This page lists the third parties that Front End Engineering Consultancy Limited (Business Registration No. 75797664, Hong Kong), trading as FEEC (“FEEC”), uses to provide the EmitLedger Service, and the FEEC-controlled infrastructure that stores customer data. It forms Annex 3 of the Data Processing Agreement. Capitalised terms have the meaning given in the Master Subscription Agreement and the DPA.
1. Where customer data lives
- Shared Cloud (live service): servers operated by FEEC and rented from netcup GmbH in Germany.
- Encrypted backups: Cloudflare R2 object storage restricted to the European Union jurisdiction, plus a local copy on the hosting server in Germany. Backups are encrypted on the server before they leave it, so the storage provider only ever holds encrypted data.
- Dedicated Hosting: the region stated in the Order Form. Options are the EU (netcup GmbH, Nuremberg, Germany) or Singapore (netcup GmbH, Singapore). Other regions (for example the Middle East) use a hosting provider named in the Order Form and added to this list before any data is stored.
- Self-Hosted Licence: Customer runs the Software in its own infrastructure. The sub-processors below do not receive Customer Data from self-hosted deployments.
2. Sub-processors with access to Customer Data
| Sub-processor | Purpose | Customer Data processed | Location | Status | Transfer safeguards |
|---|---|---|---|---|---|
| netcup GmbH (Karlsruhe, Germany) | Server hosting (virtual and dedicated servers) for the Shared Cloud, staging and FEEC-operated Dedicated Hosting | All Customer Data stored in the Service, including account data, audit logs, uploaded files, photos and location data | Germany (Shared Cloud; EU Dedicated Hosting in Nuremberg). Singapore for Singapore Dedicated Hosting | Active | Processing in the EU under the GDPR; data processing agreement with netcup under Art. 28 GDPR. For Singapore hosting: same agreement, plus EU SCCs between Customer and FEEC (DPA clause 9). Infrastructure provider only; netcup does not access data inside the servers in the ordinary course. |
| Zoho Corporation (ZeptoMail transactional email service) | Sending transactional email: invitations, password resets, notifications and data-due reminders | Recipient name and email address, email content (which may include tenant name, period references and links; emails do not contain emission figures) | United States (Zoho US data centre) | Active | Zoho data processing addendum; EU SCCs where the data centre is outside the EEA. |
| Cloudflare, Inc. (proxy and DNS) | Routing all web and API traffic for emitledger.com (the website, web app, API and sign-in service) through Cloudflare’s network: TLS termination, protection against denial-of-service attacks, and authoritative DNS | All Customer Data in transit between users and the Service. TLS is terminated at Cloudflare’s edge and traffic is re-encrypted with TLS to the hosting server | Global (the Cloudflare data centre nearest the user) | Active | Cloudflare data processing addendum including EU SCCs. |
| Cloudflare, Inc. (R2 object storage) | Off-site encrypted backups of the database and stored files | Encrypted backup archives only. Cloudflare cannot read them (encrypted before upload; FEEC holds the key). Retention: daily backups for 35 days and monthly backups for 12 months; recent backups are protected from deletion for 30 days | European Union (EU jurisdiction bucket) | Cloudflare data processing addendum including EU SCCs; data encrypted before transfer. | |
| Expo (650 Industries, Inc.) | Relaying mobile push notifications to Apple and Google | Device push token, notification content (identifiers only, such as a period reference; never emission figures) | United States | When the mobile app is released | Expo data processing terms; EU SCCs. |
| Apple Inc. (Apple Push Notification service) | Delivering push notifications to iOS devices | Device push token, notification content (identifiers only) | United States / global | When the mobile app is released | Apple developer terms; EU SCCs. |
| Google LLC (Firebase Cloud Messaging) | Delivering push notifications to Android devices | Device push token, notification content (identifiers only) | United States / global | When the mobile app is released | Google data processing terms; EU SCCs. |
3. Service providers without access to readable Customer Data
These providers support the Service but do not process readable Customer Data. They are listed for transparency.
| Provider | Purpose | Data involved | Location | Safeguards and notes |
|---|---|---|---|---|
| Internet Security Research Group (Let’s Encrypt) | TLS certificates for the hosting server | Domain names only; no Customer Data | United States | Public certificate authority. |
| GitHub, Inc. | Source code hosting and continuous integration | Source code and test data only; no Customer Data | United States / global | Customer Data is never placed in repositories or CI. |
4. Other providers used by FEEC as controller
For FEEC’s own business (for example inbound email to support [at] emitledger.com and sales [at] emitledger.com, accounting and banking), FEEC uses providers that act for FEEC, not for customers. They are described in the Privacy Policy. If a customer sends Customer Data by email to support, that email is handled by FEEC’s email provider, Zoho Mail (Zoho Corporation, United States data centre).
5. Changes to this list
5.1 FEEC will update this page and give at least 30 days’ notice before a new sub-processor starts processing Customer Data, as described in clause 4 of the DPA.
5.2 How to get notified: customer administrators receive sub-processor notices by email. Anyone else can ask to be notified by writing to privacy [at] emitledger.com with the subject “Subscribe to sub-processor updates”.
5.3 Objections: a customer may object on reasonable data-protection grounds within the notice period by writing to privacy [at] emitledger.com, as described in clause 4.4 of the DPA.
5.4 Moving a “Planned” or “When the mobile app is released” entry to active use counts as a change that requires notice under 5.1.
6. Change log
| Date | Change |
|---|---|
| 2026-09-18 | First published version (1.0) |