A sub-processor is a company we engage to process personal data on your behalf as part of running Kirora: for example, to send your email or deliver your push notifications. This page lists them, what each one does, what data it handles, where, and the safeguard we rely on when data leaves the European Economic Area, the UK or Nigeria. It forms Annex 3 of our Data Processing Agreement.
Every sub-processor is bound by a written agreement with data protection terms at least as protective as our DPA, as far as they apply to the service it provides, and we remain responsible to you for its work.
How we tell you about changes
We give at least 30 days’ notice before a new sub-processor starts processing your data. We update this page and email the owner of every workspace, plus anyone who has subscribed to updates. If you have reasonable data protection grounds to object, email us within the notice period and we will work with you on it, as the DPA describes.
To subscribe to updates, or to ask anything about this list, email privacy@kirora.io .
Our sub-processors
| Sub-processor | Purpose | Data processed | Location | Transfer safeguard |
|---|---|---|---|---|
| Amazon Web Services, Inc. | Sending email (Amazon SES), including our own account emails; storing template images and contact import and export files (Amazon S3); delivering template images (Amazon CloudFront); receiving bounce and complaint notices (Amazon SNS and SQS) | Recipient addresses, message content, delivery, bounce and complaint data; contact data in import and export files; images you upload | Frankfurt, Germany (EU; AWS region eu-central-1). CloudFront serves images from locations worldwide. | Data stays in the EU. CloudFront edge copies are of images you publish in emails. SCCs and UK Addendum in AWS’s data processing addendum. |
| Brimble | Running the Kirora application (API and background workers), database and cache | All customer data held in the service: contacts, attributes, events, messages, consent history, push device tokens, form submissions, workspace users | Germany (EU) | Data stays in the EU. |
| OpenAI, L.L.C. | Kiro AI, the drafting and analysis assistant, when a workspace has it switched on | Your prompts and the workspace content Kiro AI reads to answer them, such as campaign, template, segment and journey details and performance figures. Kiro AI cannot read contact records. Requests are sent with storage switched off. | United States | SCCs (Module 3) and UK Addendum; EU-US Data Privacy Framework where certified |
| Apple Inc. | Delivering push notifications to iOS apps (APNs) and Safari web push | Device or browser push token and notification content. Safari web push content is encrypted end to end. | United States | SCCs and UK Addendum; EU-US Data Privacy Framework where certified |
| Google LLC | Delivering push notifications to Android apps (Firebase Cloud Messaging) and Chrome web push | Device or browser push token and notification content. Web push content is encrypted end to end. | United States | SCCs and UK Addendum; EU-US Data Privacy Framework where certified |
| Mozilla Corporation | Delivering web push notifications to Firefox | Browser push token and encrypted notification content | United States | SCCs and UK Addendum |
| Cloudflare, Inc. | Bot protection (Cloudflare Turnstile) on sign-up forms hosted or framed by Kirora, when the form uses Kirora’s own Turnstile widget (the default) | The visitor’s IP address and browser signals, collected by Cloudflare when the form loads and checked when it is submitted | United States, and Cloudflare’s network worldwide | SCCs and UK Addendum; EU-US Data Privacy Framework where certified |
| Microsoft Corporation | Delivering web push notifications to Edge on Windows | Browser push token and encrypted notification content | United States | SCCs and UK Addendum; EU-US Data Privacy Framework where certified |
Push notifications to apps are sent with the APNs key or Firebase service account you upload, and web push goes through the push service the subscriber’s browser uses. We list these push services above while we confirm whether they act as our sub-processors or under your own agreements with them.
Integrations you enable
You can connect other services to your workspace. These are not Kirora sub-processors: you choose to use them, you hold the account with them, and they act under your own agreement with them. Data flows between them and Kirora only because you connected them, and you can disconnect them at any time.
| Service | What it does in Kirora | Data that flows |
|---|---|---|
| Paystack | Sends us successful payments from your Paystack account, recorded as order events | Payer’s email address, order reference, amount and currency |
| Stripe | Sends us successful charges from your Stripe account, recorded as order events | Payer’s email address, payment reference, amount and currency |
| Zapier | Calls our API with a key you create, to add or update contacts, track events and find contacts | Whatever your Zaps send or read: contact identifiers, attributes and events |
| HTTP API and webhooks | Your own systems, or any tool you choose, call our API or receive our webhook events at a URL you set | Contact data and message events you choose to send or subscribe to |
| Cloudflare Turnstile, with your own keys | If you choose to use your own Cloudflare account’s widget and keys on your sign-up forms instead of Kirora’s | The visitor’s IP address and browser signals, collected by Cloudflare when the form loads and checked when it is submitted |
Questions
If you have questions about any sub-processor or integration, or need a copy of the transfer terms we rely on, email privacy@kirora.io .