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-ProcessorPurposeData categoriesLocation
Shopify Inc.E-commerce platform; order and return data sourceOrder and customer dataCanada / USA
DigitalOcean LLCCloud infrastructure, database, and object storage (labels/photos)All application dataEU (Amsterdam, Netherlands)
Resend, Inc.Transactional email (return notifications, verification codes)Email, name, return statusUSA
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 sharedMerchant return-address search text (no end-customer data)EU (Germany)

Billing & payments

Sub-ProcessorPurposeData categoriesLocation
Revolut LtdMerchant subscription billing (off-platform tenants)Merchant billing identifiersUnited Kingdom
Stripe, Inc.Customer top-up payments on uneven exchanges (opt-in, merchant's own account)Payment data, emailUSA / EU

AI-assisted features

Sub-ProcessorPurposeData categoriesLocation
Anthropic, PBCAI-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 otherwiseUSA

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-ProcessorPurposeData categoriesLocation
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 textUSA

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-ProcessorPurposeData categoriesLocation
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 currencyUSA
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 currencyUSA / EU (Ireland)
Help Scout PBCHelpdesk conversation sync (internal status notes, conversation sidebar)Customer email (conversation matching), conversation subject and snippet, order and return number, return status, refund amount and currencyUSA
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 currencyUSA

Analytics & monitoring

Sub-ProcessorPurposeData categoriesLocation
PostHog, Inc.Cookieless product-usage analytics (where enabled)Pseudonymous id, event metadataUSA / EU
Plausible Analytics OÜCookieless web analytics (aggregate, no PII)Aggregate traffic dataEU (Estonia)
Google Ireland LtdGoogle Analytics 4 / Ads; loads only after Analytics/Marketing consentPseudonymous usage/event data, approximate locationEU / USA (consent-gated)
LinkedIn Ireland UCLinkedIn Insight tag; loads only after Marketing consent (marketing site only)Pseudonymous conversion dataEU / USA (consent-gated)
Functional Software, Inc. (Sentry)Error monitoringPII-scrubbed stack tracesUSA

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.

Questions about our Sub-Processors, or to request our Data Processing Agreement, contact [email protected]. See also our Data Processing Agreement and Privacy Policy.