Subprocessors and Service Providers
PhiShark uses certain third-party service providers to provide the Services. This page describes sub-processors that may process customer personal data on behalf of PhiShark and main service providers that have a different role in terms of data protection.
1. Subprocessors
The following providers may process personal data on behalf of PhiShark, depending on the PhiShark feature and technical configuration used:
| Provider | Service | Major processing zone |
|---|---|---|
| Hetzner Online GmbH | Server and infrastructure services | European Union / selected server region |
| Google Cloud Platform | Cloud infrastructure, storage and related technical services | Depending on the selected service and region |
| Groq | AI inference services | USA / relevant infrastructure of the provider |
| Cerebras Systems, Inc. | AI inference services | USA |
Each subprocessor processes only the data necessary for the service provided to it.
PhiShark puts into effect the necessary data processing agreements with sub-processors where required by applicable data protection legislation and ensures the implementation of appropriate technical and administrative measures.
2. Independent service providers
Some service providers may not be sub-processors processing data on behalf of PhiShark and may act as independent data controllers for their own purposes in respect of certain transactions.
To the extent that Dodo Payments, PhiShark is used as Merchant of Record in purchasing and subscription processes, it may act as an independent data controller in terms of payment transactions, tax, fraud prevention, sanctions controls, chargeback and related legal obligations, subject to its own confidentiality conditions.
The privacy policy of the relevant provider also applies to the personal data you provide directly to these providers.
3. International data transfers
In cases where personal data must be transferred outside Türkiye, the European Union/EEA or the United Kingdom, PhiShark uses appropriate transfer mechanisms required by applicable legislation.
These are, according to concrete transfer;
- Appropriate assurances and standard contracts stipulated in Article 9 of the KVKK;
- European Commission Standard Contractual Clauses (SCC);
- applicable international transfer mechanisms in terms of the UK GDPR; or
- other transfer mechanisms permitted by the relevant legislation
may contain.
4. Subprocessor changes
PhiShark keeps this list up to date.
Where PhiShark acts as a data processor on behalf of a customer and general subprocessor authority is granted, if a new subprocessor is added or an existing subprocessor is replaced, relevant customers will be notified in advance as specified in the applicable DPA or contract.
The customer may object to the new subprocessor within the period specified in the applicable contract and on reasonable data protection grounds.
5. Communication
For questions about subprocessors or international data transfers:
PHISHARK TEKNOLOJİ ANONİM ŞİRKETİ Cevizli Mah. Zuhal Cad. Ritim Istanbul Sitesi A5 Blok No:46E İç Kapı No:179 Maltepe/İstanbul MERSIS: 0729137429700001