Public Factual Disclosure
Passings LLC (“Passings”) uses the following third-party service providers (“subprocessors”) to operate the Passings platform and deliver our services. Each subprocessor processes data only for the purposes described and is bound by contractual data protection obligations. Where a vendor determines its own purposes for some processing (an “independent controller” relationship), the relevant row says so; those relationships are governed by the vendor’s own terms rather than service-provider restrictions.
This list is updated when we add or remove a subprocessor. To be notified of future changes, email [email protected] with the subject line “Subprocessor Notifications” (Privacy Policy §4.1).
Current Subprocessors
The following subprocessors are active as of the date of this list:
| Subprocessor | Purpose | Data Processed | Location | Privacy Policy |
|---|---|---|---|---|
| Supabase (Singapore Pte Ltd) | Database, authentication, file storage, edge functions | All user data, vault contents, auth tokens, AI conversation history | US (AWS us-east-1) | supabase.com/privacy |
| Vercel Inc. | Web hosting, CDN, deployment, Speed Insights | Request logs, IP addresses | US (global CDN) | vercel.com/legal/privacy-policy |
| Stripe, Inc. | Payment processing for Consumer purchases and Provider billing (per-lead, Provider Pro, Featured Placement, and Subscription Basic) | Payment card details, billing addresses, email, subscription metadata. Stripe acts as our payment processor for these purposes; for fraud prevention, anti-money-laundering compliance, and improvement of its own services, Stripe acts as an independent controller under its own privacy policy. | US | stripe.com/privacy |
| Anthropic PBC | AI features (all powered by Anthropic Claude models): Pax in-app planning assistant; Eulogy AI Assist (eulogy drafting and refinement); Obituary AI Assist (obituary drafting and refinement); AI Notification Drafts (post-death notification drafting); and the Landing Chatbot (marketing Q&A on the public site) | User messages and prompts you submit to each surface (conversational prompts; eulogy-drafting inputs including names, relationships, and anecdotes; obituary-drafting inputs including the deceased’s name and biographical information; and Landing Chatbot messages), together with the AI-generated outputs returned to you. Anthropic processes these inputs to generate AI responses and retains them for up to 30 days for abuse monitoring and security purposes, after which they are deleted per Anthropic’s stated retention policy; content flagged by Anthropic’s abuse-monitoring systems as a suspected policy violation may be retained longer (up to 2 years) under Anthropic’s usage policies. Anthropic does not use Passings’ API inputs or outputs to train its models under Passings’ commercial API agreement. Anthropic employees do not routinely view conversation content; access is limited to abuse-monitoring systems and specific cases of suspected policy violations. | US | anthropic.com/privacy |
| Voyage AI, Inc. | Embeddings for Pax knowledge retrieval | Knowledge-base text chunks at ingestion (no user data), and — at question time — the text of the message you send Pax, transmitted to compute an embedding used to find relevant help content | US | voyageai.com/privacy-policy |
| Loops, Inc. (Loops.so) | Transactional and marketing email, including dormancy notices, Additional Storage Renewal reminders, Legacy Content delivery notifications, Provider decline notifications to families, and post-death operator-transition notifications | Email addresses, names, plan tier status, notification schedule data | US | loops.so/legal/privacy |
| Mapbox, Inc. | Provider marketplace maps | ZIP codes, location queries, IP addresses | US | mapbox.com/legal/privacy |
| Cloudflare, Inc. | DNS, WAF, DDoS protection, bot detection | IP addresses, request headers, bot scores | US (global) | cloudflare.com/privacypolicy |
| Upstash, Inc. | Rate limiting (Redis) | Request metadata, IP addresses | US | upstash.com/privacy |
| Google LLC (Workspace) | Email hosting for passings.io (support@, privacy@, legal@, trust@, and other aliases) | Support emails, internal communications, Trust & Safety reports, privacy inquiries, legal process | US | policies.google.com/privacy |
| Google LLC (Analytics) | Website analytics | Anonymized usage data, page views, device info | US | policies.google.com/privacy |
| Google LLC (AdSense) | Web advertising on Free tier experience and landing site | Device/browser signals, IP addresses, page context. Under CPRA this constitutes ‘sharing’ for California residents; subject to opt-out via Your Privacy Choices page and GPC signal. | US | policies.google.com/privacy |
| Google LLC (Maps Platform / Places API) | Address autocomplete during address entry (provider onboarding and user/plan addresses) | Partial and complete street addresses entered by the user, location queries, IP addresses. Google provides the Maps Platform under its own controller terms and may use these queries to provide and improve Google products and services; Google is an independent controller for this processing, not a service provider. | US | policies.google.com/privacy |
| Google LLC (Fonts) | Webfont delivery on page load | IP address and browser metadata of the page request; no account data | US | policies.google.com/privacy |
| PostHog, Inc. | Product analytics and feature usage tracking (session replay is disabled; no session recordings are made) | Usage events and feature interactions, with identifiers stripped as described in Privacy Policy §2.2 | US | posthog.com/privacy |
| Functional Software, Inc. (d/b/a Sentry) | Application error monitoring and performance tracing | Stack traces, error messages, application version, and request path (query strings scrubbed). IP address, cookies, authorization headers, user name, user email, form keystrokes, and DOM contents are excluded by configuration (sendDefaultPii: false; beforeSend scrubber; beforeBreadcrumb ui.input drop; Session Replay disabled). User identity is not associated with Sentry events. | US (us.sentry.io region) | sentry.io/privacy/ |
| Resend, Inc. | SMTP relay for Supabase authentication emails (signup confirmation, password reset, email change); also used to deliver internal security-incident alert emails | Email addresses, email content (which for a security alert may include a reporting user’s email address), delivery metadata | US | resend.com/legal/privacy-policy |
| BetterStack (Better Stack s.r.o.) | Uptime monitoring and incident alerting | Health endpoint pings (no user data); incident notification metadata | EU | betterstack.com/privacy |
| Ahrefs Pte. Ltd. | Landing-site SEO analytics (passings.io) | Aggregate page metadata, IP addresses | SG | ahrefs.com/privacy |
| Metricool S.L. | Landing-site marketing analytics (passings.io) | Visitor behavior, IP addresses, referral data | EU | metricool.com/privacy-policy |
See Privacy Policy §12 (AI Features and Companion Chatbot Disclosures) and Appendix A.3 (AI Feature Data) for the user-facing description of these AI surfaces and the retention practices for prompts and outputs. See Terms of Service §3 for the contract-level disclosure of the AI features.
Planned Subprocessors (Coming Soon)
The following subprocessors are planned for future features. They will be added to the Current Subprocessors list before the relevant feature launches, and this list will be updated accordingly:
| Subprocessor | Purpose | Feature | Status |
|---|---|---|---|
| Physical product fulfillment partner(s) | Order fulfillment for QR plaques and keepsakes | Physical commerce | Coming soon |
| WebRTC / video infrastructure provider | In-app video calling between collaborators | Enhanced collaboration | Coming soon |
| Google LLC (AdMob) | Mobile app advertising on Free tier (device advertising identifiers (IDFA/AID), app context; under CPRA this will constitute ‘sharing’ for California residents, subject to opt-out) | Mobile advertising | Coming soon — Mobile launch |
| Apple Inc. (App Store Connect) | iOS app distribution and in-app purchase processing | iOS mobile app | Coming soon — Mobile launch |
| Google LLC (Play Console) | Android app distribution and in-app purchase processing | Android mobile app | Coming soon — Mobile launch |
A Note About Mercury
Passings LLC uses Mercury (Column N.A.) for business banking. Mercury processes business financial data for Passings LLC and Passings Holding LLC. Mercury does not process or have access to user personal data. Mercury is not a subprocessor of user data but is disclosed here for completeness.
Data Transfer Safeguards
User data is stored and processed primarily in the United States (AWS us-east-1). Four subprocessors listed above are domiciled outside the United States. Supabase (Singapore Pte Ltd) hosts Passings data in the US (AWS us-east-1). BetterStack (EU) receives no user data. Ahrefs (Singapore) and Metricool (EU) receive landing-site visitor analytics including IP addresses. Subprocessors with global infrastructure (Cloudflare, Vercel) may cache or route data through international nodes for performance purposes; primary storage remains in the US.
Subprocessor Notification
Passings provides notification of subprocessor changes through updates to this list and through the Privacy Policy’s update notification process.
Contact
Questions about our subprocessors? Contact [email protected]. Privacy-specific questions: [email protected].