Sub-processor list
Version 1 · effective 5 Oct 2026, 23:48
DRAFT — this text has not yet been through legal review.
Text prior to lawyer approval. The information in square brackets will be completed in the legal review.
What this list is for
On agencies' sites and panels, AcenteKit processes personal data on behalf of the agency: the agency is the data controller, the platform is the data processor. The platform has part of this processing carried out by the providers below (sub-processors). This list forms part of the data processing agreement concluded with the agency.
Data that the platform processes on its own behalf (sign-up on the main site, demo requests, subscription payment and measurement) is not covered by this list; it is covered by the main site's privacy notice on personal data.
Sub-processors
Hostinger International Ltd. — server hosting
- Service: the platform's application server, database and uploaded files.
- Data categories: all agency data held on the platform; identity and contact details of agency users, identity and contact details of customers and guests, reservation and payment status records. Card details are not held on the platform.
- Place of processing: Germany (Frankfurt).
- Transfer basis: [transfer basis under KVKK art. 9: to be determined in the legal review].
Hostinger International Ltd. — backup storage
- Service: keeping the nightly backup of the database and files off the server (30 days).
- Data categories: all data in server hosting; the backup is encrypted before being sent to the provider and the encryption key is not held by the provider.
- Place of processing: [backup storage location].
- Transfer basis: [transfer basis under KVKK art. 9: to be determined in the legal review].
Hostinger International Ltd. — email delivery
- Service: sending reservation, payment, document and account notifications by email.
- Data categories: the recipient's name and email address, the content of the message (e.g. reservation summary).
- Place of processing: [email server location].
- Transfer basis: [transfer basis under KVKK art. 9: to be determined in the legal review].
Services chosen by the agency itself
Payment providers and channel managers that the agency connects with its own account operate under the agency's own contract and are not included in this list. [Assessment of this distinction: to be confirmed in the legal review.]
Changes
Before a new sub-processor is added to the list or a sub-processor is replaced, a notification is sent by email to the administrators of active agencies and the new version is published on this page. From the notification, the agency may object with reasons within [objection period]; the consequences of an objection are regulated in the data processing agreement.