Legal · sub-processors
Sub-processors
Pace-ly uses the following sub-processors to deliver the Service. Each processes personal data on our behalf under a data-processing agreement (DPA) or equivalent data-protection terms under GDPR Article 28, available on request (see below). The list reflects the sub-processors engaged today and may change as the Service evolves; we give at least 30 days’ notice before adding a new one. Subscribe to the list at support@pace-ly.com if you want to receive those notices.
| Sub-processor | Purpose | Data categories | Location | Transfer basis |
|---|---|---|---|---|
| Discord Inc. | OAuth identity provider for sign-in | Discord ID, username, email, avatar URL | United States | SCCs (Commission Decision (EU) 2021/914) |
| Stripe Payments Europe, Ltd. | Subscription billing and invoicing | Email, billing address, payment method (held by Stripe), subscription metadata | Ireland (EEA), with limited transfer to Stripe Inc. (US) | EEA + SCCs where US transfers occur |
| Anthropic PBC | AI inference (Claude API) for the race-engineer feature | Driver feedback, telemetry excerpts and prompt context per chat turn | United States | SCCs. Anthropic does not train on API inputs by default. |
| Cloudflare, Inc. | Edge hosting, Workers runtime, D1 (database), R2 (telemetry and lap-video storage), and Email Routing for inbound support mail | All Service data, including telemetry, lap video, account, billing metadata, logs | EU region jurisdictions for EU accounts (R2 location hint); some control plane in US | SCCs for any US transfer; encryption in transit and at rest |
| Resend (Plus Five Five, Inc.) | Transactional and support e-mail delivery (e.g. contact-form messages) | Recipient/sender name and e-mail address, message content, and any IP included for abuse handling | United States | SCCs (Commission Decision (EU) 2021/914) |
Data-processing terms
Each sub-processor processes personal data under its data-processing terms or a signed DPA incorporating the GDPR Article 28 obligations and, where data leaves the EEA, the Standard Contractual Clauses. To request the data-processing terms or SCCs relevant to your processing, email support@pace-ly.com; we will provide what we hold and redact non-relevant commercial terms.
Changes
When we add a new sub-processor we will (a) publish an update to this page, (b) notify subscribers to the sub-processor mailing list at least 30 days in advance for material additions, and (c) give Pro customers a right to terminate without penalty if they object to a new sub-processor handling their personal data.