Subprocessors Policy
Effective Date: November 22, 2025
Last Updated: November 22, 2025
This Subprocessors Policy (“Policy”) describes the third-party service providers (“Subprocessors”) used by GliVal (“GliVal”, “we”, “our”), a Booking Platform operated by X STAR CODE, Edmonton, Alberta, Canada.
Registration Number: TN26511691
Contact: [email protected]
Subprocessors support essential operational functions such as payments, messaging, hosting, and security. They process personal information solely on behalf of GliVal, and only as necessary to operate the Platform.
By using GliVal, Customers and Clients consent to the use of these Subprocessors.
1. What Are Subprocessors?
A Subprocessor is a third-party provider that processes personal information on GliVal’s behalf for:
- payment processing,
- SMS and email delivery,
- hosting and infrastructure,
- security and fraud detection,
- operational logging and system performance.
GliVal does not sell, rent, or transfer personal information to any service provider for advertising purposes.
2. Current List of Authorized Subprocessors
2.1 Stripe
Purpose: Payment processing, payouts, dispute handling.
Data Processed: Payment Intent IDs, charge metadata, payout identifiers, dispute information, transaction amounts.
Location: Global (data may be routed internationally).
Notes: Required for all online payments through Stripe Connect Express.
2.2 Twilio
Purpose: SMS delivery (verification codes, confirmations, reminders).
Data Processed: Phone numbers, message content, delivery logs.
Location: United States / Global.
Notes: Used for essential communication and verification only.
2.3 Brevo
Purpose: Email delivery (transactional notifications).
Data Processed: Email addresses, message content, delivery status logs.
Location: Europe / Global.
Notes: Used only for essential booking- and system-related emails.
2.4 DigitalOcean
Purpose: Primary production hosting provider, application servers, storage, backups.
Data Processed: Platform metadata, operational logs, booking-related API responses, subdomain rendering data.
Location: Canada / United States / Global.
Notes: Main infrastructure provider for live production environments.
2.5 Hostinger
Purpose: CI/CD execution environment and development infrastructure (e.g., build pipelines, test environments).
Data Processed: Operational logs, build artifacts, deployment metadata.
Location: Global.
Notes: Hostinger does not host production systems or process live Client personal data.
3. How Subprocessors Are Selected
GliVal evaluates Subprocessors based on:
- security and compliance standards,
- operational reliability,
- minimal necessary access to data,
- privacy principles consistent with PIPEDA,
- performance and infrastructure capacity.
GliVal ensures Subprocessors maintain commercially reasonable security measures.
4. Data Handling & Limitations
Subprocessors:
- receive only the minimum data required for their function,
- may not use data for advertising or unrelated activities,
- must adhere to applicable privacy laws,
- must maintain appropriate technical and organizational security measures.
GliVal does not share:
- full payment card information (handled exclusively by Stripe),
- identity documents,
- unnecessary medical or sensitive personal data.
5. Customer Responsibilities
Customers must:
- comply with all legal requirements regarding Client data,
- not misuse, resell, or unlawfully store data obtained through GliVal,
- ensure their own data handling practices meet regional privacy requirements.
GliVal is not responsible for Customer misuse of Client data.
6. Updates to Subprocessors
GliVal may add or remove Subprocessors from time to time. Updates will be reflected in this Policy.
Significant changes may be announced within the Platform at GliVal’s discretion.
Continued use of the Platform constitutes acceptance of updated Subprocessors.
7. Contact Information
For questions regarding Subprocessors or data handling:
GliVal (operated by X STAR CODE)
Edmonton, Alberta, Canada
Registration Number: TN26511691
Email: [email protected]