Gameheim

Legal

Annex 1: Sub-processors

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

FieldDetail
Company nameMicrosoft Corporation
Registered officeOne Microsoft Way, Redmond, WA 98052, USA
Data-centre regions usedWest Europe (Netherlands); Italy North (Milan), for the database; North Europe (Ireland), for Azure AI Search. Azure Front Door is a global delivery network
Services providedInfrastructure 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 processedCustomer 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
RoleSub-processor
Legal basis for transfers outside the EU/CHEU-US Data Privacy Framework; Standard Contractual Clauses (SCCs) included in the Microsoft DPA

3.2 Stripe

FieldDetail
Company nameStripe Payments Europe, Limited; for authorised payment services, Stripe Payments UK Ltd (contracting entities for Swiss accounts)
Registered officeDublin, Ireland (parent company: Stripe, Inc., San Francisco, CA, USA)
Services providedPayment processing, subscription management and checkout
Categories of data processedThe Customer's billing and payment data (full card data is processed exclusively by Stripe)
RoleFor 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/CHEU-US Data Privacy Framework; Standard Contractual Clauses included in the Stripe DPA

3.3 Google LLC (Firebase Cloud Messaging)

FieldDetail
Company nameGoogle LLC
Registered office1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
Data-centre region usedGlobal Firebase/FCM infrastructure (Google Cloud)
Services providedFirebase 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 processedDevice FCM token and, on iOS, APNs token; device identifier, platform. No user personal data passes through FCM.
RoleSub-processor
Legal basis for transfers outside the EU/CHEU-US Data Privacy Framework; Standard Contractual Clauses

3.4 Apple Inc. (Apple Push Notification service)

FieldDetail
Company nameApple Inc.
Registered officeOne Apple Park Way, Cupertino, CA 95014, USA
Data-centre region usedGlobal Apple infrastructure
Services providedAPNs: 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 processedDevice APNs token, device identifier. No user personal data passes through APNs.
RoleInfrastructure subcontractor
Legal basis for transfers outside the EU/CHEU-US Data Privacy Framework; Standard Contractual Clauses

3.5 Hostinger International Ltd

FieldDetail
Company nameHostinger International Ltd
Registered office61 Lordou Vironos str., 6023 Larnaca, Cyprus (EU)
Services providedSending transactional email from Virsion's domain through Hostinger mail servers (account verification, service notifications, administrative communications)
Categories of data processedEmail address, name, content of service emails
RoleSub-processor
Legal basis for transfers outside the EU/CHNot 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

DocumentURL
Stripe Services Agreement (Switzerland)https://stripe.com/en-ch/legal/ssa
Stripe Data Processing Agreementhttps://stripe.com/legal/dpa
Stripe Privacy Policyhttps://stripe.com/privacy
Stripe Privacy Centerhttps://stripe.com/legal/privacy-center

4.3 Google / Firebase

DocumentURL
Google Cloud Data Processing Addendumhttps://cloud.google.com/terms/data-processing-addendum
Firebase Terms of Servicehttps://firebase.google.com/terms
Firebase Privacyhttps://firebase.google.com/support/privacy

4.4 Apple

DocumentURL
Apple Developer Program License Agreementhttps://developer.apple.com/support/terms/
Apple Privacyhttps://www.apple.com/legal/privacy/

4.5 Hostinger

DocumentURL
Hostinger Data Processing Addendum (DPA)https://www.hostinger.com/legal/dpa
Hostinger Universal Terms of Servicehttps://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:

ServiceRetention
Azure OpenAIAbuse 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 databaseRetention managed by Virsion under the Agreement's policies (art. 10).
Azure StorageData 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).
StripeRetention 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

RoleContact
Virsion's point of contact for data protectioninfo@virsion-studio.com
Customer's point of contactAdministrator of the Organization (registration email)