Sub-Processors and other recipients

Processors under Art 28 GDPR and independent platforms · Last updated: 12 September 2026

Apart from error and crash diagnostics and anonymous feedback you choose to send (Sentry), the polydesk clicktrader desktop application sends no personal data to third parties on our behalf; in particular no trading or usage data. The recipients below relate to the application's error diagnostics, this website, software distribution and support. We will update this page before adding or replacing a recipient. Recipients involved in Plus license purchases (payment processing) will be added before Plus sales open.

Processors (Art 28 GDPR)

These providers process personal data on our behalf and on our documented instructions under a data processing agreement.

ProviderPurposeLocation / transfer basis
Microsoft Ireland Operations Ltd. (Azure Static Web Apps)Hosting of this website; server logsContract partner in Ireland (EU). Static content is delivered from Microsoft's globally distributed edge network, so requests may be processed outside the EU. Microsoft Corporation (USA) is certified under the EU-US Data Privacy Framework; Microsoft's Data Protection Addendum includes EU standard contractual clauses
Functional Software, Inc. d/b/a SentryError and crash diagnostics for the desktop application (app version, operating system, stack trace) for troubleshooting, and anonymous feedback you choose to send from the app (rating, text, app version, platform); no trading or usage data; deleted after 90 days at the latestStorage in the EU data region (Frankfurt); provider USA, certified under the EU-US Data Privacy Framework

Independent controllers and platforms

These providers are not our processors. You interact with them directly; they process your data as independent controllers under their own privacy policies.

ProviderPurposeLocation / transfer basis
GitHub, Inc.Distribution of application builds (downloads, release checksums, release notes); you interact with GitHub only when you follow a link thereUSA, certified under the EU-US Data Privacy Framework
Discord Inc.Community support channel, planned and not yet open (only if you join our server once it opens)USA; EU standard contractual clauses under Discord's terms
X Corp.Product announcements (only if you interact with our profile)USA; EU standard contractual clauses under X's terms

Questions about this list: office@itereon.eu. See also the privacy policy.