Sub-processor register republished: PRD-107 v1.1

PASSNFLY has republished its public sub-processor register.

The register now reproduces the owner-approved "Automated Check-in Sub-Processor Register and Data Recipient Disclosure" (PRD-107 v1.0, last reviewed 31 July 2026) and adds an amendment disclosing the vendors the service uses at runtime.

Summary of changes:

• Direct sub-processors (PRD-107 baseline): AWS Cloud Infrastructure, Amazon SES (reactivated), Mailchimp Transactional (new), Vonage SMS (new), Twilio SMS.
• External recipients / user-selected platforms (PRD-107 baseline, disclosed for transparency): airlines, carrier reservation & departure-control systems, airport & security systems, Apple Wallet, Google Wallet, recipient email/telecom networks.
• Amendment (runtime vendors): Resend, Replit, Neon, OpenAI (via Replit AI gateway), Mindee, Stripe, SorryApp, Google Cloud Translation; user-selected: Google Sign-In & Gmail import, Google Fonts.
• Retired (not used by the service): SendGrid, MongoDB Atlas, Zendesk, Sentry.

This is a consolidated disclosure notice covering the full republication; individual notices were intentionally not sent per row. Reason: republication of the owner-approved register (PRD-107 v1.0, last reviewed 31 July 2026) plus the ATT amendment disclosing vendors already in production use; delaying disclosure by 30 days would knowingly prolong an inaccurate public register, contrary to the transparency objective of GDPR Art. 28. One consolidated notice is issued instead of per-row dispatches.

Full register: https://7d0ef576-5d24-4545-b6f7-38d8a2fbb7d3-00-3n7sl7tvo7wm8-kl8sozzj.riker.replit.dev/compliance/subprocessors

If you have questions or objections, contact our Data Protection Officer at dpo@passnfly.com. You can manage or cancel this subscription from the link in any notification email.