Sub-processors
Third parties engaged by MousePlayer, their purpose and the data they receive. This list forms part of the Data Processing Agreement and of the Technical and Organizational Measures.
1. The short answer
No sub-processor takes part in the recording itself. A daily off-site copy of the complete database and of the recording archive — including session recordings — is however stored with Google (Google Cloud Storage, bucket in Warsaw); since 11 August 2026 it has been held there encrypted: encryption takes place on our own server before the transfer (rclone crypt) and covers file and directory names as well; the keys are held on our own server. Google does not receive them and cannot read the content, but remains a sub-processor — encryption is a technical measure, not a change of role. The previous, unencrypted target folder holding the copies from before 11 August 2026 was deleted on 12 August 2026. The tracking script transmits exclusively to MousePlayer's own infrastructure; during normal recording no third party is contacted. Everything listed below concerns either your own Customer account (payment, support) or MousePlayer's own web pages – not the data of your visitors.
Five things are deliberately not on this list, because they are not sub-processors:
- Consent management platforms. MousePlayer reads the consent signal your CMP places in the browser. Nothing is sent to the CMP provider.
- Optional exports (BigQuery, webhooks). You configure these, they run with your own credentials into your own systems, and you – not MousePlayer – determine the recipient. Without your configuration they are inactive.
- Geolocation. The country of a visitor is derived from a local database file on our own server. No IP address is sent to any geolocation provider.
- Telegram. When a support request arrives, a fixed signal is sent to Telegram, without sender, subject, message text or IP address. As no personal data is transferred, Telegram is not a sub-processor.
- VAT ID check (VIES). Where a Customer gives a VAT ID, we check it with the VAT Information Exchange System (VIES) of the European Commission; the country code and the number are transmitted. The Commission operates this system as an independent body and does not process on our behalf. This concerns your Customer account, not the data of your visitors.
2. Current sub-processors
| Recipient | Purpose | Categories of data | Place of processing | Legal basis for transfer |
|---|---|---|---|---|
| Stripe | Payment processing and invoicing for Customer accounts | E-mail address, account and workspace identifier, language, currency, plan and billing period, and the Customer’s name, billing address and, where applicable, VAT ID, to the extent captured during checkout. Payment data (card, direct debit and other payment methods) is entered on Stripe-hosted pages and never reaches MousePlayer. | EU / USA | The standard Stripe Data Processing Agreement. Contracting party: Stripe Payments Europe, Ltd.; for transfers to the USA, Stripe, Inc. Basis for transfer: Data Privacy Framework, with Module 2 of the Standard Contractual Clauses as a fallback. Accepted on 1 Aug 2026 as part of the terms accepted when the account was opened (statement of MousePlayer). Payment processing is not yet in operation; it will be activated when paid plans launch. |
| Google (reCAPTCHA) | Spam and abuse protection on MousePlayer's own forms (sign-in, registration, forgotten and reset password, support, billing) | IP address and browser signals of the person filling in the form. Not deployed on Customer websites and not part of session recording. | EU / USA | The Google data processing terms. Contracting party: Google Ireland Limited; for transfers to the USA, Google LLC. Basis for transfer: Standard Contractual Clauses / Data Privacy Framework. Accepted on 1 Aug 2026 (statement of MousePlayer). Applies to reCAPTCHA; the off-site backup is covered by the Google Cloud Data Processing Addendum, see its row. |
| Namecheap | Domain registration, authoritative DNS, forwarding of incoming e-mail; since 23 September 2026 also sending of outgoing e-mail (Namecheap Private Email) | Domain data; content and sender of e-mail addressed to MousePlayer. For outgoing e-mail: e-mail address and, where known, name of the recipient and the content of the message – account confirmation and password reset, workspace invitations, notices of a sign-in from a new device with IP address, device and approximate location, warnings before an unused account is deleted, notices of amended contract documents, replies to support requests, the weekly report where enabled, notices about projects (such as anomalies or element markings that no longer match) and system notices to the operator. | USA | The Namecheap Data Processing Addendum; it covers the current Standard Contractual Clauses. Basis for transfer: Standard Contractual Clauses. Accepted on 1 Aug 2026 (statement of MousePlayer). |
| Let's Encrypt (ISRG) | Issuance and renewal of TLS certificates | Domain names only. No personal data of users or website visitors. | USA | Public certification authority; no personal data processed on our behalf |
| Google Ireland Limited (Google Cloud Storage) | Off-site copy of the daily backup | Full copy of the database and, since 6 October 2026, of the recording archive, including session recordings; encrypted before transfer (rclone crypt, keys held by MousePlayer), file and directory names included. | Poland (EU) – bucket in region europe-central2 (Warsaw), since 5 September 2026. Until then the copy was held in a private Google Drive account for which no data region can be booked; the destination had to be stated as USA / worldwide. | Processing on our behalf under the Google Cloud Data Processing Addendum, accepted for the Cloud project. This removes the deviation stated here from 17 August 2026 to 5 September 2026: those terms are not available for a private Google account, and the general terms of use do not establish processing on behalf under Art. 28 GDPR. Retention of the copies: 7 days for daily copies, 364 days for weekly copies. The copy is encrypted before transfer (rclone crypt, file and directory names included); the keys are held by MousePlayer – Google sees blocks without meaning. That takes the content from Google, not the role. Transition complete: copies placed in the private Drive account before 5 September 2026 were deleted on 6 September 2026, after a restore from the new destination had been verified. Since then nothing is held outside the Google Cloud Data Processing Addendum. |
| None – operated on our own hardware in Łódź, Poland, including the machines that run the language model for generated texts; nothing goes to an external AI service. Internet connectivity (Toya sp. z o.o., AS16342) is mere transport and is TLS-encrypted end to end. | Operation of the servers and internet connectivity | All data processed by the service, to the extent it passes through or is stored on that infrastructure. | Poland (EU) | Not applicable: no transfer to a hosting third party. Toya sp. z o.o. is a mere conduit and therefore not a sub-processor. |
3. Changes to this list
MousePlayer engages sub-processors on the basis of the Controller's general written authorization under the DPA. Before a new sub-processor begins processing, or an existing one is replaced, MousePlayer informs Customers 30 days in advance. Within that period the Controller may object on reasonable data protection grounds; if the objection cannot be resolved, the Controller may terminate the affected service.
Notification is given by e-mail to the account holders and as a notice on every page of the logged-in area, which stays until it has been acknowledged. An objection is to be sent in text form to office@mouseplayer.com.
4. Status and version
- Version: 1.5 · Effective: 16 October 2026 · Last reviewed: 16 October 2026 · replaces version 1.4 of 24 September 2026. Changed: the Stripe row names all data transmitted and states that payment processing is not yet in operation; the Namecheap row names every kind of e-mail sent; the reCAPTCHA row names every form; the backup row and the box in section 1 name the recording archive, which has been included in the backup since 6 October 2026; the VAT ID check with VIES is listed as a recipient that is not a sub-processor. Also part of this version: the backup row attributes the keys to MousePlayer rather than to the controller, the statements on acceptance of the terms are identified as statements of MousePlayer, and section 3 states the form of an objection. Version 1.4 replaced version 1.3 of 17 September 2026; changed: the Namecheap row names the sending of outgoing e-mail through Namecheap Private Email, in use since 23 September 2026, and the data it carries.
- In case of divergence between language versions, the English version prevails.