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Third-Party Subprocessors

Last Updated: May 21, 2026

To provide Wallies services, Wallies LLC uses trusted third-party vendors (subprocessors) who may process your data on our behalf. This page lists all subprocessors in compliance with GDPR Article 28 requirements.

Effective Date: This version is effective as of the "Last Updated" date above. The subprocessors listed below reflect our current data-handling practices as of that date. The 30-day notice period in "Changes to Subprocessors" applies to future material changes made after this effective date — not to subprocessors already in use and disclosed on this page.

Active Subprocessors

Base44 Platform

Infrastructure

Purpose: Backend infrastructure, database hosting, authentication

Data Processed: User accounts, conversations, memories, subscription data

Location: United States

Stripe

Payments & Payouts

Purpose: Payment processing for subscriptions, ILY purchases, drops, handles, tickets, and creator payouts via Stripe Connect

Data Processed: Payment information, transaction history, KYC and payout details for creators

Location: United States (global operations)

Bunny Stream (Bunny.net)

Video

Purpose: Primary video upload, encoding, HLS delivery, and thumbnail generation for Rooms and hosted posts

Data Processed: Uploaded video files, generated thumbnails, playback metadata, viewer IP (delivery only)

Location: Slovenia (EU HQ) / Global CDN

Mux

Video

Purpose: Secondary video ingest, encoding, signed playback, and playback analytics for select hosted content

Data Processed: Uploaded video files, playback analytics, viewer IP (delivery only)

Location: United States (global CDN)

Cloudflare

Streaming & CDN

Purpose: Live streaming (Cloudflare Stream), asset delivery, and DDoS protection

Data Processed: Stream media, IP addresses, connection metadata

Location: Global edge network

Daily.co

Voice / Video Rooms

Purpose: Real-time voice and video rooms in Closets and livestreams

Data Processed: Voice/video streams (in-transit only), session metadata

Location: United States / Global

Google Cloud (Vision API)

Moderation

Purpose: NSFW, violence, and CSAM scanning on uploaded media

Data Processed: Uploaded images and video frames (for safety classification only)

Location: United States / Global

Cloudmersive

Moderation

Purpose: Virus and malware scanning on uploaded files (marketplace assets, app uploads, message attachments)

Data Processed: Uploaded files (scanned for malware signatures only)

Location: United States

OpenAI

AI & Safety

Purpose: Companion chat (LLM), content moderation classification, audio transcription (Whisper) for uploaded videos, and memory embeddings

Data Processed: Companion prompts, user-authored text submitted for moderation, video audio tracks, memory text

Location: United States

Contractually prohibited from training generalized models on Wallies data.

Anthropic

AI Provider

Purpose: Large language model processing for AI responses

Data Processed: Conversation prompts, user messages (if selected as AI provider)

Location: United States

⚠️ Optional - only if user selects Anthropic as provider

Google (Gemini AI)

AI Provider

Purpose: Large language model processing for AI responses

Data Processed: Conversation prompts, user messages (if selected as AI provider)

Location: United States / Global

⚠️ Optional - only if user selects Google as provider

ElevenLabs

Voice

Purpose: Text-to-speech voice generation for companions

Data Processed: Text messages for voice conversion (no voice recordings stored)

Location: United States

⚠️ Optional - only if user selects ElevenLabs voices

GIPHY

Content

Purpose: GIF search and embedding in chats, comments, and posts

Data Processed: Search queries you type into the GIF picker, IP address (for GIF delivery)

Location: United States

Meta (Facebook / Instagram)

Ad Attribution

Purpose: Ad conversion tracking via Meta Pixel and Conversions API (only if you arrived from a Meta ad)

Data Processed: Hashed email, hashed identifiers, page-view and conversion events

Location: United States / Global

⚠️ Optional - controlled by cookie preferences

Google Ads

Ad Attribution

Purpose: Ad conversion tracking via Google Ads gtag (only if you arrived from a Google Ads campaign)

Data Processed: Hashed identifiers, page-view and purchase conversion events

Location: United States / Global

⚠️ Optional - controlled by cookie preferences

TikTok

Ad Attribution

Purpose: Ad conversion tracking via TikTok Pixel and Events API (only if you arrived from a TikTok ad)

Data Processed: Hashed email, hashed identifiers, page-view and conversion events

Location: United States / Global

⚠️ Optional - controlled by cookie preferences

Data Transfer Mechanisms

For subprocessors outside the EU/EEA, we rely on:

  • Standard Contractual Clauses (SCCs) approved by the European Commission
  • Vendor certifications (e.g., SOC 2, ISO 27001)
  • Contractual data protection obligations

Changes to Subprocessors

This page is the source of truth and is updated whenever we add, remove, or change a subprocessor. For material changes affecting how your personal data is handled, we will notify users in-app (via system message and/or in-app notification) at least 30 days before the change takes effect. Minor operational changes (e.g., regional CDN or infrastructure swaps with no change in data handling) may be reflected on this page without an individual notification. You may object to new subprocessors by contacting us at privacy@wallies.com

Your Rights

You retain all data subject rights (access, deletion, portability) regardless of which subprocessors are involved. Contact privacy@wallies.com to exercise your rights.