Article 28 processor
You're the data controller. We process on your documented instructions and nothing else. Full stop.
Built and hosted in the EU. Your monitoring data lives on Hetzner in Germany and Finland, not in some us-east bucket you didn't choose. The handful of sub-processors outside that (CDN, email, billing) run under SCCs or UK adequacy. No surprise transfers, no clickwrap DPA buried in the ToS. Create an account and you get an Article 28 processor agreement on day one.
You're the data controller. We process on your documented instructions and nothing else. Full stop.
Your monitoring data sits on Hetzner in Germany and Finland. A handful of sub-processors sit outside that — CDN, email, billing, certificates, push and the optional AI analysis — each named below, each under SCCs or UK adequacy.
A short, plain-language Article 28 contract is waiting the moment you create an account. No legal back-and-forth, no waiting on us to countersign.
Our technical and organisational measures live at /tom, versioned. Diff what changed between releases instead of taking our word for it.
Changes run through CI with security checks and dependency scanning on each build.
Access, rectification, erasure and portability are self-serve from your account. The rest is one email to [email protected].
Every bit of customer data, from monitor configs to check results, alerts and status-page subscribers, stays in the EU. Our probes run on Hetzner in Germany and Finland too: they fetch your site, report the result over an authenticated channel and keep nothing else.
Germany
Primary database, API and application, holding all customer data
OP · Hetzner Cloud GmbH
Finland
Secondary region and uptime probes
OP · Hetzner Cloud GmbH
Required by Art. 32 GDPR, published in full as a versioned document. What follows is the summary.
We tell every customer 30 days before adding a new sub-processor. Don't like it? Object, and we'll help you migrate at no charge.
| Entity | Location | Role | DPA / SCCs |
|---|---|---|---|
| Hetzner Online GmbH | Germany + Finland (EU) | Infrastructure hosting, compute and storage, holding all application data | EU — no transfer |
| Cloudflare, Inc. | Global anycast; nearest point of presence, which may be outside the EEA | DNS, DDoS protection, CDN, WAF and TLS termination — processes request and response content in transit | EU SCCs + DPA |
| Mailgun (Sinch) | EU region endpoint | Transactional email for alerts and account email | EU SCCs + DPA |
| Paddle.com Market Ltd | UK / EU | Payments, billing and invoicing (Merchant of Record) | UK adequacy + DPA |
| Let's Encrypt (ISRG) | USA | TLS certificate issuance; domain names also appear in public Certificate Transparency logs | Public certificate authority |
| OpenRouter, Inc. | USA | AI incident analysis, run only when a user asks for one, and the AI summary of the monthly report for teams that switch it on; routes on to a model provider | EU SCCs |
| Google Ireland Ltd / Google LLC | USA | Chrome UX Report API for the performance check; Google Fonts on a status page where its operator selected one | EU SCCs |
| Apple Distribution International Ltd | USA | Push notifications to the iOS app | EU SCCs |
Every account gets an Article 28 Data Processing Agreement at sign-up, in German or English. Email us if your legal team wants to redline it.
… full agreement with Schedule A (TOM) and Schedule B (Sub-Processors).
Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen
You can take a complaint straight to the LDI NRW. We'd rather you came to us first, but the right is yours, not ours.
This page is a summary and does not constitute legal advice · consult your own DPO for controller-side obligations
Hoppla runs on Hetzner in Germany and Finland. Join the early-access list and we’ll invite you as places open.