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. Subprocessor categories
| Category | Purpose | Data types | Processing location | Transfer safeguard |
|---|---|---|---|---|
| Hosting and database | Application servers, database, encrypted backups | All data categories processed in the service | European Union | Processed within the EU; GDPR data processing agreement |
| Cloud file storage | Storing artwork, mockups, print files and images | Uploaded files; production files containing personalization text | United States | EU SCCs (2021/914) with UK/Swiss addenda; KVKK Art. 9 mechanisms |
| Payment processing | Subscription, credit and order payments, invoices | Name, email, billing details, amounts; card data held by the payment provider only | United States and other countries | EU 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 suggestions | Product and design context; for reply suggestions, the relevant message text | United States | EU SCCs with UK/Swiss addenda; KVKK Art. 9; commercial terms committing not to train models on API data |
| AI image and video generation | Mockups, product images and short videos | Design images and prompt text | United States | EU SCCs (2021/914) with UK/Swiss addenda; KVKK Art. 9 mechanisms |
| Shipping label and shipment management platforms | Shipping rates, label purchase and tracking | Recipient name, shipping address, parcel details | United States | EU SCCs (2021/914) with UK/Swiss addenda; KVKK Art. 9 mechanisms |
| Carriers (USPS, UPS, FedEx) | Carriage and delivery of the parcel | Recipient name, shipping address, parcel details | United States | Transfer necessary to perform the shipping contract; SCCs |
| Contracted producers (independent print businesses) | Printing, packing and handing the order to the carrier | Print file, personalization text, recipient name and address (for packing slip and label) | United States | Producer agreement with confidentiality and data protection terms; SCCs |
| Transactional email infrastructure | Account, order and security notices | Email address, name, message content | United States | EU SCCs (2021/914) with UK/Swiss addenda; KVKK Art. 9 mechanisms |
| Marketing email, SMS and WhatsApp infrastructure | Marketing Center sends, delivery and engagement measurement | Recipient email or phone, name, message content, delivery and engagement events | United States | EU SCCs (2021/914) with UK/Swiss addenda; KVKK Art. 9 mechanisms |
| Error tracking and performance monitoring | Finding and fixing errors, service reliability | Technical data, IP address, user ID; form inputs are masked | United States | EU 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.
Other legal documents
- Terms of ServiceThe service agreement between you and Custombull.Version 3.0 · September 19, 2026
- Privacy PolicyWhat data we process, why, and your rights.Version 3.0 · September 19, 2026
- KVKK Information Notice (Turkish)Notice under Turkish Law No. 6698, Article 10. Turkish only.Version 1.0 · September 19, 2026
- Cookie PolicyWhich cookies we use, why, and with what consent.Version 2.0 · September 19, 2026
- Data Processing AgreementGDPR Art. 28 terms for your buyers' data.Version 1.0 · September 19, 2026
- SubprocessorsService providers that process data on our behalf.Version 1.0 · September 19, 2026
- Acceptable Use and Copyright PolicyProhibited content, DMCA notice and counter notice.Version 1.0 · September 19, 2026
- Security and Abuse PolicySecurity standards, prohibited actions, consequences of attacks and vulnerability reporting.Version 1.0 · September 19, 2026
- Refund and Quality Guarantee PolicyNo-questions refund for defects, credits and subscriptions.Version 1.0 · September 19, 2026
- About Integrated PlatformsTrademark notices for Etsy, eBay, Shopify and other platforms.Version 1.0 · September 19, 2026
The term 'Etsy' is a trademark of Etsy, Inc. This application uses the Etsy API but is not endorsed or certified by Etsy, Inc.