Data residency statement

Draft, not in force. Version 0.1 of 6 October 2026.

This statement takes effect on {{EFFECTIVE_DATE}}.

This statement is Annex V of the data processing agreement and is published on app.socializza.com. In this statement "Socializza" means ITALDRONI S.r.l., which provides the Socializza service.

The principle

Regulation (EU) 2016/679 (GDPR) does not require data to be stored in the European Union. It requires every transfer to a third country to meet the conditions of Chapter V. Residency in the Union is therefore a commitment that Socializza makes on its own initiative. For this reason every exception is listed here before the contract is signed.

Socializza stores all customer data in the European Union, with the sole exceptions listed below for payments and for the channels that the customer activates.

Socializza also chooses European-owned providers. For this reason the table of exceptions also lists the non-European-owned providers that process data in the Union.

Data stored in the European Union

Data	Where	Provider
PostgreSQL database with the workspace data described in Annex II of the data processing agreement, the member accounts and the billing data. Platform tokens are encrypted with a key specific to each workspace.	Amazon Lightsail virtual server, eu-central-1 region, Frankfurt, Germany.	Amazon Web Services EMEA SARL, Luxembourg, exception 6
Post media, deleted no later than 7 days after publication or cancellation.	The Amazon Lightsail server of the first row, eu-central-1 region, Frankfurt, Germany.	Amazon Web Services EMEA SARL, Luxembourg, exception 6
Backups of the database and of the key store snapshots, encrypted before upload. Socializza keeps 30 days of rolling backups and one monthly copy for 12 months.	AWS S3, eu-central-1 region, Frankfurt, Germany.	Amazon Web Services EMEA SARL, exception 2
Security logs of sign-in and abuse prevention, which keep the IP address for 30 days. Server operational logs and metrics, from which personal data is removed at ingestion, kept for 30 days.	Security logs, operational logs and metrics on the server of the first row.	Amazon Web Services EMEA SARL, Luxembourg, exception 6
OpenBao key store, which holds the key that encrypts the keys of the individual workspaces. The unseal shares are held outside the servers.	On the Amazon Lightsail server of the first row, eu-central-1 region, Frankfurt, Germany.	Amazon Web Services EMEA SARL, Luxembourg, exception 6. Socializza uses no key management services of US providers.

Exceptions

Each row describes a flow that leaves the Union or that a non-European-owned entity processes.

Flow	Data that leaves or that a non-European entity processes	Recipient	Reason	Chapter V mechanism	Customer can turn it off
1. Transactional email with Amazon SES	Recipient's email address, account username, agent name and a link to the app. The messages never contain the text of posts, media or comments.	Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855 Luxembourg, a company of a US group. eu-central-1 region, Frankfurt, Germany. Sub-processor.	Sending approvals, notifications, sign-in links and waiting-list messages. Socializza uses no other mail channel.	The data stays in the eu-central-1 region. The standard contractual clauses of Commission Implementing Decision (EU) 2021/914 apply, which the AWS GDPR Data Processing Addendum, part of the AWS Service Terms, applies to every transfer outside the European Economic Area.	No
2. Encrypted backups with Amazon S3	Copy of the database and of the key store snapshots, in encrypted form only. AWS never receives the key.	Amazon Web Services EMEA SARL, as in row 1. eu-central-1 region, Frankfurt, Germany. Sub-processor.	Backup vault with deletion lock (Object Lock).	As in row 1.	No
3. Web subscription payments with Stripe	The customer's billing and payment data, such as company name, country, VAT number, plan and customer reference. Socializza never puts workspace content in Stripe's description fields or metadata.	Stripe Payments Europe, Limited, Dublin, Ireland, and Stripe, LLC, United States. Stripe acts as independent controller and as processor.	Collecting subscriptions, SEPA Direct Debit, tax calculation and invoices. Stripe does not offer storage of payment data in the Union only.	Stripe's data processing agreement, part of the Stripe Services Agreement. Stripe's Data Transfer Addendum relies first on the adequacy decision on the EU-US Data Privacy Framework, under which Stripe, LLC is certified, and in the alternative on the standard contractual clauses.	No, for web payments. An in-app purchase replaces this flow with exception 4, which also leaves the Union. The Agenzia plan is sold on the web only. The Gratis plan requires no payment.
4. In-app purchases with Apple and Google	Buyer and payment data, collected by the store. Socializza receives from the store the subscription data for the plan purchased.	Apple Distribution International Ltd, Hollyhill Industrial Estate, Hollyhill, Cork, Ireland, for the App Store. Google, for Google Play. Both act as seller (merchant of record).	Selling subscriptions within the iOS and Android apps, at the same prices as on the web.	No data processing agreement is available. Apple and Google process purchase data as independent controllers under their own terms. Apple Inc., United States, is not certified under the EU-US Data Privacy Framework; Apple's privacy policy names standard contractual clauses as the mechanism. Google LLC, United States, is certified under the Data Privacy Framework, so the transfer relies on the adequacy decision, Commission Implementing Decision (EU) 2023/1795 of 10 July 2023.	No, for in-app purchases. Paying on the web replaces this flow with exception 3, which also leaves the Union.
5. Push notifications with APNs and FCM	An opaque identifier and the device token. The app downloads the content from the server in the Union when the user opens the notification.	Apple Inc., One Apple Park Way, Cupertino, California, for Apple Push Notification service (APNs), and Google LLC, 1600 Amphitheatre Parkway, Mountain View, California, for Firebase Cloud Messaging (FCM), both in the United States. Recipients named in the privacy notice, not sub-processors.	Delivering notifications to the iOS and Android apps.	No customer content leaves the Union. For APNs, Apple Inc. is not certified under the EU-US Data Privacy Framework, and Apple's privacy policy names standard contractual clauses as the mechanism. For FCM, Google LLC acts as processor of Socializza under the Firebase Data Processing and Security Terms. Google LLC is certified under the Data Privacy Framework, so the transfer relies on the adequacy decision, Commission Implementing Decision (EU) 2023/1795 of 10 July 2023, and in the alternative on the standard contractual clauses of those terms.	Yes, by turning off push notifications.
6. Hosting with Amazon Lightsail	The categories in Annex II of the data processing agreement and the media uploaded by the customer. Platform tokens are stored in encrypted form only.	Amazon Web Services EMEA SARL, as in row 1. eu-central-1 region, Frankfurt, Germany. Sub-processor.	A virtual server hosting the database, the application, the key store and the media.	As in row 1.	No

Rows 3 and 4 concern billing data and row 5 push notification data, which Socializza processes as controller under the privacy notice. This data falls outside the data processing agreement. It does fall within the residency commitment, and for this reason it appears here. AWS, for rows 1, 2 and 6, also appears in the list of sub-processors, Annex IV of the data processing agreement.

Social platforms

On the customer's instruction, Socializza publishes on social platforms and reads their data. At launch the platforms are X and, through Meta, Facebook Pages, Instagram and Threads. The platforms are recipients that the customer chooses, set out in Annex II of the data processing agreement. Each processes the data as an independent controller, in its own relationship with the customer and under its own terms. These flows therefore fall outside the residency commitment of this statement.

Services that do not process customer data

These services are not sub-processors and do not appear in the list of sub-processors.

Service	What it processes	Why it processes no customer data
Cloudflare	Only the DNS records of socializza.com, with no proxy and no web application firewall.	Customer traffic does not pass through Cloudflare.
Tailscale	The control plane of the private network between Socializza's servers, with the servers' keys and metadata, such as node names and addresses.	The control plane exchanges only keys and metadata, and no customer content passes through it. ITALDRONI assessed the service against the European-ownership commitment and accepted it. The planned next step is Headscale, hosted in the Union.
GitHub	Source code, continuous integration and container images.	The build processes do not access customer data.
Codemagic	Building the iOS and Android apps.	It builds the code and receives no customer data.

Channels excluded at launch

Approvals through Telegram and WhatsApp are not offered at launch and do not appear in this statement. Any channel added later enters with the 30-day notice of section 5.5 of the data processing agreement and adds a new row to the table of exceptions.