·03 — Sub-processors
Sub-
processors.
Last updated · 1 October 2026
Seshman uses a small number of third-party services to run parts of the platform. This page lists each of them, what they do for us, where they're located, and the safeguard we rely on when personal data crosses borders. It's updated whenever the list changes.
About this page
A "sub-processor" is a third party that processes personal data on our behalf as part of delivering the Seshman service. Under UK GDPR (Article 28), where you're a trainer using Seshman to manage your clients' data — making you a data controller and Seshman your processor — you have the right to know who our sub-processors are and to object to material changes.
We notify trainers in-app at least 30 days before we add or replace a sub-processor that materially affects how your data is processed. If you reasonably object to a proposed change, you can terminate your subscription with effect from the date the change takes effect, in line with Schedule 1, clause 6 of the Terms of Service.
A separate change log is maintained at seshman.com/legal/changes.
Current sub-processors
The table below covers everything that processes personal data on our behalf today.
| Vendor | Purpose | Location | Transfer mechanism |
|---|---|---|---|
| Hosting and infrastructure | |||
| Amazon ECS on AWS Fargate | Hosting the Seshman API | UK (eu-west-2, London) | UK-internal — no Chapter V transfer |
| Amazon S3 | Storage of generated documents — payment requests, invoices, receipts, refund notes, statements, signed documents and consultation exports | UK (eu-west-2, London) | UK-internal — no Chapter V transfer |
| AWS KMS | Encryption keys for sensitive consultation answers | UK (eu-west-2, London) | UK-internal — no Chapter V transfer |
| AWS RDS (PostgreSQL) | Primary database — personal data at rest | UK (eu-west-2, London) | UK-internal — no Chapter V transfer |
| AWS Cognito | Authentication and identity | UK (eu-west-2, London) | UK-internal — no Chapter V transfer |
| Sign in with Apple / Google Sign-In | Optional federated sign-in: when you choose it, Apple or Google authenticate you and pass us your name and email address | United States (Apple Inc. / Google LLC) | UK Extension to the EU-U.S. Data Privacy Framework |
| AWS Amplify | Hosting for the seshman.com marketing site | UK (eu-west-2, London) | UK-internal — no Chapter V transfer |
| AWS CloudWatch | Application and access logs (may include IP addresses) | UK (eu-west-2, London) | UK-internal — no Chapter V transfer |
| Email delivery | |||
| AWS SES | Outbound transactional email (payment requests, receipts, reminders, schedule confirmations, cancellations, summaries, welcome, account alerts) | UK (eu-west-2, London) | UK-internal — no Chapter V transfer |
| AWS SNS | SES bounce and complaint event delivery to our processors | UK (eu-west-2, London) | UK-internal — no Chapter V transfer |
| Push notifications | |||
| Apple Push Notification Service (APNs) | Delivery of push notifications to iOS devices | United States (Apple Inc.) | UK Extension to the EU-U.S. Data Privacy Framework |
| Google Firebase Cloud Messaging (FCM) | Delivery of push notifications to Android devices | United States (Google LLC) | UK Extension to the EU-U.S. Data Privacy Framework |
| Expo Push | Intermediary that hands push notifications to APNs and FCM | United States (650 Industries, Inc.) | UK Extension to the EU-U.S. Data Privacy Framework, supplemented by EU Standard Contractual Clauses (Module 2) incorporated by reference in Expo's Terms of Service |
| Payments and subscriptions | |||
| Stripe (Stripe, Inc.; Stripe Payments UK Ltd) | Card payments between trainers and clients via Stripe Connect — the trainer's own Stripe account, Stripe-hosted card entry, refunds. Stripe collects trainers' identity, business and bank details directly, as a controller | United States, with UK and EU entities | UK Extension to the EU-U.S. Data Privacy Framework; EU Standard Contractual Clauses with the UK Addendum in Stripe's Data Processing Agreement |
| Apple In-App Purchase | Trainer subscription billing on iOS; Apple holds the payment details | United States (Apple Inc.) | UK Extension to the EU-U.S. Data Privacy Framework |
| Google Play Billing | Trainer subscription billing on Android; Google holds the payment details | United States (Google LLC) | UK Extension to the EU-U.S. Data Privacy Framework |
| RevenueCat (RevenueCat, Inc.) | Subscription status across Apple and Google — receives a pseudonymous account identifier and purchase / renewal events | United States | EU Standard Contractual Clauses with the UK Addendum in RevenueCat's Data Processing Addendum |
| App distribution and updates | |||
| Apple App Store and TestFlight | iOS app distribution; collects standard installation and crash data on Apple's terms | United States (Apple Inc.) | UK Extension to the EU-U.S. Data Privacy Framework |
| Google Play | Android app distribution; collects standard installation and crash data on Google's terms | United States (Google LLC) | UK Extension to the EU-U.S. Data Privacy Framework |
| Expo Application Services — EAS Update | Delivers updates to the app's code between store releases; sees device type, app version and IP address when the app checks for updates | United States (650 Industries, Inc.) | UK Extension to the EU-U.S. Data Privacy Framework, supplemented by EU Standard Contractual Clauses (Module 2) incorporated by reference in Expo's Terms of Service |
| Analytics | |||
| Plausible Analytics (Plausible Insights OÜ) | Aggregate visitor analytics for the seshman.com marketing site — cookieless, no cross-site tracking, no personal data stored | European Union (Estonia, with hosting in Germany) | EU-internal — no Chapter V transfer |
| Error monitoring — announced 1 October 2026, not yet receiving production data | |||
| Sentry (Functional Software, Inc.) | Receives a report when the app, the website or our servers hit an error, so we can find and fix it: the technical details of the error, device type, operating system and app version, and the account's internal identifier. Never your name, email address or IP address, and never the contents of sessions, notes or forms. Reports are kept for 30 days. Production data starts flowing only after the 30-day notice to trainers has run (in-app and by email); until then Sentry receives data from our test environment only | Data stored in Sentry's EU region (Germany); the vendor is US-based | EU Standard Contractual Clauses with the UK Addendum in Sentry's Data Processing Addendum, for any access from outside the UK/EU |
| Website contact form | |||
| FormSubmit (formsubmit.co) | Relays what you type into the contact form on seshman.com — your name, email address and message — to our inbox. Used for nothing else; we keep the email, not a copy on the vendor's side | Not published by the vendor | Only the details you choose to send us; if you'd rather not use the form, email us directly (see /contact) |
AWS is contracted via Amazon Web Services EMEA SARL where applicable; all storage and processing of customer data takes place in the AWS eu-west-2 region (London). The corporate parent (Amazon.com, Inc.) is U.S.-based and DPF-certified, providing a fallback safeguard for any incidental access by U.S.-based support personnel.
Other tools we use (not sub-processors)
These third-party tools are part of how we operate Seshman but do not process personal data on our behalf. We list them here for transparency.
- Google Search Console — we use this to understand how Seshman appears in Google search results. Search Console shows us aggregate data Google already holds about searches related to our domain. It does not process personal data of visitors to seshman.com and is therefore not a sub-processor under Article 28.
Changes to this list
Material additions or replacements (a new sub-processor in a different jurisdiction, a sub-processor handling a new category of data, a change to the transfer mechanism we rely on) are announced 30 days in advance via an in-app banner to all trainers and, where we have your email address, by email.
Minor changes (typos, clarifications, vendor renames that don't change the processing) are made silently and noted on the change log.
If you'd like to object to a proposed change, reply to the notification email or contact privacy@seshman.com. The objection mechanism is described in clause 6 of the Data Processing Agreement.
Contact
Questions about this page or any sub-processor: privacy@seshman.com.
Seshman is operated by Inca Labs Limited, 167-169 Great Portland Street, Fifth Floor, London, W1W 5PF, United Kingdom.