Subprocessors

Last updated: 3 October 2026

WPXFacets uses the subprocessor below to provide the dedicated managed Elasticsearch service. This page forms the current subprocessor list referenced by the WPXFacets Data Processing Agreement.

Current subprocessors

Hetzner Online GmbH

Address: Industriestr. 25, 91710 Gunzenhausen, Germany

Service and processing: Physical infrastructure, virtual-server and storage hosting for each customer’s dedicated managed node.

Processing location: The EU site assigned and disclosed by WPXFacets for the subscription: Nuremberg or Falkenstein, Germany, or Helsinki, Finland. For a contracting company established in the United States, WPXFacets assigns Ashburn, Virginia or Hillsboro, Oregon only after the applicable DPA transfer and provisioning conditions are met; provisioning is held while they are unmet. WPXFacets chooses and discloses the site before processing; the customer does not choose a Hetzner region.

Date listed: 24 August 2026

Hetzner operates the physical infrastructure, hypervisor, and network. WPXFacets operates the guest operating system, Elasticsearch, per-server gateway, and application-level access controls.

Hetzner’s own current subprocessor information is available from its data-protection documentation.

Hetzner’s published onward-provider list names Hetzner US LLC, NTT Global Data Centers Americas, Inc. and QTS Investment Properties Hillsboro, LLC for US infrastructure.

According to Hetzner’s written confirmations, Hetzner Online GmbH remains the contractual provider and operates Hetzner Cloud. Hetzner US LLC provides local infrastructure and server-related arrangements, including contracts with the colocation providers, but does not receive or process Customer Data or data stored on the servers. NTT and QTS provide colocation without access to server data. Hetzner states that Customer Data and server data are not disclosed to other US companies and that support access is carried out only by employees located in the EU. These statements describe the provider flow; they are not a blanket finding that every WPXFacets data flow is outside Chapter V.

Hetzner states that Cloud-server backups and logs are stored in the US when the server location is in the US, and otherwise in the EU. This describes the location of such copies if present, not the existence of WPXFacets-managed index backups. WPXFacets must identify and address any actual copies under Annex II C. The provider makes encryption of server data the account customer’s responsibility; WPXFacets’ current measures and limitations are disclosed in Annex III. Hetzner’s existing DPA remains the provider agreement, and Hetzner confirms that no additional DPA is required for choosing a US Cloud location. Location authorisation does not replace any required Chapter V mechanism or WPXFacets’ security duties.

WPXFacets must document the actual assigned-site chain and effective safeguards before Customer Data is processed there. The above providers are Hetzner’s infrastructure/onward providers, not separate direct appointments by WPXFacets. Internal colocation agreements have not been disclosed to WPXFacets; no US-site audit, executed SCC or DPF certification is asserted by this DPA.

Before any US-node processing, WPXFacets must determine and document whether GDPR Chapter V applies to each actual data flow. Where it applies, WPXFacets must establish the applicable lawful transfer mechanism and any required transfer assessment and safeguards. WPXFacets must also verify the selected site’s actual provider chain, contractual authorisation, security and overseas-processing risks, and disclose the assignment to the Customer in advance. Where the documented facts establish that a provider flow is not a Chapter V transfer, no transfer instrument is required for that flow; this does not remove the other obligations or resolve a separate disclosure to the Customer. Listing US locations does not by itself authorise processing.

Retention and deletion responsibilities

WPXFacets remains responsible for the DPA’s maximum 90 UTC calendar-day Search Analytics retention, calculated from each aggregate’s original UTC day, and automatic deletion of expired data independently of the customer’s plugin or WordPress traffic. Disabling, disconnecting, uninstalling or expiry of access does not extend retention; reactivation does not reset age. Requested complete-dataset deletion and end-of-service return/deletion remain distinct. Infrastructure power-off is not deletion or grounds for indefinite storage.

After effective loss of subscription entitlement, WPXFacets keeps the VPS running for seven calendar days for renewal or payment resolution, with customer access and collection blocked and managed cleanup continuing. This does not extend Analytics retention. Without reactivation by the deadline, WPXFacets destroys the VPS and verifies effective deletion, including existing copies, in accordance with the Customer’s documented instruction and the DPA’s adopted Clause 10 return/deletion obligations. Pending cancellation starts no period before the paid term ends; plugin uninstall, disconnection or Analytics disablement does not trigger destruction while the subscription is active.

Changes and objections

WPXFacets will email the account address at least 30 days before a new or replacement subprocessor begins processing Customer Data. The notice will identify the subprocessor, its role, processing location, and intended start date.

A customer may object during that notice period on reasonable data-protection grounds by contacting support@wpxfacets.com. WPXFacets will work with the customer in good faith to resolve the objection. The rights in the Data Processing Agreement continue to apply.

Change history

24 August 2026 — Initial page published with Hetzner Online GmbH as the sole subprocessor for the managed Elasticsearch service.
1 October 2026 — Clarified WPXFacets hosting assignment and conditional US onward-provider disclosure. US processing remains subject to the DPA conditions.
3 October 2026 — Updated the attributed Hetzner provider roles and access/location confirmations; clarified flow-specific Chapter V assessment without asserting an executed transfer instrument or operational clearance.