Subprocessors
Kula relies on the providers below to run the service. Each of them is bound by a data processing agreement with obligations at least as protective as those of our Data Processing Agreement. Data is stored in the European Union. Where a provider is established outside the EU, transfers are covered by the European Commission's Standard Contractual Clauses and, where the provider is certified, by the EU-US Data Privacy Framework.
Infrastructure
| Provider | Purpose | Data | Location |
|---|---|---|---|
| Hetzner Online GmbH | Hosting of the application and the database; encrypted database backups | All service data | Germany (servers), Finland (backups) |
| Amazon Web Services EMEA SARL (Amazon SES) | Delivery of emails; bounce and complaint notifications | Recipient addresses, email content, delivery events | France (Paris region) |
| Functional Software, Inc. (Sentry) | Application error monitoring | Technical data attached to an error, which may include an account identifier | European Union |
Optional features
| Provider | Purpose | Data | Location |
|---|---|---|---|
| Anthropic, PBC | AI assistant built into the dashboard, only when a user writes to it | The conversation, and the account data the assistant reads to answer (for example a campaign or a segment) | United States |
Requests to the AI assistant are processed under Anthropic's commercial terms: Anthropic does not use them to train its models. Customers who do not use the assistant send no data to Anthropic. AI agents that customers connect to Kula through MCP are chosen and operated by the customer, and are not subprocessors of Kula.
Support
| Provider | Purpose | Data | Location |
|---|---|---|---|
| Proton AG | Mailbox of support@kulamail.com | Messages sent to support | Switzerland |
Independent providers
Creem sells Kula's paid plans as merchant of record. It processes billing and payment data as an independent controller, under its own privacy policy, and is not a subprocessor.
Changes to this list
We announce a new subprocessor at least 30 days before it starts processing customer data, by updating this page and emailing the owners of paid accounts. A customer who objects on reasonable data protection grounds can tell us at support@kulamail.com during that period; if we cannot address the objection, the customer can terminate the affected service and receive a refund of any prepaid, unused amount.