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Subprocessors and International Data Transfers
We use the service providers below (subprocessors) to run Focus and this website. The table shows what each one does for us, which categories of personal data it can receive, where the data is processed and on what basis it is transferred abroad.
Article 9 of the Turkish Personal Data Protection Law (KVKK, Law No. 6698) allows personal data to be transferred abroad under the standard contract published by the Personal Data Protection Board. We are putting this contract in place with each provider below; a signed standard contract is notified to the Personal Data Protection Authority within five business days. The transfer basis column shows, for each provider, whether its contract is still in preparation, signed or notified.
Providers marked as planned are not in use yet. They are listed in advance so that the list is complete before they receive any personal data.
| Provider | Service | Personal data | Region | Transfer basis | Status |
|---|---|---|---|---|---|
| Railway Corporation | Application hosting and PostgreSQL database |
| To be confirmed | Standard contract: in preparation | In use |
| Cloudflare, Inc. | Object storage (exports, downloads, encrypted screenshots, encrypted backups), website and help center hosting |
| To be confirmed | Standard contract: in preparation | In use |
| Google LLC | Website analytics (Google Analytics), only if you accept analytics cookies |
| To be confirmed | Standard contract: in preparation | In use |
| Google LLC | Ad conversion measurement (Google Ads): the ad click ID and the sign-up and first-data events, only if you accept marketing cookies |
| United States | Standard contract: in preparation | Planned, not yet in use |
| LinkedIn Ireland Unlimited Company | Ad measurement and conversion tracking (LinkedIn Insight Tag), only if you accept marketing cookies |
| European Union (Ireland) | Standard contract: in preparation | In use |
| Sendinblue SAS (Brevo) | Transactional e-mail |
| European Union (France) | Standard contract: in preparation | In use |
| Sendinblue SAS (Brevo) | E-mail delivery of the website's call-back requests to our team |
| European Union (France) | Standard contract: in preparation | In use |
| Stripe Payments Europe, Limited | Card payments and subscription billing for customers outside Türkiye |
| European Union (Ireland) | Standard contract: in preparation | Planned, not yet in use |
| PayTR Ödeme ve Elektronik Para Kuruluşu A.Ş. | Card payments and subscription billing for customers in Türkiye |
| Türkiye | No transfer abroad | Planned, not yet in use |
| OpenRouter, Inc. | AI summaries and anomaly explanations: forwards the requests to the AI model provider (Anthropic); off by default, enabled per organization |
| United States | Standard contract: in preparation | Planned, not yet in use |
| Anthropic PBC | AI summaries and anomaly explanations (Claude API); off by default, enabled per organization |
| United States (global inference) | Standard contract: in preparation | Planned, not yet in use |
We update this page when a provider is added, changes or is no longer used. For questions, contact info@verfay.com.