

This page lists the external providers that process personal data on behalf of Roraima. It is the list required by Article 7 of the Data Processing Agreement (Article 28 GDPR) that every Vendor accepts together with their service contract.

1. Sub-processors (Article 28 GDPR)

These are the providers that process personal data on behalf of Roraima, which in turn processes it on behalf of the Vendor. By accepting the Agreement, every Vendor gives general authorisation for the use of these providers.

ProviderWhat it is used forWhere it processes the dataSafeguard for transfers outside the European Union
Hetzner Online GmbH
Gunzenhausen, Germany
Hosts the platform infrastructure: database and filesHelsinki data centre, Finland — European UnionNo transfer: processing takes place entirely within the European Union
Cloudflare, Inc.
San Francisco, United States
Protects and delivers the website traffic; routes incoming mailGlobal network: traffic is served from the network location closest to the visitorEU-US Data Privacy Framework certification and European Commission Standard Contractual Clauses
Sendinblue SAS «Brevo»
Paris, France
Sends all platform emailsServers in the European Union (France, Germany, Belgium)Data held in the European Union; Standard Contractual Clauses for support access from outside
Stripe Payments Europe, Ltd
Dublin, Ireland
Processes marketplace paymentsPredominantly European Union, United States and IndiaEU-US Data Privacy Framework certification and European Commission Standard Contractual Clauses
Think Intermedia SIA «Sendberry»
Riga, Latvia
Sends guests the SMS with the door codeCompany established in the European Union; an SMS to a foreign number also passes through the phone operators of that number's countryIts terms exclude transfers outside the European Economic Area without Roraima's written consent; delivery through the operators of a third country is necessary for the SMS to reach the guest's number

2. Provider for services where Roraima is the controller

This provider is not part of the Article 28 chain described above, because it relates to processing for which Roraima determines the purposes itself. We list it here for transparency. Details are in the Privacy Policy.

ProviderWhat it is used forWhere it processes the dataSafeguard for transfers outside the European Union
Anthropic Ireland, Limited
Ireland
Provides the artificial intelligence models behind the platform's conversational assistantsData stored in the United States; processing may take place in selected countriesEuropean Commission Standard Contractual Clauses

Under the contract, content sent to this provider is deleted within thirty (30) days and is not used to train the models.

3. Who is not a sub-processor

Some recipients receive data but decide themselves how to process it, and are therefore not Roraima's sub-processors. In particular:

  • the public authorities to which the law requires data to be transmitted, such as the Italian State Police for guest registration forms and the regional bodies for statistical surveys;
  • the payment providers, for the purposes they pursue in their own right: fraud prevention, anti-money-laundering obligations and sanctions screening;
  • the providers chosen by the Vendor, for example the manufacturer of a connected lock that the Vendor installs at their property and links to their own account.

4. How this list changes

Before a new provider receives any personal data, we update this page and give Vendors at least fifteen (15) days notice.

Within that period any Vendor may object on reasonable grounds relating to data protection. If the objection cannot be resolved, the Vendor may withdraw from the affected service before the new provider is activated.

Changes to this list follow that procedure and do not require a new acceptance of the Agreement.

To object or ask for clarification: privacy@roraima.io

Roraima — Startup di Dario Salaris, Via Firenze 16, 07039 Valledoria (SS), Italy