Sub-processors and third parties
Last updated: 2026-10-19 Version: 1.11
This page lists the third parties that process personal data on our behalf, or that receive personal data in the course of providing Walteris. It is referenced from our Privacy Policy and updated whenever a provider is added, removed or changed.
| Provider | Role | What it receives | Location |
|---|---|---|---|
| Amazon Web Services (AWS) | Hosting, database, key management, authentication (Cognito), logging; sends the energy calculator’s one report-link email (SES) | All service data | eu-north-1 (Stockholm), EU |
| ESO | The electricity distribution operator: the source of the metering data behind the energy calculator (Privacy Policy section 14), if you use it | Your name, surname, date of birth or personal code, the object number and our statement that you consented, to register an access right (permission to read the object’s data for up to 7 days); returns the object’s card, 12 months of 15-minute import and export readings, for a solar plant the monthly settlement lines and, in some cases, the previous calendar year’s monthly totals (section 14). We cancel the right when the report is built | Lithuania, EU. ESO is an independent controller for its register of access rights and for its own metering data |
| Tesla | Vehicle connection and control | Access token, vehicle identifier, VIN, charging commands; returns charge level, charging status and — with your permission — the car’s position | Tesla EU endpoint. Tesla is an independent controller for its own purposes under its own privacy notice |
| Home battery / inverter manufacturer (varies by device) | Home-battery connection and control, if you connect one | The identifier of your inverter or battery and charge and discharge commands; returns its state of charge and the power flowing into and out of the battery, the solar array and the grid connection. No location, no email, no vehicle data | Depends on the equipment you own. The manufacturer is an independent controller for its own purposes under its own privacy notice. This row is updated with the manufacturer’s name and location as each integration goes live |
| Open-Meteo | Solar generation forecasting | The approximate coordinates of your home, if you add a solar array — the stored point is offset by ~50 m. No account identifier | Germany, EU |
| Mixpanel | Product analytics — in-app usage on consent, server-recorded actions on legitimate interest, website page counts | A fixed list of event names, your internal account identifier, and your device type, operating-system version, app version and a random device identifier created by its library. Kept 13 months. No email, name, vehicle id, VIN, address or coordinates | Mixpanel Inc., United States; EU data residency for storage (api-eu.mixpanel.com). Transfers under the European Commission’s standard contractual clauses |
| Apple | App distribution, subscription billing (merchant of record), and confirming that a subscription is still valid | Your payment relationship is with Apple; we receive no card details, name or billing address. When you subscribe, your app passes Apple our internal identifier for your account so the purchase reaches the right one. When we check the subscription, we send Apple that subscription’s own identifier and nothing else about you | Apple Distribution International Ltd., Ireland. Apple acts as merchant of record and as its own controller for the payment, not as our processor |
| Expo (EAS) | App delivery and over-the-air updates; delivery of push notifications, if you turn them on | Device and app-version metadata when checking for updates. For a notification: the device’s push address and the text of the notification — a short fixed question in your language. No account identifier, email address or coordinates | United States. Transfers under the European Commission’s standard contractual clauses |
| Apple (APNs) | Delivery of notifications to your device | The device’s notification address and the text of the notification, handed on by Expo | Apple Distribution International Ltd., Ireland; delivery under Apple’s own terms |
| MailerLite | Three separate email lists: the website waitlist, if you sign up there; the energy calculator’s news list, if you ask for news there; and product news and tips to app users, if you switch that on in the app | Your email address, plus the language you read in so we write to you in it; on the calculator’s list, the date you asked. The three lists are held as separate groups with their own retention, and none adds you to another: on the waitlist and the calculator’s list an address is confirmed by clicking the link in MailerLite’s email, while the app list is the in-app switch itself, which we timestamp. Nothing else from the app or the calculator reaches them — no name, vehicle, location, meter or usage data | UAB MailerLite, Vilnius, Lithuania, EU |
| Cloudflare | Hosting and edge delivery of the walteris.com site, the energy calculator’s pages included | Standard request metadata for the website only. The calculator’s forms pass through Cloudflare to our servers and are stored nowhere on the way. No app data | Cloudflare, Inc., United States. The site is served from Cloudflare’s global network, so a request may be handled at whichever location is nearest the visitor. Transfers under the European Commission’s standard contractual clauses |
Notes
- The marketing site at walteris.com sets no cookies and stores nothing on your device. It counts page views by telling our own server, which identifies visitors with a one-way fingerprint that is re-salted daily and never leaves our systems. The waitlist conversion event carries a hash of your email address, never the address itself.
- We do not use advertising SDKs, attribution or cross-app tracking, crash reporters, session recording, or any data broker. The app requests no location permission on your phone.
- On your vehicle’s position. With your permission at the manufacturer, we read it about every 15 minutes to answer one question — is the car at home? — and then discard it. No position history is stored, and no position is sent to any of the providers above: Tesla is where it comes from, and nobody receives it. The one coordinate we keep, your home point, is stored shifted by about 50 metres and leaves our own systems only in your data export. Privacy Policy section 4 has the detail, including what that shift is and is not worth.
- We never sell personal data, and Tesla’s developer terms independently prohibit it.
- If we change our solar forecasting provider (the alternatives are OpenWeather, United Kingdom, and Solcast, Australia), this page and the Privacy Policy are updated before the change takes effect, because it changes where your coordinates are sent.
- Transfers outside the EEA rely on an adequacy decision where one exists, and otherwise on the European Commission’s standard contractual clauses.