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Version 2.5 · effective 2026-10-11

Subprocessors and Providers — FizzUp

1. How to read this registry

FizzUp uses technology providers only to the extent required for an active function. Not every technically approved integration is active for every user, market or module.

The public registry distinguishes active providers from providers only approved for possible activation. A provider marked optional does not receive data merely because it appears in this registry. Before activation, FizzUp confirms the exact legal entity, role, processing region, contract/DPA and transfer basis and, where the provider will be a subprocessor of Entrusted Data, follows the DPA notice procedure.

2. Registry

Provider / groupFunctionTypical dataFunctional statusSafeguards
RailwayAPI, database, website and backend infrastructure hostingaccount data, progress, transcripts, coach memory, beta list, logsactive; EU region (the Netherlands, europe-west4)contract and DPA
Google Cloud / Google Geminithe only active AI provider: live voice conversation (Gemini Live, relayed through the FizzUp server, audio not stored), coach replies in chat, post-session analysis and learning plan, coach memory (including embeddings), pronunciation assessment in exercises, speech recognition and synthesis (Google Cloud Speech-to-Text and Text-to-Speech); also Google sign-in and notifications (Firebase Cloud Messaging)Live audio, chat text and transcripts, learning profile and goals, coach memory, exercise recording, device token, email and Google identifier for sign-inactive, keyDPA and an appropriate transfer mechanism, e.g. adequacy/DPF or SCCs
Hostingertransactional email (sign-in, invitations, notifications, billing) and marketing email (only with the recipient's prior consent) through its mail server (SMTP); FizzUp mailboxes (e.g. hello@, privacy@, support@) and domainemail address, name, message content, delivery data, correspondence sent to and from FizzUpactivecontract/DPA; region and transfer in line with the service configuration
Resendalternative email delivery, if activatedemail address, name, message content, delivery dataoptionalactivation only after confirming contract/DPA, region and transfer mechanism
Stripeweb payments, B2B billing and future web B2C/Family billingcustomer ID, transaction and billing data; card data handled by Stripe under its serviceactive for web billingDPA/payment terms and appropriate transfer mechanism
AppleiOS distribution, Sign in with Apple, push and consumer purchases if activatedaccount/device identifiers, purchases, platform dataactive depending on platformplatform terms and applicable safeguards
Google Play / Google IdentityAndroid distribution, authentication and consumer purchases if activatedaccount/device identifiers, purchases, platform dataactive depending on platformplatform terms and applicable safeguards
Microsoft (Azure Speech)pronunciation assessment in selected exercises, if activated (pronunciation is currently assessed by Google Gemini)recording of the answer in the exercise and its textoptional, inactiveactivation only after confirming contract/DPA, region and transfer mechanism
Meta (WhatsApp Business)WhatsApp messages with FizzUp, if the user uses this channelphone number and message contentoptionalactivation only after confirming contract/DPA and transfer mechanism
Sentryerror/stability diagnostics if activatedtechnical data, event identifiers, redacted error contextoptionalbefore activation: confirm entity, DPA, content minimisation and transfer mechanism
OpenAIpremium voice conversation and additional language models, if activatedLive audio, text, transcript and session identifier needed for the featureoptional, inactive (receives no data)activation only after updating the pre-voice notice and confirming contract/DPA, training restrictions and transfer mechanism
Anthropicadditional language models if activatedtext and context needed for the functionoptional, inactive (receives no data)before activation: contract/DPA, no-training setting, transfer mechanism
OpenRouterrouting to additional models (e.g. Anthropic) if activatedtext and limited function contextoptional, inactive (receives no data)activation only after privacy, security, contract and transfer review
z.aiadditional language model if activatedtext and limited function contextoptional, inactive (receives no data)activation only after privacy, security, contract and transfer review
TwilioSMS and one-time codes, if activatedphone number, code contentoptional, inactiveactivation only after privacy, security, contract and transfer review

3. No-training principle

For Private Coaching Layer data, FizzUp uses service configurations and terms that, under the relevant contract and provider capabilities, exclude use of transferred data for training the provider's general/public models.

4. Provider changes

FizzUp may change a provider or model for quality, availability, security, compliance or cost reasons. A change requiring notice or objection under the DPA is communicated to the B2B customer within the specified notice period.

Material public-registry changes are reflected in the Legal Centre.

5. Transfers

Where processing occurs outside the EEA, we use an appropriate GDPR transfer mechanism, including an adequacy decision, the EU-US Data Privacy Framework for an eligible recipient, or SCCs together with a transfer assessment and supplementary measures where required.

Contact: privacy@fizzup.ai.

The Polish version is the reference version. This English text is a translation; in case of an unintended difference, the Polish version prevails.