Sub-processors
Last updated: 17 October 2026
The app, the client portal and the database are hosted on InovaSkills' own infrastructure in Portugal, and the off-site backups are kept at another InovaSkills site in Portugal; no provider is involved in hosting or backups. If the hosting moves to a cloud provider in the European Union, that provider will be added to this page with the notice below.
This page lists the providers that process personal data for InovaSkills to provide the iTrackFlow service. It is part of the Data Processing Agreement (Annex 3) and is referred to in the Privacy Policy. Additions and replacements are notified to subscription holders 30 days in advance, under clause 5 of the Agreement.
| Role | Entity | Data location | Transfer safeguard |
|---|---|---|---|
| Email delivery (all app and portal messages) | 123 Reg (123-Reg Limited, United Kingdom) | European Union (data centre of the GoDaddy group in France, used by 123 Reg) | European Commission adequacy decision for the United Kingdom |
| Card payments (checkout, subscription charges, refunds and the billing portal): name, email, billing address and VAT number of the subscription holder, and the card details the Customer types on Stripe's own payment page — never through iTrackFlow | Stripe Payments Europe, Limited (Ireland) | European Union; Stripe, LLC (United States) may access the data to provide the service and prevent fraud | EU-US Data Privacy Framework (Stripe, LLC is certified) and the European Commission's standard contractual clauses |
| Certified invoicing (legal invoices and credit notes): billing details of the subscription holder and the invoice lines | Infolusa, Lda (Facturalusa, Portugal) | Portugal | Not needed (no transfer outside the European Union) |
Not sub-processors: network operators that only carry encrypted traffic, and the public OpenHolidays service, from which the app fetches holiday calendars without sending any personal data.