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Subprocessors

We rely on specialist providers for parts of the service. This page shows which types of providers process your data and your buyers' data, for what purpose, where, and under which safeguards.

Last updated: Version: 1.0AKIN INDUSTRIES LLCTürkçe sürüm

In short

  • Subprocessors process data only on our instructions and only as far as the service requires.
  • Each is bound by a written contract that forbids using the data for its own purposes and requires appropriate security.
  • We list providers here by category; the full list with names is available to our customers on request under confidentiality.
  • We notify customers at least 30 days before adding a new subprocessor, and they may object.
  • Marketplaces you connect are not our subprocessors; they are independent platforms we exchange data with on your instructions.

This summary is for convenience only and is not binding. The full text below governs.

Contents
  1. 1. Subprocessor categories
  2. 2. Full list with names
  3. 3. Parties that are not subprocessors
  4. 4. Change notice and objection
  5. 5. International transfer safeguards

1. Subprocessor categories

As of September 19, 2026
CategoryPurposeData typesProcessing locationTransfer safeguard
Hosting and databaseApplication servers, database, encrypted backupsAll data categories processed in the serviceEuropean UnionProcessed within the EU; GDPR data processing agreement
Cloud file storageStoring artwork, mockups, print files and imagesUploaded files; production files containing personalization textUnited StatesEU SCCs (2021/914) with UK/Swiss addenda; KVKK Art. 9 mechanisms
Payment processingSubscription, credit and order payments, invoicesName, email, billing details, amounts; card data held by the payment provider onlyUnited States and other countriesEU SCCs (2021/914) with UK/Swiss addenda; KVKK Art. 9 mechanisms
AI model providers (text and analysis)Ideas, titles, tags, descriptions, image analysis, copyright pre-checks, reply suggestionsProduct and design context; for reply suggestions, the relevant message textUnited StatesEU SCCs with UK/Swiss addenda; KVKK Art. 9; commercial terms committing not to train models on API data
AI image and video generationMockups, product images and short videosDesign images and prompt textUnited StatesEU SCCs (2021/914) with UK/Swiss addenda; KVKK Art. 9 mechanisms
Shipping label and shipment management platformsShipping rates, label purchase and trackingRecipient name, shipping address, parcel detailsUnited StatesEU SCCs (2021/914) with UK/Swiss addenda; KVKK Art. 9 mechanisms
Carriers (USPS, UPS, FedEx)Carriage and delivery of the parcelRecipient name, shipping address, parcel detailsUnited StatesTransfer necessary to perform the shipping contract; SCCs
Contracted producers (independent print businesses)Printing, packing and handing the order to the carrierPrint file, personalization text, recipient name and address (for packing slip and label)United StatesProducer agreement with confidentiality and data protection terms; SCCs
Transactional email infrastructureAccount, order and security noticesEmail address, name, message contentUnited StatesEU SCCs (2021/914) with UK/Swiss addenda; KVKK Art. 9 mechanisms
Marketing email, SMS and WhatsApp infrastructureMarketing Center sends, delivery and engagement measurementRecipient email or phone, name, message content, delivery and engagement eventsUnited StatesEU SCCs (2021/914) with UK/Swiss addenda; KVKK Art. 9 mechanisms
Error tracking and performance monitoringFinding and fixing errors, service reliabilityTechnical data, IP address, user ID; form inputs are maskedUnited StatesEU SCCs (2021/914) with UK/Swiss addenda; KVKK Art. 9 mechanisms

A provider is only involved when you use the related feature. For example, if you do not send SMS or WhatsApp messages, no phone numbers go to the messaging infrastructure.

Contracted producers are independent print businesses operating in the United States. Custombull is not a manufacturer; your order is routed to a suitable producer in the network based on the product and location. Producers see only the data needed to print, pack and ship that order.

2. Full list with names

The full current list of subprocessors, with their names, is provided to Custombull customers on request under a duty of confidentiality at hello@custombull.com; customers are notified at least 30 days before a new subprocessor is added and have the right to object.

This approach meets the notice requirements on "recipients or categories of recipients" in GDPR Articles 13(1)(e) and 14(1)(e) and on "to whom personal data may be transferred" in Article 10 of Türkiye's KVKK. Under the Data Processing Agreement, our customers keep the right to know subprocessors by name and to object.

3. Parties that are not subprocessors

We exchange data with the following parties, but they do not act on our behalf; their own terms and privacy policies apply:

  • Marketplaces and store platforms you connect (Etsy, Shopify, eBay, Amazon and other channels in early access): we read and write listing and order data with the access you grant.
  • "Sign in with Google": only if you use it, we receive your name, email address and profile ID from Google.
  • Card networks and banks: they process your payment under their own rules.
  • Public authorities: only in response to a binding legal request and to the extent the law allows.

4. Change notice and objection

At least 30 days before we add a new subprocessor or materially change the data an existing one processes, we notify our customers by email and, where needed, update the categories on this page. If an urgent security or continuity reason forces a shorter timeline, we notify you promptly with the reason.

If you wish to object on reasonable data protection grounds, email hello@custombull.com within 30 days of the notice. We will look for a solution together; if none is found, you may terminate the affected service and receive a refund of prepaid fees for the unused period. Details are in the Data Processing Agreement.

5. International transfer safeguards

Our application servers are in the European Union; most subprocessors process data in the United States. For transfers from the European Economic Area, the United Kingdom and Switzerland we rely on the European Commission's Standard Contractual Clauses (with the required UK and Swiss addenda). Transfers from Türkiye follow the mechanisms in Article 9 of the KVKK. See the Privacy Policy for details.

Contact

For any question or request about this document, email hello@custombull.com. Postal address: AKIN INDUSTRIES LLC, 11500 Main St. Suite 126, Houston, TX 77025, United States of America.

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The term 'Etsy' is a trademark of Etsy, Inc. This application uses the Etsy API but is not endorsed or certified by Etsy, Inc.

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