Annex 1 to the Gameheim Customer Agreement (https://www.gameheim.com/agreement), of which it is an integral part: the sub-processors Virsion relies on and the third-party terms that apply. This online version is the version in force (art. 11.1 of the Agreement and § 6 below). Version 1.2 of 12 October 2026. The Italian version prevails in case of discrepancy.
1. Purpose and scope
This Annex 1 is an integral and substantial part of the Agreement and implements the references in arts. 1.3, 11, 12.1 and 12.3. It identifies the sub-processors and infrastructure subcontractors Virsion relies on to provide the Service, together with the applicable third-party terms, conditions and documentation.
Those third-party terms cannot be negotiated by Virsion and apply directly to the services provided by the respective third parties. In case of conflict between this Annex and the referenced third-party terms, the latter prevail solely for the services those parties provide, without prejudice to Virsion's mandatory obligations towards the Customer and to applicable mandatory law.
The version of this Annex in force is the one published and/or notified by Virsion under the update mechanism in § 6. The Customer shall periodically consult the updated version.
2. Roles in the processing (reference to art. 12.1)
- Customer: Controller (for the Organization's data).
- Virsion: Processor (for the Organization's data); independent Controller for registration and billing.
- Parties listed in § 3: Sub-processors or independent providers, as stated there.
- Epic Games, when the Customer enables the forwarding of Unreal Engine editor crashes: not a Sub-processor, but a recipient chosen by the Customer that processes the data as an independent controller (Annex B, § 6).
3. List of sub-processors / subcontractors
3.1 Microsoft Corporation
| Field | Detail |
|---|---|
| Company name | Microsoft Corporation |
| Registered office | One Microsoft Way, Redmond, WA 98052, USA |
| Data-centre regions used | West Europe (Netherlands); Italy North (Milan), for the database; North Europe (Ireland), for Azure AI Search. Azure Front Door is a global delivery network |
| Services provided | Infrastructure hosting (compute, storage, database, networking), AI services (Azure OpenAI, Azure AI Search), secrets management (Key Vault), CDN and WAF (Front Door), monitoring (Log Analytics) |
| Categories of data processed | Customer Data (content, wiki, documents, messages, voice recordings, Perforce metadata, Unreal Engine crash data), Users' Personal Data (credentials, access logs), AI prompts and Output, usage metadata |
| Role | Sub-processor |
| Legal basis for transfers outside the EU/CH | EU-US Data Privacy Framework; Standard Contractual Clauses (SCCs) included in the Microsoft DPA |
3.2 Stripe
| Field | Detail |
|---|---|
| Company name | Stripe Payments Europe, Limited; for authorised payment services, Stripe Payments UK Ltd (contracting entities for Swiss accounts) |
| Registered office | Dublin, Ireland (parent company: Stripe, Inc., San Francisco, CA, USA) |
| Services provided | Payment processing, subscription management and checkout |
| Categories of data processed | The Customer's billing and payment data (full card data is processed exclusively by Stripe) |
| Role | For payment processing Stripe also acts as an independent controller under its own terms; for the other services, provider/processor under the Stripe DPA |
| Legal basis for transfers outside the EU/CH | EU-US Data Privacy Framework; Standard Contractual Clauses included in the Stripe DPA |
3.3 Google LLC (Firebase Cloud Messaging)
| Field | Detail |
|---|---|
| Company name | Google LLC |
| Registered office | 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA |
| Data-centre region used | Global Firebase/FCM infrastructure (Google Cloud) |
| Services provided | Firebase Cloud Messaging (FCM): delivery of push notifications to the Android and iOS mobile apps. Service messages only, no personal data or content in the payloads. |
| Categories of data processed | Device FCM token and, on iOS, APNs token; device identifier, platform. No user personal data passes through FCM. |
| Role | Sub-processor |
| Legal basis for transfers outside the EU/CH | EU-US Data Privacy Framework; Standard Contractual Clauses |
3.4 Apple Inc. (Apple Push Notification service)
| Field | Detail |
|---|---|
| Company name | Apple Inc. |
| Registered office | One Apple Park Way, Cupertino, CA 95014, USA |
| Data-centre region used | Global Apple infrastructure |
| Services provided | APNs: final delivery to iOS devices of the push notifications forwarded by Firebase Cloud Messaging; Virsion does not send data to Apple directly. Service messages only, no personal data or content in the payloads. |
| Categories of data processed | Device APNs token, device identifier. No user personal data passes through APNs. |
| Role | Infrastructure subcontractor |
| Legal basis for transfers outside the EU/CH | EU-US Data Privacy Framework; Standard Contractual Clauses |
3.5 Hostinger International Ltd
| Field | Detail |
|---|---|
| Company name | Hostinger International Ltd |
| Registered office | 61 Lordou Vironos str., 6023 Larnaca, Cyprus (EU) |
| Services provided | Sending transactional email from Virsion's domain through Hostinger mail servers (account verification, service notifications, administrative communications) |
| Categories of data processed | Email address, name, content of service emails |
| Role | Sub-processor |
| Legal basis for transfers outside the EU/CH | Not applicable, processing within the EU |
Note on geolocation (GeoIP): country-level geolocation of accesses is performed internally using the MaxMind GeoLite2 database hosted on the Service's systems: no data is sent to MaxMind, which is therefore not a recipient of the data.
4. Applicable third-party terms, conditions and documentation
4.1 Microsoft / Azure
4.2 Stripe
| Document | URL |
|---|---|
| Stripe Services Agreement (Switzerland) | https://stripe.com/en-ch/legal/ssa |
| Stripe Data Processing Agreement | https://stripe.com/legal/dpa |
| Stripe Privacy Policy | https://stripe.com/privacy |
| Stripe Privacy Center | https://stripe.com/legal/privacy-center |
4.3 Google / Firebase
| Document | URL |
|---|---|
| Google Cloud Data Processing Addendum | https://cloud.google.com/terms/data-processing-addendum |
| Firebase Terms of Service | https://firebase.google.com/terms |
| Firebase Privacy | https://firebase.google.com/support/privacy |
4.4 Apple
| Document | URL |
|---|---|
| Apple Developer Program License Agreement | https://developer.apple.com/support/terms/ |
| Apple Privacy | https://www.apple.com/legal/privacy/ |
4.5 Hostinger
| Document | URL |
|---|---|
| Hostinger Data Processing Addendum (DPA) | https://www.hostinger.com/legal/dpa |
| Hostinger Universal Terms of Service | https://www.hostinger.com/legal/universal-terms-of-service-agreement |
5. Logs, retention and Zero Data Retention (reference to art. 12.3)
Unless specifically configured and where available, the «Zero Data Retention» mode for Azure OpenAI is not enabled by default.
Microsoft's policies on technical logs, retention and abuse monitoring described in the documentation in § 4 apply.
Current Gameheim configuration:
| Service | Retention |
|---|---|
| Azure OpenAI | Abuse monitoring active (Microsoft default). Prompt/completion data may be kept for up to 30 days for abuse-monitoring purposes, unless an opt-out is approved by Microsoft. |
| Log Analytics (Virsion) | 31 days for application logs, access logs and security (WAF) logs. |
| SQL database | Retention managed by Virsion under the Agreement's policies (art. 10). |
| Azure Storage | Data kept for the term of the Agreement; Unreal Engine crash minidumps and logs for 90 days (Annex B, § 5). Deletion on termination (art. 5.5). |
| Stripe | Retention under Stripe's policies and the legal obligations on accounting and anti-money-laundering. |
Zero Data Retention for Azure OpenAI is available on request to Microsoft for eligible customers. It requires Microsoft's approval and disables abuse monitoring. Virsion will consider enabling it at the Customer's request, subject to the applicable Microsoft conditions.
6. Updates to the list and right to object
This clause specifies and completes the reference in art. 11.1 of the Agreement (updated online version).
Virsion may add or replace sub-processors by notifying the Customer at least 20 (twenty) days before the change takes effect, by written notice to the email address of the Organization's administrator and/or an in-platform notice.
The Customer may object to the change on reasonable, documented data-protection grounds within 15 days of the notice.
If no agreed solution is found within 15 days of the objection, the Customer may withdraw without penalty, limited to the affected services, as its sole remedy.
The online version is the version in force; the date of the last update is shown at the top of this Annex.
7. Points of contact
| Role | Contact |
|---|---|
| Virsion's point of contact for data protection | info@virsion-studio.com |
| Customer's point of contact | Administrator of the Organization (registration email) |
