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SOFTWARE & PRODUCT STUDIO20YEARS2006 – 2026
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Sub-processor List

Third-party processors we rely on

The list of suppliers that process personal data while we deliver our services: type of service, location, transfer mechanism and change notification.

Version
Draft v0.1
Updated
13 September 2026
Applicable region
European UnionGlobalTürkiye
Legal basis
GDPR Art. 28(2) · KVKK Art. 8-9
Who it is for
Corporate customers that have signed a DPA, and data protection officers.
Pending legal review. This text is a working draft; fields in square brackets will be filled with project and company details and reviewed by legal counsel before publication. The binding version is the signed agreement.
CM Apps · Sub-processor ListDraft v0.1 · 13 September 2026

1. Purpose

This list transparently discloses the sub-processors used by CM Apps in accordance with Section 5 of the Data Processing Agreement. The list may vary by product and project; for customer-specific deployments, the applicable list is specified in the annex to the principal agreement.

2. Infrastructure and hosting

[Cloud provider A]: servers and storage. Location: [Germany / Frankfurt]. Mechanism: within the EEA / SCC. [Cloud provider B]: Türkiye region. Location: [Istanbul]. Mechanism: within Türkiye. [CDN / DNS provider]: traffic management. Location: [Global]. Mechanism: SCC.

3. Communication and support

[Email delivery service]: transactional emails. Location: [EU/US]. Mechanism: SCC / DPF. [Support and ticketing system]: customer support records. Location: [EU]. Mechanism: within the EEA. [Messaging provider]: notifications and SMS. Location: [Türkiye]. Mechanism: within Türkiye.

4. Payments and finance

[Payment institution]: subscription collection. Location: [Türkiye / EU]. Mechanism: within the relevant country. [Accounting / e-invoice integrator]: invoices and account records. Location: [Türkiye].

5. Analytics and monitoring

[Error tracking tool]: application error logs. Location: [EU]. Mechanism: within the EEA. [Product analytics]: anonymous/pseudonymous usage data. Location: [EU/US]. Mechanism: SCC.

6. Change notification

The addition or replacement of a sub-processor is announced at least [30] days in advance on this page and by email to customers that have signed a DPA. To subscribe to the notification list: [EMAIL]. Last updated: [13 September 2026].

This document is part of the CM Apps Agreements & Policies center. In case of conflict with other documents, the order of precedence is set out in the relevant agreement.

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