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Legal · draft, October 2026

Sub-processors

Draft, not yet in force. This page is a working draft and is not legal advice. It will be reviewed and replaced before we take on paying customers.

When a studio uses Joul, the studio is the controller of its clients’ data and we process it on the studio’s instructions. Some of that work is done for us by other companies: our sub-processors. This page lists them, honestly split between those in use today and those we plan to use.

Today and planned

In use today: Resend for email, and the Expo push service for app notifications when they are switched on. Everything else below is planned and not yet in use. The database and files are meant to stay in the UK or EU; where a provider is outside the UK and EEA, the transfer is covered by the UK’s International Data Transfer Agreement (IDTA) or the EU’s Standard Contractual Clauses (SCCs) with the UK addendum.

Resend

What for
Sending email: sign-in codes, booking emails, reminders and receipts.
Data
Email addresses, names and the content of each email.
Where
United States (company); sending region to be confirmed.
Transfer safeguard
UK IDTA, or EU SCCs with the UK addendum
Status
In use

Expo push service

What for
Delivering app notifications to phones, through Apple’s and Google’s push services. Only when app notifications are switched on.
Data
The phone’s push token and the notification text (such as a class name and time).
Where
United States.
Transfer safeguard
UK IDTA, or EU SCCs with the UK addendum
Status
In use

Oracle Cloud

What for
The servers that run the web app, studio sites and the app’s API, and the Postgres database that holds studio data.
Data
Everything a studio keeps with us, including encrypted health answers, and short-lived logs.
Where
Region to be confirmed in the UK or EU.
Transfer safeguard
Stored in the UK or EU; UK IDTA, or EU SCCs with the UK addendum for any access from outside them.
Status
Planned

Cloudflare

What for
DNS for our domains, the encrypted tunnel every visit to our servers comes through, and file storage (R2) for logos, photos and signed waiver files.
Data
Requests and visitors’ IP addresses as they pass through; studio images and documents.
Where
Global network; storage location to be set in the EU.
Transfer safeguard
UK IDTA, or EU SCCs with the UK addendum
Status
Planned

Stripe

What for
Card payments and Direct Debit, when online payments arrive.
Data
Names, emails and payment amounts. Card details go straight to Stripe, never to us.
Where
UK and EU, with some processing in the United States.
Transfer safeguard
UK IDTA, or EU SCCs with the UK addendum
Status
Planned

Meta (WhatsApp Cloud API)

What for
WhatsApp booking messages, for clients who choose WhatsApp.
Data
Phone numbers, first names and the message text.
Where
United States and the EU.
Transfer safeguard
UK IDTA, or EU SCCs with the UK addendum
Status
Planned

A text message provider (to be chosen)

What for
Text messages, for clients who choose texts or are not on WhatsApp.
Data
Phone numbers and the message text.
Where
To be confirmed when chosen.
Transfer safeguard
UK IDTA, or EU SCCs with the UK addendum, where outside the UK and EEA.
Status
Planned

Trigger.dev

What for
Running background jobs such as reminders and waitlist offers. Today the app runs these itself.
Data
What each job needs, such as a booking’s ID and time.
Where
To be confirmed (EU preferred).
Transfer safeguard
UK IDTA, or EU SCCs with the UK addendum
Status
Planned

Sentry, PostHog and Better Stack

What for
Monitoring: error reports (Sentry), how the dashboard is used (PostHog) and uptime checks for a live status page (Better Stack). The status page at /status already shows live checks from our own health endpoint and the incidents we post; an external uptime service is still planned.
Data
Error details and usage events, set up to leave out client details; uptime checks see no personal data.
Where
To be confirmed (EU regions preferred).
Transfer safeguard
UK IDTA, or EU SCCs with the UK addendum
Status
Planned

Anthropic (Claude)

What for
Joulie (the studio assistant), only for studios that switch it on: briefings, alerts, the team’s questions and the changes it prepares for approval. Later, the AI WhatsApp receptionist.
Data
What each answer needs: class times and counts, clients’ first names and initials, credits, the studio’s notes and the team’s questions. Never health or waiver answers, emails, phone numbers or birthdays.
Where
United States.
Transfer safeguard
UK IDTA, or EU SCCs with the UK addendum; a data processing addendum with the provider before it is switched on.
Status
Planned

OpenAI

What for
An alternative AI provider for Joulie, only if chosen instead of Anthropic.
Data
The same as Anthropic above, never both at once.
Where
United States.
Transfer safeguard
UK IDTA, or EU SCCs with the UK addendum
Status
Planned

Before we add one

We will email studio owners before we add or replace a sub-processor, with time to object before the change. The notice period will be set out in the data processing agreement.

More detail

How we protect studio data, and what we do for studios as a processor, is in the data processing agreement summary. Questions: [email protected].