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Sub-processors

These are the companies that process personal data for Refract. For the data agencies and businesses add about their clients, they are sub-processors under our data processing agreement. We tell workspace owners by email at least 14 days before adding or replacing one. Questions: info@refractads.com.

Last updated 17 October 2026·Privacy policy·Terms and conditions·Data processing agreement·Trust centre
On this pageHosting and the app platformProviders engaged by Base44Providers for Refract's own account and billingServices you connect yourselfChanges

Hosting and the app platform

Refract is built and hosted on Base44. Base44 stores and processes all customer data in the app, and engages its own providers listed in the next section.

CompanyWhat it does for RefractLocationTransfer safeguard
Base44, Inc.App hosting, database, file storage (ad images), sign-in, transactional emails (sign-in codes and invitations), basic usage statistics, and the AI service used for builder stepsUnited StatesStandard Contractual Clauses or EU-US Data Privacy Framework (Base44 DPA)

Providers engaged by Base44

Base44 publishes these as its sub-processors (base44.com/dpa/exhibitc). They process customer data only to run the Base44 platform that Refract is built on.

CompanyWhat it doesLocation
MongoDBDatabase storage and hostingUnited States
RenderServer hostingUnited States
SupabaseMedia hosting (uploaded images)United States
Twilio SendGridSending emailsUnited States
Google CloudAnalytics servicesUnited States
DatadogLoggingUnited States
OpenAIAI model used for builder stepsUnited States
AnthropicAI model used for builder stepsUnited States
Wix.com Ltd.Base44's parent company: providing and improving the platformIsrael (EU adequacy decision)

For builder steps, only the campaign brief, public page text, claims, existing-ad text and the content of that step are sent to the AI model. Imported results, API keys and invited people's email addresses are never sent.

Providers for Refract's own account and billing

These handle data about Refract's customers (the workspace owner's billing details), not the data customers add about their clients.

CompanyWhat it doesLocation
StripePayments, invoices and the billing portal. Card details are entered on Stripe's own page. Stripe acts as an independent controller for fraud prevention and legal compliance.Ireland and United States

Services you connect yourself

If you connect an OpenAI Ads Manager account to a client, Refract uses the API key you provide to read that account's delivery and conversion reports. OpenAI processes that account's data under your own agreement with OpenAI, so it isn't a Refract sub-processor. Refract never changes campaigns through the connection.

Changes

When we add or replace a sub-processor we update this page and email workspace owners at least 14 days beforehand (or as soon as we're told, if one of our providers gives us less notice). You can object on reasonable data protection grounds by emailing info@refractads.com, as set out in the data processing agreement.

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