1. What this list is
Eer Technology SPA acts as the data processorfor the personal data that the Customer (data controller) processes through the FireTun Service. To deliver the Service we rely on a limited set of external providers whose role and scope are described on this page, in compliance with Article 28 of the General Data Protection Regulation (GDPR) and Chile's Law 21,719 on personal data protection.
This page is updated whenever any subprocessor is added, removed or substantially changed. Customers may subscribe to notifications by writing to privacy@firetun.com and will receive reasonable advance notice of any subprocessor change involving access to personal data.
2. Infrastructure subprocessors
Compute, network and storage providers on which the Service components run. These providers do not have logical access to the Customer's encrypted data.
| Provider | Service | Data processed | Location |
|---|---|---|---|
| Vultr Holdings, LLC | Compute and network for gateways and data-plane nodes. | Encrypted in-transit traffic; connection metadata. | USA, EU, Latin America (regions selectable by the Customer for Dedicated Tenants). |
| Contabo GmbH | Compute for the control plane and Service databases. | Data encrypted at rest and in transit. | Germany (EU). |
| Bunny.net (BunnyWay d.o.o.) | Content delivery network (CDN) for static assets of the public website. | Public-site access logs (IP, user-agent, requested URL). | Slovenia (EU) with global edge presence. |
3. Payment subprocessors
Two payment gateways are used for billing and invoicing of subscriptions, depending on the Customer's region.
| Provider | Service | Data processed | Location |
|---|---|---|---|
| Paddle.com Market Ltd / Paddle.com Inc. | International payment processing as Merchant of Record. Collects and remits applicable taxes, handles payment inquiries, and processes refunds where applicable. | Billing data, tax identification, address, tokenized payment method, transaction history. | United Kingdom and United States. |
| MercadoPago | Payment processing in Latin America. | Billing data, tax identification, tokenized payment method, transaction history. | Argentina, Brazil, Chile, Mexico and other LATAM countries where Mercado Pago operates. |
4. Identity and transactional communication subprocessors
Components used for operator authentication and for sending transactional emails related to Service operation.
| Component | Service | Data processed | Location |
|---|---|---|---|
| Keycloak (self-hosted by Eer Technology) | Identity provider for operator authentication when the Customer opts to use the managed IdP. When the Customer integrates its own IdP (Google, Microsoft Entra, Okta, etc.), Keycloak is not involved. | User identifiers, e-mail address, password hash, MFA factors. | Germany (EU). |
| HashiCorp Vault HA (self-hosted by Eer Technology) | Custody of cryptographic keys (per-tenant certificate authorities, per-tenant encryption keys, integration secrets). | Key material; no Customer data in plaintext. | Germany (EU). |
| eermail (self-hosted by Eer Technology) | Internal transactional e-mail service (verifications, security alerts, billing notifications). | E-mail addresses, content of transactional messages, delivery and status records. | Germany (EU). |
5. Isolation and minimization
Eer Technology applies the following principles regarding subprocessors:
- Per-tenant encryption at rest.Customer information stored in the Service databases is encrypted with independent per-tenant keys; a compromise of an infrastructure provider does not allow decryption of another customer's data.
- Encryption in transit. All communication with subprocessors occurs over TLS 1.3 with mutual authentication where technically feasible.
- Data minimization. Each subprocessor receives only the minimum information required to deliver its service.
- Contractual agreements with each subprocessor including obligations of security, confidentiality and compliance with GDPR / Law 21,719 where applicable.
6. Notification of changes
Eer Technology will give the Customer at least thirty (30) days advance noticeof any addition or replacement of a subprocessor with access to the Customer's personal data. The notice will be sent to the registered contact address and published on this page with its update date.
If the Customer reasonably objects to the addition of a subprocessor, the parties will negotiate in good faith reasonable alternatives. If no agreement is reached, the Customer may terminate the contract without penalty for the remainder of the affected billing period.
7. DPA and contact
This page forms an integral part of the Data Processing Agreement (DPA) and of the Terms of Service. To request the full DPA, report a security incident or inquire about data processing, write to privacy@firetun.com.