Sub-processors of RETEX
Version 1.1 · Last updated: 2026-10-11 · Operated by ARSHIVE GROUP - FZCO, a Dubai free zone company, licence number 64407, IFZA Business Park, DDP, Premises no 64407-001, Dubai Silicon Oasis, Dubai, United Arab Emirates. Questions: support@retexapp.com.
This page lists the third parties that ARSHIVE GROUP - FZCO ("we") uses to process personal data when we act as a processor for a merchant who has installed RETEX (see the Data Processing Agreement and the Privacy Policy). It is the list referred to in Article 28(2) and (4) of Regulation (EU) 2016/679 (GDPR).
1. Sub-processors we engage
| Sub-processor | Purpose | Data involved | Location of processing | Transfer basis |
|---|---|---|---|---|
| Google Cloud EMEA Limited (Google Cloud Run and Cloud SQL) | Runs the application servers and the production database | All data described in the Privacy Policy, including return requests, order references, customer contact details and encrypted integration credentials | Belgium, Google Cloud region europe-west1 | None needed while all processing stays in the EEA. The provider's data processing terms include the Standard Contractual Clauses for any access to data from outside the EEA, and the provider is certified under the EU-U.S. Data Privacy Framework |
| Google Cloud EMEA Limited (files are stored in the Cloud SQL database) | Stores photos uploaded with return requests, uploaded or generated shipping labels and email attachments | Images and files; may contain personal data visible in the file | Belgium, Google Cloud region europe-west1 | As above |
| Lettermint B.V. | Sends the customer notifications and acknowledgements that a merchant's return flow generates, from RETEX's sending domain | Recipient name and email address, order and return reference, message content | EU (Netherlands) | As above, including the Standard Contractual Clauses for any part of the provider's processing or support access outside the EEA |
We do not use a separate error-tracking service: application errors are written to the logs kept by the hosting provider, after email addresses, tokens and credentials have been removed. We do not use any sub-processor for advertising, analytics or profiling.
2. Services that are not our sub-processors
- Shopify. RETEX is installed from, and reads order and customer data through, the Shopify platform. Shopify provides that platform to the merchant under the merchant's own agreement and is not engaged by us. We also use Shopify's Partner API to see which subscription plan a shop has chosen; that call involves the shop's identifier and plan, not customer personal data.
- Carriers chosen by the merchant. A merchant may connect its own account with a carrier (for example UNISEND or InPost) so that return labels or return codes are created for its customers. When the merchant does so, our application sends the data the carrier needs to create the shipment (typically the sender's name, contact details and the parcel-locker or address) to that carrier, using the merchant's credentials and on the merchant's instruction. The merchant has its own contract with the carrier, and the carrier processes this data as its own controller or as the merchant's processor, not as ours. The carriers currently supported are listed in the support page.
- The merchant's own mail servers. If a merchant configures its own SMTP or IMAP mailbox, mail is sent and read through that mailbox. The merchant's mail provider is the merchant's processor.
3. How changes are made
We will give each merchant at least 30 days' notice before a new sub-processor starts processing the merchant's personal data, or before a sub-processor is replaced.
- How we notify. By email to the contact address stored for the shop in RETEX, and by updating this page and its "Last updated" date.
- Right to object. Within the notice period the merchant may object on reasonable data-protection grounds by writing to support@retexapp.com. We will then work with the merchant to find a solution, for example by not using the new sub-processor for that merchant's data. If no solution is found, the merchant may terminate the affected service as set out in the Terms of Service and the Data Processing Agreement.
- Urgent replacements. If a sub-processor must be replaced immediately for security or continuity reasons, we notify merchants as soon as possible and the right to object applies from the date of notice.
4. Our commitments for every sub-processor
We enter into a written agreement with each sub-processor that imposes data-protection obligations equivalent to those in our Data Processing Agreement with the merchant, we remain responsible to the merchant for the sub-processor's performance, and we prefer providers that process data in the European Economic Area. Where a provider or its personnel can access data from outside the EEA, we put the Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914) or another transfer mechanism permitted by Chapter V GDPR in place before any such access. Our own access from the United Arab Emirates, where we are based, is covered by section 7.2 of our Data Processing Agreement.