6. Sub-processor List

Last updated: 14 September 2026

These are the third parties involved in delivering NASST. We publish the list because Article 28(2) of the UK GDPR requires you to know who processes data on your behalf, and because Amazon's Data Protection Policy requires us to keep track of it.

We give 30 days' notice before adding a sub-processor. See §5.3.4 of the Data Processing Agreement for your right to object.

6.1 Current sub-processors

Amazon (Amazon Services Europe S.à r.l. and affiliates)

What it doesThe Selling Partner API. Everything NASST shows comes from here
Data it receivesRequests to your own Amazon account, authorised by you
LocationEU endpoints for UK and European marketplaces
Transfer basisNot applicable — your own data, at your own provider, on your instruction

Amazon is not a sub-processor in the ordinary sense. It is the source of the data and you already have a direct relationship with it. Listed for completeness.

Brevo (Sendinblue)

What it doesDelivers account emails — verification, password reset, security notices
Data it receivesYour email address and the content of the message
LocationFrance, with data centres in the European Union
Transfer basisNone required. Brevo is an EEA processor, so this is not a restricted transfer
Article 28 termsAppendix 3 of Brevo's Terms of Service, accepted at sign-up

Only transactional email. We do not send marketing. The domain's DKIM records are verified, so account email leaves under nasst.co.uk rather than from a consumer mailbox.

Until 2 September 2026 this role was performed by Google (Gmail SMTP) in the United States, relying on the UK extension to the EU-US Data Privacy Framework. Moving it to an EEA provider removed that transfer entirely.

Microsoft 365, supplied by GoDaddy

What it doesReceives the info@nasst.co.uk mailbox
Data it receivesWhatever you choose to send to that address, including a data subject request and any identity information sent with it
LocationMicrosoft stores content in its UK or EU region under its residency terms; GoDaddy, which resells the service, is a United States company
Transfer basisMailbox content stays within Microsoft's UK or EU region, both adequate for UK transfers. For GoDaddy, the UK International Data Transfer Agreement is deemed executed within its Data Processing Addendum, with the Data Privacy Framework applying first where available

Sending email and receiving email are different providers, and both belong on this list. Brevo sends; this mailbox receives.

UPCitemdb

What it doesLooks up a barcode from a product name when Amazon's catalogue has none
Data it receivesA product name or barcode. Nothing else
LocationUnited States
Transfer basisNo personal data is transferred

Worth being precise: UPCitemdb receives a search string such as a product title. It does not receive your email address, your account identifier, your IP address or any Amazon data about your business. It cannot tell that two lookups came from the same customer.

Open Beauty Facts and Open Food Facts

What it doesThe same job as UPCitemdb, on the "Barcode fallback" switch in Extract & Match: finds a barcode from a product name when a match fails without one
Data it receivesA product name or brand. Nothing else
LocationFrance. Both are run by Open Food Facts, a French non-profit association
Transfer basisNone required. France is in the EEA, so this is not a restricted transfer

These are free, public, crowd-sourced product databases. The lookup is made by our server, not by your browser, so your IP address never reaches them, and the search string carries nothing about you or your Amazon account. A barcode found this way is treated as a hint: the Amazon listing it points at is still scored on its own merits before anything is shown to you.

The switch is on by default and can be turned off for any run. With it off, no product name leaves the app for these services at all.

Keepa GmbH

What it doesPrice, sales-rank and offer-count history; the hourly deal feed; and looking up who a competing seller is
Data it receivesA product identifier (ASIN), a category, deal search filters, a competing seller's Amazon merchant ID, and our API key
LocationKemnath, Germany — inside the EEA
Transfer basisUK adequacy regulations for the EEA. No Standard Contractual Clauses required

Keepa does not receive your email address, your account identifier, or your own Amazon credentials. It cannot tell that two lookups came from the same customer, or which customer — every request goes on one API key that is ours, not yours.

Two things Keepa now receives that it did not before, added 28 August 2026:

*Competing sellers' merchant IDs.* When you look at who else is selling a product, we ask Keepa to resolve those sellers' IDs into shop names. Those IDs identify other Amazon businesses, not you, and Amazon already publishes the names on the listing page. Keepa also returns a trading address, a VAT number and a company registration number, and the code discards all three before anything is stored or sent to a browser.

From 14 September 2026 the names are fetched automatically for the sellers already shown on your screen, rather than only when you ask for one. The reason is a practical one: a listing where the *brand itself* is one of the sellers is a listing worth walking away from, and that is invisible while the page shows merchant IDs.

A name resolved this way is kept for 90 days, and it is only the name — no address, no Buy Box share, no catalogue. Asking for a seller's full record, on the Seller Lookup, still returns the Buy Box share and what they sell, and that fuller answer is kept for 24 hours.

*Deal search filters.* The hourly deal sweep sends the categories and price ranges being watched. Those are search terms, not personal data, and the same query is run once for every customer watching it rather than once per customer.

Keepa confirmed in writing on 11 August 2026 that displaying its data inside a commercial product is permitted under an ordinary paid subscription. We do not resell API access, which is the one thing their terms prohibit.

Stripe

What it doesTakes subscription payments and stores your card
Data it receivesYour email address, billing details and card details
LocationIreland and the UK. The contracting entities are Stripe Payments Europe, Limited and Stripe Payments UK Ltd, with onward processing by Stripe, Inc. in the United States
Transfer basisStripe's Data Processing Agreement (https://stripe.com/legal/dpa), which incorporates Standard Contractual Clauses and the UK Addendum for onward transfers to Stripe entities outside the EEA

Card details never reach our servers. Payment is handled on the provider's own hosted pages, so we hold an identifier for your subscription and nothing that could be used to charge a card.

Hetzner Online GmbH

What it doesRuns the servers
Data it receivesTechnically all of it, as the infrastructure it runs on
LocationHelsinki, Finland
Transfer basisNone required. Section 3 of the Data Processing Agreement concluded on 2 September 2026 commits Hetzner to processing exclusively within the EU or EEA, with any third-country transfer requiring our prior consent

6.2 Content delivery networks

None. As of 2 September 2026 there are no content delivery networks, and no third party is contacted when you load any page of this service.

Until that date your browser fetched styling, JavaScript libraries, spreadsheet export code and typefaces from Tailwind CDN, unpkg, SheetJS CDN and Google Fonts. Those requests carried your IP address to four companies outside the United Kingdom before you had agreed to anything, simply as a consequence of opening the page.

Every one of those files is now served from our own servers in Finland. This is verifiable rather than asserted: load any page with your browser's network tools open, and every request goes to nasst.co.uk or app.nasst.co.uk.

This removed the last international transfer of personal data in this service.

6.3 What we deliberately do not use

Named because their absence is a meaningful commitment:

Not usedWhat it would have meant
Analytics providersYour behaviour in the app sent to a third party
Advertising networksTracking you across other websites
Error-reporting servicesCrash data, sometimes including request contents, sent off-site
Customer-support widgetsA third-party script with access to the page you are on

6.4 SerpApi — optional, and only if you choose it

This changed on 28 August 2026. SerpApi previously appeared above as a provider we had removed. It is now available again, on a different footing: it runs on your own SerpApi account and your own API key, which you add yourself in Account and can remove at any time.

What it doesLive retailer price comparison in Best Offers
Data it receivesA product name or search term, and your own API key. Nothing about you
LocationUnited States
Whose accountYours. You hold the contract with SerpApi and the searches are billed to you
If you do not add a keySerpApi is never called and receives nothing. Best Offers still works, using free search links

Your key is encrypted before it is stored and is never sent back to any page — only its last four characters are ever shown, so you can tell which key is saved. Deleting your account deletes the key with everything else.

> For review before launch. Because the account and the contract are yours, > SerpApi is arguably not our sub-processor at all — we relay your search term > to a provider you chose, using your credentials. It is listed here anyway, > because a data flow the customer cannot see is worse than one described under > the wrong heading. Whether it belongs in 6.1 as a sub-processor, or in a > separate section as a customer-directed integration, is a question for the > solicitor rather than one to settle in code. SerpApi confirmed the > arrangement itself is permitted — see SUPPLIER_ANSWERS.md section 3.


6.5 Extract & Match, and the page saver extension

Added 2026-08-28. This is the one feature where data reaches us from somewhere other than Amazon, so it is described separately rather than folded into the table above.

What happens

You browse a supplier's or retailer's website yourself. When you find a page worth checking, you press the extension's button (or Alt+Shift+S). That sends that one page's HTML to NASST, where the product names, prices and barcodes are pulled out and looked up on Amazon using your own Amazon connection.

What we receiveThe HTML of a page you explicitly chose to send
WhenOnly when you press the button. Never automatically, never in the background
What the extension can readThe page you are on at the moment you press it. It has no site list, no scheduled activity and no access to your browsing history
Where it goesThis app only. The extension will talk to no other address
How long we keep it24 hours, then the stored page is deleted automatically
Who can see itYou. Saved pages are recorded against your account and no other customer can list, read or delete them

What we do NOT do

We do not crawl retailer websites. We do not fetch pages you have not sent. We do not follow links out of a page you send. Nothing about your browsing outside the moment you press that button reaches us.

The retailer's own terms are yours to honour

A retailer's website has its own terms, and some of them restrict automated collection. You are the person visiting that site, using your own browser, on a page you chose. That relationship is between you and them, and it is your responsibility to stay inside their terms — sending a page to NASST does not change what you were allowed to do with it. We provide the tool; we cannot and do not agree those terms on your behalf.

The extension is not on the Chrome Web Store

It is downloaded from inside NASST and installed unpacked, which means you can read every line of it before you install it. It is six files: a manifest, one background script and three icons. Deleting the folder uninstalls it.

Matching is a best guess, not a fact

Products are matched to Amazon listings by barcode where the page gives one, and otherwise by comparing brand, name and size. The comparison is deliberately cautious — a candidate is rejected when its size or variant contradicts the source — but a match is still an inference. Check anything before you buy it. See document 2 §2.7 for what that means for liability.


6.6 Changes

We will email account holders at least 30 days before adding a sub-processor.