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    Subprocessors
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    Subprocessors

    Subprocessors and processing records

    Last updated: 28 October 2026 — disclosed under GDPR Articles 13, 28(2) and 30. Controller: RUFF UNIT SRL (Tax ID 53176530), Bucharest, Romania.

    Who processes personal data for us

    Jam House uses the providers below to process personal data on its behalf. Each is bound by a Data Processing Agreement (DPA) with at least the protections of GDPR Article 28(3). Public authorities receiving data as required by law (ANAF) are also listed and identified as such.

    A new subprocessor is added to this page and the Privacy Policy at least 30 days before receiving any data. To object, email privacy@jamhouse.ro within those 30 days; if your objection cannot be accommodated, you can close your account without penalty.

    ProviderRolePurposeLocationTransferDocuments
    Supabase
    Supabase, Inc. (Delaware, USA)
    Database & storage
    The authoritative database, authentication and object storage supporting the platform.
    • Identity (email, name, picture)
    • Profile
    • Address
    • Creator KYC
    • Bank details
    • Library and playback
    • Wallet and financial data
    • Listening telemetry (only with analytics consent)
    • Reports
    • Consent log
    • DSAR records
    EU — Frankfurt, Germany (data at rest); remote support access from the USStandard Contractual Clauses (SCC)
    Privacy PolicyDPA

    Data is hosted in the EU region; Supabase Inc. staff in the US may access it for support and operations under the Standard Contractual Clauses in the Supabase DPA. The service role key never leaves the server runtime; the client uses the anon key with RLS.

    Supabase Auth (account verification)
    Supabase, Inc. (Delaware, USA)
    Transactional email
    Generates and validates account messages: signup confirmation, password reset and email changes.
    • Email address
    • Confirmation / reset codes
    EU — Frankfurt, Germany; remote support access from the USStandard Contractual Clauses (SCC)
    Privacy PolicyDPA

    Supabase manages authentication and code validity. Brevo delivers messages via SMTP.

    Brevo (account emails and notifications)
    Sendinblue SAS (France), trading as Brevo
    Transactional email
    Delivers authentication codes and service messages: purchases, subscriptions, withdrawals, moderation decisions and account notifications. Does not send marketing messages.
    • Email address
    • Display name
    • Message content (verification codes, amounts, titles and transaction data)
    • Delivery metadata
    EU — France, Germany and Belgium (hosting)EU/EEA
    Privacy PolicyDPA

    The provider delivers messages; accounts, passwords and code validation are managed by Supabase.

    Google Sign-In
    Google Ireland Limited (Ireland) / Google LLC (US)
    Sign in
    Optional “Continue with Google” sign-in. Google authenticates you and returns your name, email and profile picture; used only if you choose this option.
    • Email address
    • Name
    • Profile picture URL
    EU / USEU–US Data Privacy Framework (DPF)
    Privacy PolicyDPA

    Google acts as an independent controller for authentication; listed for transparency.

    Vercel
    Vercel Inc. (Delaware, USA)
    Hosting & infrastructure
    Edge hosting, serverless functions and deployment platform; Vercel Web Analytics (cookieless page-view statistics, loaded only after analytics consent).
    • Request metadata (IP, user agent, route) in short-lived logs
    • Aggregated analytics events (only if Analytics consent granted)
    EU — Frankfurt by default; global edge for static assets.EU–US Data Privacy Framework (DPF)
    Privacy PolicyDPA
    Viva.com
    Viva Payment Services S.A. (Greece)
    Payment processing
    Card payment processing, 3-D Secure authentication, refunds and chargeback handling for token top-ups. Viva also acts as an independent controller for card payments (PSD2, AML).
    • Payer name (snapshot)
    • Payer email (snapshot)
    • Card token (Viva-side, never stored)
    • Order amount and currency
    • IP at checkout
    EU — GreeceEU/EEA
    Privacy PolicyDPA
    FGO
    Smart ID Dynamics SRL (Romania)
    Invoicing & e-Factura
    Issuing fiscal invoices and forwarding to ANAF e-Factura (RO_CIUS).
    • Recipient name (snapshot)
    • Recipient email (snapshot)
    • Invoice line items
    • Gross/VAT/net amounts
    EU — RomaniaEU/EEA
    Privacy Policy

    Invoices are sent to ANAF e-Factura (GEO 120/2021, B2C from 2025). DPA required before launch.

    ANAF (Romanian National Agency for Fiscal Administration)
    Romanian Tax Authority — statutory recipient, not a processor
    Invoicing & e-Factura
    e-Factura (RO_CIUS) submission and DAC7 marketplace reporting.
    • Creator legal name
    • CUI/CNP
    • Address
    • Annual gross income
    • Number of transactions
    EU — RomaniaEU/EEA
    Privacy Policy

    Statutory recipient under Cod Fiscal and OUG 16/2023 (DAC7).

    Record of processing activities (Art. 30)

    Why we keep each type of personal data, the legal basis, who receives it and for how long. Retention periods are enforced automatically; also see Privacy Policy.

    Account creation and management

    Allow users to create an account, sign in, recover access, manage profile information.

    Legal basis
    Contract — Art. 6(1)(b)
    Data
    identity, contact details, profile, device data, audit log
    Data subjects
    fans, creators
    Recipients
    Supabase, Supabase Auth (account verification), Brevo (account emails and notifications), Google Sign-In, Vercel
    Transfers outside the EEA
    US — Supabase support access (SCC); US — Vercel (EU-US DPF); US — Google authentication, if used (DPF)
    Retention
    For the lifetime of the account. On deletion: disabled immediately, permanently deleted after 30 days (restoration window); the account row is then retained only in pseudonymised form for as long as the financial records referencing it are retained.

    Creator onboarding (KYC + contract)

    Verify creator identity, capture tax profile and signed platform contract before granting payout access.

    Legal basis
    Legal obligation — Art. 6(1)(c)Recipient identification is required for withholding and reporting tax on creator payouts (Tax Code Art. 72, 223-224; D207) and DAC7 seller verification (Tax Procedure Code, Annex 3).
    Data
    identity, identity document, tax ID, address
    Data subjects
    creators
    Recipients
    Supabase, ANAF (Romanian National Agency for Fiscal Administration)
    Transfers outside the EEA
    US — Supabase support access (SCC)
    Retention
    Identity / company document scans: deleted on account erasure. Identification details, tax residence certificate, signed contract and commission amendments: 10 years (Law 82/1991, Art. 25) — supporting the withholding applied and filed declarations.

    Creator payouts and tax withholding

    Compute, withhold, declare and disburse creator earnings; produce settlement statements; file e-Factura.

    Legal basis
    Legal obligation — Art. 6(1)(c)
    Data
    identity, tax ID, bank details, financial transactions, address
    Data subjects
    creators
    Recipients
    Supabase, Brevo (account emails and notifications), FGO, ANAF (Romanian National Agency for Fiscal Administration)
    Transfers outside the EEA
    US — Supabase support access (SCC)
    Retention
    10 years from the end of the financial year (Law 82/1991, Art. 25).

    Token top-ups and content purchases

    Process card payments via Viva, mint tokens to the wallet, record purchases, issue invoices.

    Legal basis
    Contract — Art. 6(1)(b)
    Data
    identity, contact details, financial transactions, device data
    Data subjects
    fans, creators
    Recipients
    Supabase, Viva.com, Brevo (account emails and notifications), FGO, ANAF (Romanian National Agency for Fiscal Administration)
    Transfers outside the EEA
    US — Supabase support access (SCC)
    Retention
    Paid orders, invoices and wallet ledger: 10 years (Law 82/1991, Art. 25), pseudonymised after account erasure. Orders that did not bring in money lose their name / email snapshot on erasure.

    Library and playback experience

    Save tracks to playlists, restore last playback position, manage subscriptions to creators.

    Legal basis
    Contract — Art. 6(1)(b)
    Data
    in-app behavior, content
    Data subjects
    fans
    Recipients
    Supabase, Vercel
    Transfers outside the EEA
    US — Supabase support access (SCC)
    Retention
    Until account erasure (deleted on finalisation, 30 days after the request).

    Listening telemetry and feed personalisation

    Recording plays, opens and clicks to rank trending content and personalise the home page (taste profile).

    Legal basis
    Consent — Art. 6(1)(a)
    Data
    in-app behavior, device data
    Data subjects
    fans, creators, visitors
    Recipients
    Supabase
    Transfers outside the EEA
    US — Supabase support access (SCC)
    Retention
    Raw events: 6 months, deleted weekly (purge_interaction_event_partitions). Taste profile: recalculated nightly from the last 90 days. Both are deleted on account erasure; collection stops as soon as analytics consent is withdrawn.

    Reports, moderation and abuse handling

    Receive user reports, review content, take moderation actions, log admin actions.

    Legal basis
    Legitimate interests — Art. 6(1)(f)Necessary to operate a safe marketplace and to comply with the DSA (Reg. (EU) 2022/2065) for very-large platforms once thresholds met.
    Data
    identity, content, audit log
    Data subjects
    fans, creators
    Recipients
    Supabase, Brevo (account emails and notifications)
    Transfers outside the EEA
    None
    Retention
    Reports, content snapshots and admin decisions are kept as moderation evidence for the lifetime of the platform (repeat infringement policy, DSA Art. 23); the reporter’s identity is detached when their account is erased.

    Cookie banner and proof-of-consent

    Display a compliant banner, record the user's decision, gate non-essential SDKs.

    Legal basis
    Consent — Art. 6(1)(a)
    Data
    consent records, device data
    Data subjects
    fans, creators, visitors
    Recipients
    Supabase
    Transfers outside the EEA
    None
    Retention
    Choice cookie: 12 months on the device, then the banner asks again. Consent evidence register: 36 months from each decision (purge_compliance_records), whether or not the account still exists.

    Fraud detection and platform security

    Detect abuse, brute-force attacks, scraping; rate-limit; preserve evidence of breaches.

    Legal basis
    Legitimate interests — Art. 6(1)(f)Balancing test favours processing — without it the platform cannot protect honest users or fulfil contractual obligations.
    Data
    device data, audit log
    Data subjects
    fans, creators, visitors
    Recipients
    Supabase, Vercel
    Transfers outside the EEA
    None
    Retention
    Rate-limited requests (rate_limit_hits): stored as irreversible hashes of IP / account / address, never in plain text, and deleted within 24 hours. Webhook replay protection records: kept with the payment records they protect (10 years). Hosting request logs: according to Vercel retention (days).

    Data subject access requests

    Receive, track and fulfil requests under GDPR Articles 15-21 within the statutory 30-day SLA.

    Legal basis
    Legal obligation — Art. 6(1)(c)
    Data
    identity, audit log
    Data subjects
    fans, creators
    Recipients
    Supabase
    Transfers outside the EEA
    None
    Retention
    5 years after the request is closed (purge_compliance_records); stored under the anonymised address after account erasure.

    Personal-data breach handling (Art. 33)

    Detect, contain, investigate and report personal-data breaches to ANSPDCP within 72 hours; notify affected subjects when required.

    Legal basis
    Legal obligation — Art. 6(1)(c)
    Data
    audit log
    Data subjects
    fans, creators
    Recipients
    Supabase
    Transfers outside the EEA
    None
    Retention
    Indefinite — Art. 33(5) requires documentation of every breach; the register contains no person-level data.