Approved by SMARTEDTECH SL (owner)· Effective November 1, 2026
AfterToMe International Transfer Schedule and Subprocessor List
1. Rule
1. Personal data processed for AfterToMe is stored in the European Economic Area. Where a processor established outside the EEA is used, or a processor's support staff access data from outside the EEA, the transfer is covered by (a) an adequacy decision of the European Commission within its scope, or (b) the Standard Contractual Clauses of Decision (EU) 2021/914 in the applicable module, with completed annexes and a transfer impact assessment kept by the Operator.
2. Where a transfer cannot be covered lawfully, the Operator stops that processing and selects an alternative provider; consent is not used as a routine transfer basis.
2. Subprocessor list
| Function | Provider | Location of processing | Instrument | Data accessed |
|---|---|---|---|---|
| Hosting, storage and backups | Supabase (database, file storage and backups); Vercel (application hosting and delivery) | EEA | Art. 28 agreement; SCC where support access is from outside the EEA | All platform data (encrypted at rest) |
| Authentication and sign-in | Supabase (authentication) | EEA | Art. 28 agreement | Account identifiers, session data |
| Transactional email | Resend | EEA | Art. 28 agreement | Email address, notification content |
| Payment processing | Payment service provider identified at checkout (currently Stripe) | EEA entity; group transfers under its SCCs | Art. 28 agreement + SCC | Payment and billing data; no vault content |
| AI model inference for EchoSoul | Google (Gemini API) for text; HeyGen for EchoSoul video avatars and voices | Provider infrastructure; may be outside the EEA | Art. 28 agreement + SCC where outside the EEA | EchoSoul inputs and outputs only; no training (C07.5) |
| Error monitoring | Sentry | Region of the Sentry project (the EU ingest endpoint is allowed by the site's security policy) | Provider data-processing terms; SCC where outside the EEA | Technical error and performance reports; request bodies, cookies, email addresses, IP addresses and user identifiers are removed before sending; no screen or session recording |
| Rate limiting and abuse prevention | Upstash (Redis); Cloudflare (Turnstile) | Provider infrastructure | Provider data-processing terms; SCC where outside the EEA | Rate-limit counters keyed by IP address and account identifier; bot-check tokens |
| Address lookup | Google (Maps Places API) | Provider infrastructure | Provider data-processing terms; SCC where outside the EEA | Address search text typed by the user |
3. The table above lists each provider integrated in the service as at this version, with the processing location and the instrument, and is updated under §3. The Operator does not publish a provider in this schedule before the corresponding Article 28 agreement is in place.
3. Changes to subprocessors
The Operator notifies changes to the list at least 30 days before the new subprocessor processes personal data, by email to account holders and in the versioned archive of this schedule. You may object by writing to legal@aftertome.com; where the objection cannot be resolved you may terminate the affected plan with a pro-rata refund (C17.2).
4. Obtaining a copy of the safeguards
You may request a copy of the Standard Contractual Clauses in force for any provider, with commercial details redacted, from legal@aftertome.com.
Platform-specific terms
Digital legacy and release instructions
1. The service stores instructions and content that you designate for release to named recipients after a verified trigger event. The service does not create a will, does not transfer title to property, and does not replace probate or inheritance procedures.
2. Release is executed only after human verification of the trigger event against the evidence rule you selected (for example an official death certificate presented by a named recipient plus a waiting period), and may be suspended where a dispute, legal hold or court order is notified.
3. You may revoke or change instructions at any time while you have capacity. Recipients have no right to content before release.
4. The Operator keeps released content available to recipients for the period stated in your plan and then deletes it; rights of erasure and court orders prevail over any technical lock.
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Integrity proof and verification records
1. A proof record attests that a specific digital content (identified by its cryptographic digest) existed at a point in time and was signed by the stated signer. A proof record does not attest to the truth, accuracy, legality or regulatory status of the content, and is not a certification, accreditation or qualified electronic time stamp unless the record states a qualified trust service provider.
2. Verification pages show the digest, the signer, the timestamp source and the retention period; records are retained for the period stated in the plan or required by law.
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