Sub-processor List
Last updated 22 September 2026
This page lists the third parties that process personal data on behalf of SPEND PILOT LTD to run SpendPilot, where they process it, and why. Each is bound by a contract that requires it to protect your data and to act only on our instructions. It is part of our Privacy Policy.
1. Infrastructure
| Provider | Location of processing | Purpose | Data | Transfer safeguard |
|---|---|---|---|---|
| Hetzner Online GmbH | Germany | Servers, database and file storage for the app and its backend | All account and Service data | None needed. Data stays in the EU, which the UK recognises as adequate |
| [WEBSITE HOSTING PROVIDER, FOR EXAMPLE VERCEL INC.] | [REGION TO BE CONFIRMED] | Hosting the marketing website at spendpilot.co.uk and the waitlist form | IP address, waitlist email in transit | [DATA PRIVACY FRAMEWORK OR UK IDTA / EU SCCs TO BE CONFIRMED] |
2. AI
| Provider | Location of processing | Purpose | Data | Transfer safeguard |
|---|---|---|---|---|
| OpenAI, L.L.C. [CONFIRM CONTRACTING ENTITY] | United States | Generating meal plans, swap suggestions and explanatory text | Budget, household size, number of meals, dietary and food preference selections (with consent), plan and list contents, collected prices. No name, email, postcode or account identifiers | EU-US Data Privacy Framework and UK Extension [CONFIRM CERTIFICATION], or UK IDTA / EU SCCs. Data processing agreement in place. Not used for model training |
3. Analytics
| Provider | Location of processing | Purpose | Data | Transfer safeguard |
|---|---|---|---|---|
| Google Ireland Limited and Google LLC (Google Analytics, Google Analytics for Firebase) | European Union and United States | Understanding how the website and app are used, crash and performance data | Device and usage data, shortened IP address, app instance identifier. Only with your consent | EU-US Data Privacy Framework and UK Extension |
| Microsoft Ireland Operations Limited and Microsoft Corporation (Microsoft Clarity) | European Union and United States | Session analytics: how visitors interact with pages and screens, with typed text masked | Device and usage data, interaction recordings. Only with your consent | EU-US Data Privacy Framework and UK Extension |
4. App distribution, sign-in and notifications
| Provider | Location of processing | Purpose | Data | Transfer safeguard |
|---|---|---|---|---|
| Apple Distribution International Ltd and Apple Inc. | Ireland and United States | App Store distribution, push notification delivery (APNs) | Device push token | EU-US Data Privacy Framework and UK Extension |
| Google Ireland Limited and Google LLC | Ireland and United States | Google Play distribution, authentication via Firebase Authentication (email/password and Google sign-in), push notification delivery (FCM) | Email address and hashed password, or Google account identifier, depending on how you sign in; device push token | EU-US Data Privacy Framework and UK Extension |
5. Communications
| Provider | Location of processing | Purpose | Data | Transfer safeguard |
|---|---|---|---|---|
| [EMAIL PROVIDER NAME] | [LOCATION] | Sending account, service and waitlist emails | Email address, name if provided, email content | [TO BE CONFIRMED] |
| [SUPPORT TOOL NAME, IF ANY] | [LOCATION] | Handling support requests | Email address, support conversation | [TO BE CONFIRMED] |
6. Not sub-processors
Supermarkets. Tesco, Sainsbury's, ASDA, Morrisons and Waitrose do not process personal data on our behalf. We collect prices from their public websites; they do not receive your account, identity or dietary data from us. When you tap through to a supermarket, it acts as an independent controller under its own privacy policy.
Payment providers. SpendPilot is currently free and has no payment provider. If paid plans launch through the app stores, Apple and Google will act as merchants of record under their own terms, and this page will be updated.
7. Changes to this list
We will update this page at least 30 days before adding a new sub-processor or changing what an existing one does, except where a change is needed urgently for security reasons, in which case we will update it as soon as we can. If you object to a change you can delete your account before it takes effect. If you want to be notified of changes by email, write to [email protected].
8. Contact
Still have questions?
[email protected]