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.
| Provider | What it is used for | Where it processes the data | Safeguard for transfers outside the European Union |
| Hetzner Online GmbH Gunzenhausen, Germany | Hosts the platform infrastructure: database and files | Helsinki data centre, Finland — European Union | No transfer: processing takes place entirely within the European Union |
| Cloudflare, Inc. San Francisco, United States | Protects and delivers the website traffic; routes incoming mail | Global network: traffic is served from the network location closest to the visitor | EU-US Data Privacy Framework certification and European Commission Standard Contractual Clauses |
| Sendinblue SAS «Brevo» Paris, France | Sends all platform emails | Servers 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 payments | Predominantly European Union, United States and India | EU-US Data Privacy Framework certification and European Commission Standard Contractual Clauses |
| Think Intermedia SIA «Sendberry» Riga, Latvia | Sends guests the SMS with the door code | Company established in the European Union; an SMS to a foreign number also passes through the phone operators of that number's country | Its 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.
| Provider | What it is used for | Where it processes the data | Safeguard for transfers outside the European Union |
| Anthropic Ireland, Limited Ireland | Provides the artificial intelligence models behind the platform's conversational assistants | Data stored in the United States; processing may take place in selected countries | European 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