Sub-Processor Register
Last updated: October 1, 2026
This page lists the third-party Sub-Processors that Friros AB (org. nr 559100-9047), operator of Returner, engages to process personal data on behalf of merchants. It is maintained in sync with our Privacy Policy and our internal Record of Processing Activities (GDPR Art. 30). Merchants who require advance notice of changes to this list may subscribe by contacting [email protected].
Some Sub-Processors are engaged only when a related feature is enabled (for example, customer payment processing, AI-assisted features, analytics, a marketing platform, or a helpdesk) or when selected by the merchant (for example, a shipping carrier). Primary application data (database and object storage) is hosted in the EU.
Transfer safeguards: current status. We want this page to state only what is true today. Friros AB has not yet counter-signed and filed a Data Processing Agreement or Standard Contractual Clauses with the Sub-Processors below, and we do not claim EU-U.S. Data Privacy Framework coverage for any of them. Each provider publishes its own DPA and transfer terms, and processing runs under those terms and the provider's own certifications; putting an executed agreement on file with each one is work in progress. Merchants who need the transfer documentation for a specific Sub-Processor before enabling the feature that uses it should contact [email protected], and we will tell them exactly where that Sub-Processor stands.
Where a Sub-Processor is reached through the merchant's OWN account with that provider (the marketing platform and helpdesk integrations below, and a merchant's own payment account), the merchant's existing contract with that provider governs the processing. We pass the data listed in the table; we do not hold a separate agreement with that provider.
Infrastructure & core services
| Sub-Processor | Purpose | Data categories | Location |
|---|---|---|---|
| Shopify Inc. | E-commerce platform; order and return data source | Order and customer data | Canada / USA |
| DigitalOcean LLC | Cloud infrastructure, database, and object storage (labels/photos) | All application data | EU (Amsterdam, Netherlands) |
| Resend, Inc. | Transactional email (return notifications, verification codes) | Email, name, return status | USA |
| komoot GmbH (Photon) | Address autocomplete for the merchant's own return address during onboarding; proxied server-side, so the user's IP address is not shared | Merchant return-address search text (no end-customer data) | EU (Germany) |
Billing & payments
| Sub-Processor | Purpose | Data categories | Location |
|---|---|---|---|
| Revolut Ltd | Merchant subscription billing (off-platform tenants) | Merchant billing identifiers | United Kingdom |
| Stripe, Inc. | Customer top-up payments on uneven exchanges (opt-in, merchant's own account) | Payment data, email | USA / EU |
AI-assisted features
| Sub-Processor | Purpose | Data categories | Location |
|---|---|---|---|
| Anthropic, PBC | AI-assisted merchant support and analytics. Off by default; only the data needed to fulfil a given request is sent, under Anthropic's commercial (no-training) terms. See our AI Policy. | Customer name/email (support queries only); aggregate metrics otherwise | USA |
AI assistants a merchant connects. If you connect Returner to an AI assistant (for example Claude or ChatGPT) through our MCP endpoint or API, the data your assistant reads is transferred to the AI provider you selected, on your instruction. That provider is your processor (or an independent controller, under its own terms), not a sub-processor of Friros AB, and Returner's register of sub-processors is unchanged. Access is limited to the scopes you grant, every call is logged, viewer accounts never receive shopper identity, and you can see and revoke every connection under Settings, AI and agents.
Marketing platform (merchant-connected)
| Sub-Processor | Purpose | Data categories | Location |
|---|---|---|---|
| Klaviyo, Inc. | Return lifecycle events pushed into the merchant's own Klaviyo account, so the merchant can build marketing flows off returns. Off unless the merchant connects it. | Customer email (the Klaviyo profile identifier), order and return number, return status/type, item value and currency, requested-at timestamp. No addresses, no photos, no free text | USA |
Helpdesks (merchant-connected)
When a merchant connects a helpdesk, Returner posts a return's status as an internal note on the linked ticket and reads that ticket's subject and snippet back into the Returner dashboard. Off unless the merchant connects it, and always through the merchant's own helpdesk account.
| Sub-Processor | Purpose | Data categories | Location |
|---|---|---|---|
| Zendesk, Inc. | Helpdesk ticket sync (internal status notes, ticket sidebar) | Customer email (ticket matching), ticket subject and snippet, order and return number, return status, refund amount and currency | USA |
| Intercom, Inc. | Helpdesk conversation sync (internal status notes, conversation sidebar) | Customer email (conversation matching), conversation subject and snippet, order and return number, return status, refund amount and currency | USA / EU (Ireland) |
| Help Scout PBC | Helpdesk conversation sync (internal status notes, conversation sidebar) | Customer email (conversation matching), conversation subject and snippet, order and return number, return status, refund amount and currency | USA |
| Gorgias, Inc. | Helpdesk ticket sync (internal status notes, ticket sidebar) | Customer email (ticket matching), ticket subject and snippet, order and return number, return status, refund amount and currency | USA |
Analytics & monitoring
| Sub-Processor | Purpose | Data categories | Location |
|---|---|---|---|
| PostHog, Inc. | Cookieless product-usage analytics (where enabled) | Pseudonymous id, event metadata | USA / EU |
| Plausible Analytics OÜ | Cookieless web analytics (aggregate, no PII) | Aggregate traffic data | EU (Estonia) |
| Google Ireland Ltd | Google Analytics 4 / Ads; loads only after Analytics/Marketing consent | Pseudonymous usage/event data, approximate location | EU / USA (consent-gated) |
| LinkedIn Ireland UC | LinkedIn Insight tag; loads only after Marketing consent (marketing site only) | Pseudonymous conversion data | EU / USA (consent-gated) |
| Functional Software, Inc. (Sentry) | Error monitoring | PII-scrubbed stack traces | USA |
Shipping carriers (merchant-selected)
When a merchant configures a carrier, the return shipment's name and address, parcel details, and the merchant's return address are shared with that carrier to generate labels and tracking. The shopper's email and phone number are shared only with carriers whose label service uses them for delivery notifications, and the merchant's VAT number only where a carrier requires it. Depending on the merchant's configuration these carriers are: An Post, Australia Post, bpost, Bring, BRT, Canada Post, Chronopost, Cirro, Colissimo, Correos, CTT, DAO, DHL Express, DHL Parcel, DPD, EasyPost, FedEx, GLS, InPost, Instabee, Magyar Posta, Mondial Relay, NZ Post, Packeta, Posti, PostNL, PostNord, Purolator, Royal Mail, Sendcloud, Ship&co, ShipEngine, Swiss Post, UPS and USPS. Where a carrier offers no tracking API, the tracking number alone (no name or address) is sent to 17TRACK (YQTrack Co., Ltd.) to fetch tracking status.