Trust and compliance
RatelKey engages the third parties listed below in providing the Service. Those marked as processors act on RatelKey’s documented instructions under agreements meeting the requirements of Article 28 GDPR. Stripe and GitHub act as independent controllers for the data they handle, under their own terms.
This register is maintained under section 06 of the Privacy Policy. Material changes to it are notified at least 30 days in advance.
| Provider | Role | Purpose | Data processed | Location | Transfer mechanism |
|---|---|---|---|---|---|
| Hetzner Online GmbHwww.hetzner.com | Processor | Production infrastructure for the account and sign-in service, the relay, the update service and the website, including their databases. | Account data, passkey and two-factor data, linked sign-in identities, session data, sign-in history, Burrow registration data, feedback, service records, email records and website usage data. No Burrow contents. | Germany · EUGermany (EU). | Not applicable. Data remains in the EU. |
| Cloudflare, Inc.www.cloudflare.com | Processor | DNS for ratelkey.com, and DDoS mitigation and TLS termination for the website, the account and sign-in service, the update service, and the relay control plane. | IP addresses and HTTP request metadata, and request contents in transit at the point of TLS termination. Connections to a Burrow through the relay are excluded: those addresses resolve directly to the relay and are not proxied, so their TLS terminates at the Burrow. | Global edgeGlobal edge network. TLS terminates at the point of presence nearest the client, which may sit outside the EU. | Standard Contractual Clauses and the EU-U.S. Data Privacy Framework. |
| ZeptoMail (Zoho Corporation)www.zoho.com/zeptomail | Processor | Delivery of transactional email, including address confirmation, password reset and security notices. | Recipient email address, message subject and body, and delivery outcome. | EU regionZoho EU data centre. | Not applicable where processing remains in the EU. Standard Contractual Clauses apply to any support access from outside it. |
| Stripe, Inc.stripe.com | Independent controller | Payment processing, subscription billing and invoicing for paid plans. | Email address, Stripe customer identifier and subscription metadata. Card details, billing addresses and invoices are held by Stripe and are not stored on RatelKey systems. | United StatesUnited States. | Standard Contractual Clauses and the EU-U.S. Data Privacy Framework. |
| GitHub, Inc.github.com | Independent controller | Optional sign-in with a GitHub account, where you choose it. | Your GitHub user ID, username and email address, which GitHub returns to RatelKey when you sign in with it. The access token GitHub issues is used once and is not stored. | United StatesUnited States. | The EU-U.S. Data Privacy Framework and Standard Contractual Clauses. |
A provider listed as Processor processes personal data on RatelKey’s behalf and only on its instructions. Stripe is listed as an independent controller because it determines the purposes and means of processing payment data for its own regulatory and fraud-prevention obligations. GitHub is listed as one because signing in with GitHub happens on GitHub, under your own GitHub account and GitHub’s terms.
A Burrow is installed and run by the customer on infrastructure they choose. It is not hosted by RatelKey and appears nowhere in the register above.
Where it runs is your decision. The hosting provider for a Burrow, if any, is engaged by you and is your sub-processor rather than ours.
The relay carries encrypted bytes. Where a Burrow is reached through the relay, TLS is terminated by the Burrow. The address a browser connects to resolves directly to the relay and is not proxied, so no edge provider terminates that connection. The certificate’s private key is generated by the Burrow and never leaves it. RatelKey has no access to a relayed connection’s contents and does not record them.
The following is never transmitted to RatelKey, and therefore reaches no provider in the register.
Secrets. Stored encrypted in the Burrow’s own database, on the customer’s infrastructure.
The key-encryption key. Generated by the Burrow and kept in its data directory, or supplied to it through its environment. Never written to its database and never sent to RatelKey.
Machine private keys. Generated on the enrolled machine and never transmitted. Only the public key reaches the Burrow.
A Burrow’s audit trail. Written to the Burrow’s own database and not shipped anywhere.
Questions about this register, or about how RatelKey processes personal data?
