Pombus Sub-processors
Last updated: September 25, 2026 Applies to: the Pombus service at pombus.com, operated by Willian Clayton de Almeida, an individual, trading as Pombus.
1. What this list is
Pombus uses a small number of infrastructure providers to run the Service. Some of them process personal data on Pombus's behalf, and, for the email content of Business Customers, on the Customer's behalf as sub-operators (sub-operadores under the LGPD, "sub-processors" under the GDPR). This page lists every such provider, what it does, which data it touches, where, and under which transfer mechanism.
The architecture in one sentence: mail moves through Amazon SES and Cloudflare, and is stored at rest only on a server that Pombus operates, inside an encrypted volume.
2. Current sub-processors
| # | Sub-processor | Entity | Service | What it does | Personal data involved | Location | Transfer mechanism |
|---|---|---|---|---|---|---|---|
| 1 | Amazon Web Services | Amazon Web Services, Inc. | Amazon SES | Sends outbound email and signs it with DKIM; scans for spam and malware | Full message content and metadata, transiently, while in transit | United States (us-east-1) | AWS Data Processing Addendum, which includes the EU Standard Contractual Clauses; Pombus will adopt the ANPD standard contractual clauses as they become available from these providers |
| 2 | Amazon Web Services | As above | Amazon SNS | Delivers bounce, complaint, and delivery notifications | Event metadata, including recipient addresses; no message content | United States (us-east-1) | As above |
| 3 | Cloudflare | Cloudflare, Inc. | Email Routing and Workers | Receives inbound email at the edge for pombus.com and for Customer Domains whose MX records point to Cloudflare, and passes it to Pombus's storage server through a Worker that does not keep message bodies | Full message content and metadata, transiently | Global edge network (may include the United States and other regions) | Cloudflare Data Processing Addendum, which includes the EU Standard Contractual Clauses; Pombus will adopt the ANPD standard contractual clauses as they become available from these providers |
| 4 | Cloudflare | Cloudflare, Inc. | Workers, Pages, DNS, TLS termination, DDoS protection | Serves the website, the web application, and the API | API requests and responses, which may contain message content, transiently | Global edge network | As above |
| 5 | Cloudflare | Cloudflare, Inc. | D1 | Stores web application data: session and user preferences | Account data only; no message content | Cloudflare global network; no location restriction configured | As above |
| 6 | Cloudflare | Cloudflare, Inc. | R2 | Stores user avatar images and daily encrypted backups of the message store, each deleted automatically after a 30-day retention window | Account data (avatars); encrypted backups of message content and metadata, which Cloudflare cannot decrypt | Cloudflare global network; no location restriction configured | As above |
| 7 | Hostinger | Hostinger (contracting entity as identified in the Hostinger terms) | Virtual private server hosting | Hosts the server and the LUKS-encrypted volume on which message content, attachments, and message metadata are stored at rest (SQLite database and compressed, content-addressed blob store, inside a Docker container). The provider has physical and hypervisor access to the machine but does not receive the volume encryption key | Full message content and metadata at rest, in encrypted form | Brazil | Hostinger data processing terms; data at rest remains in Brazil |
3. Providers that are not sub-processors
These providers process personal data for which Pombus is the controller (account, billing, or operational data), but never email content. They are disclosed here for transparency and in the Privacy Policy.
| Provider | Purpose | Data | Location |
|---|---|---|---|
| Stripe | Payment collection as payment intermediary (card, Pix, and other methods); Pombus remains the seller and issues the receipts (Terms of Service, Section 5.2) | Billing contact, payment identifiers, transaction records | As stated in Stripe's privacy terms (may include the United States) |
| Error monitoring, analytics, or transactional email provider | None at this time. | — | — |
4. How Pombus notifies changes
- Pombus updates this page at least 30 days before a new sub-processor starts processing personal data on its behalf (DPA Section 8.4).
- Pombus notifies changes by updating subprocessors.html and emailing the Account owner.
- A Business Customer may object to a new sub-processor on reasonable data protection grounds within 15 days after the notice, as set out in DPA Section 8.5. If the objection is not resolved, the Customer may terminate the affected Service and receive a pro-rata refund of prepaid, unused fees.
- In an emergency (for example, replacing a provider to preserve the continuity or security of the Service), Pombus may replace a sub-processor immediately and will update this page and notify Customers as soon as possible afterwards (DPA Section 8.6).
5. Questions
Data Protection Officer (Encarregado): Willian Clayton de Almeida, dpo@pombus.com.
6. Change history
| Date | Change |
|---|---|
| September 25, 2026 | Initial list: Amazon Web Services (SES, SNS), Cloudflare (Email Routing, Workers, Pages, D1, R2), Hostinger. |