Subprocessors
SofiaPulse Robots Inc. ·
1. What this page is
SofiaPulse engages four service providers. Some are used for more than one function and appear more than once below. Only two are involved in delivering advertising to the public, and neither retains a record of an individual ad request.
A subprocessor is a third party that processes personal information on SofiaPulse’s behalf, on SofiaPulse’s documented instructions, in order to deliver its services. This page lists all of them.
SofiaPulse publishes this list in full rather than describing categories of recipients, so that the statements made in its Privacy Policy and Legitimate Interest Claim can be verified against named providers. An advertiser, agency, or publisher whose agreement with SofiaPulse requires advance notice of changes to this list may write to [email protected] to be added to the notification list.
2. Ad serving
These providers are involved in delivering the Ads described in section 3 of the SofiaPulse Privacy Policy.
| Provider | Purpose | Data |
|---|---|---|
| Cloudflare, Inc. | Edge compute, ad delivery, creative and asset storage, and transcoding for the domains listed in the device storage disclosure. | IP address and request metadata, processed transiently to route and deliver the response. No identifier is set or stored. |
| Google LLC — Google Cloud | Tracking endpoint service for the domains listed in the device storage disclosure, performing IP resolution and derivation of a coarse geographic area, as described in the SofiaPulse Privacy Policy. | IP address, processed in memory and discarded. Not retained by Google on SofiaPulse’s behalf, and not written to any SofiaPulse dataset. |
No other provider is involved in serving an Ad. No demand-side platform, exchange, data provider, identity resolution vendor, or measurement vendor receives personal information from SofiaPulse for that party’s own purposes. Where an advertiser instructs SofiaPulse to include a third-party measurement or verification tag in a creative, that tag is the advertiser’s and operates under the advertiser’s own disclosures, not those of SofiaPulse.
3. Platform and client applications
These providers host the SofiaPulse platform and the front-facing applications used by clients — advertisers, agencies, and publishers — to configure campaigns, review creative, and access reporting. This is separate from ad serving. The personal information concerned is that of client personnel who hold accounts, not of individuals who view an Ad; campaign reporting accessed through these applications is aggregate and does not identify an individual.
| Provider | Purpose | Data |
|---|---|---|
| Vercel Inc. | Hosting and delivery of client-facing web applications. | IP address and standard web server logs; account identifiers and session data for signed-in client users. |
| Google LLC — Firebase Authentication | Identity provider service handling sign-in to the Applications. Supported identity providers are Google and Microsoft; an account holder authenticates with whichever of those holds their account, and that provider acts for the account holder rather than on SofiaPulse’s behalf. | Name, email address, and a stable account identifier, together with sign-in events. No password is received by SofiaPulse. |
| Cloudflare, Inc. | Compute, storage, and delivery for the SofiaPulse platform and its internal services, and front-end delivery of the Applications. | IP address and request metadata; account identifiers and session data for signed-in client users. |
| Google LLC — Google Cloud | Data warehousing and analytics supporting campaign reporting, and other operational services. | Aggregate campaign and delivery data. No individual ad request is stored, and no identifier for any person who viewed an Ad is present. |
4. Website and communications
These providers relate to the SofiaPulse marketing website and to business correspondence. They are not involved in delivering Ads.
| Provider | Purpose | Data |
|---|---|---|
| Webflow, Inc. | Hosting and content management for sofiapulse.com. | IP address and standard web server logs for visitors to the Website. |
| Google LLC — Google Analytics | Measurement of Website usage. Property G-M0B1K1LKM8. | IP address, cookie identifiers, and page interaction data for Website visitors only. |
| Google LLC — Google Workspace | Email and calendar for the sofiapulse.com domain, used for correspondence and for communications that have been requested. | Name, email address, and the content of the correspondence. |
SofiaPulse operates no customer relationship management platform and no third-party marketing automation service. Internal tools are built in-house and run on the infrastructure listed above; they introduce no additional processor.
5. How SofiaPulse engages them
Each provider is engaged under a written agreement that meets the requirements of Article 28 GDPR, including obligations of confidentiality, security, assistance with data subject requests, and deletion or return of data at the end of the engagement.
Providers are given only the information needed to perform their designated function. SofiaPulse does not authorise any of them to use or disclose personal information for their own marketing or for any other purpose of their own.
SofiaPulse’s providers operate internationally, and personal information may be processed outside the individual’s country of residence. The derivation of coarse geographic area from an IP address is performed in the Montréal region, and therefore in Canada.
Where information relating to individuals in the European Economic Area or the United Kingdom is transferred outside those areas, SofiaPulse relies on the European Commission’s adequacy decision for Canada (Decision 2002/2/EC), which covers organisations subject to the Personal Information Protection and Electronic Documents Act in their commercial activities, and on the corresponding United Kingdom adequacy regulations. Where a provider transfers personal information onward to the United States in the course of operating its own systems, the Standard Contractual Clauses in Implementing Decision (EU) 2021/914 apply under that provider’s data processing agreement.
6. Changes to this list
SofiaPulse will update this page whenever a subprocessor is added, removed, or changed, and will change the date at the top. Where an agreement with a client requires advance notice of a new subprocessor, SofiaPulse gives that notice before the new provider begins processing.
Questions about anything on this page: [email protected].