Legal · sub-processors
Sub-processors
Pace-ly uses the following sub-processors to deliver the Service. Each is bound by a Data Processing Agreement (DPA) under GDPR Article 28. We give at least 30 days’ notice before adding a new sub-processor; 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 blob storage) | All Service data, including telemetry, 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 |
Signed DPAs on file
Copies of executed DPAs are retained off-repo. To request the relevant DPA or SCCs for your processing, email support@pace-ly.com. We will 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.