Legal
Subprocessors
Version of 28 October 2026. 8 sections.
Working draft: some service provider details below (contact email and phone) are still to be completed.
- Service provider
- Sebastian Małucha
- Brand
- ViralMedia
- Address
- ul. Orzechowa 45 lok. 12, 50-540 Wrocław
- Tax ID (NIP)
- 8992491352
- Business ID (REGON)
- 021319283
- hello@hiretorin.com
- Vulnerability reports
- security@hiretorin.com
The entities that data may reach while the product runs, and when. Every external address the system connects to has an entry here. A grey entry in the Based in column means “not checked”: we have not confirmed that location yet, or the provider has not been chosen.
Polish version: Podwykonawcy. In case of discrepancy the Polish version prevails.
§ 1Language model
| Who | What for | When | Based in |
|---|---|---|---|
| Anthropic | Torin's answers, reports, drafts, web search | with every question to Torin; web search only after you approve the amount shown | USA |
| OpenAI | Torin's answers, transcription, images | only when the agency picks this provider in the settings | USA |
| OpenRouter | Torin's answers with another model | only when the agency picks this provider in the settings | not checked |
§ 2Client accounts
| Who | What for | When | Based in |
|---|---|---|---|
| Google Ads, Search Console, GA4, Business Profiles, sign-in | on the agency's instruction, after the account is connected | USA | |
| Meta | Meta Ads, WhatsApp | on the agency's instruction, after the account is connected | USA |
| TikTok | TikTok Ads (read only) | on the agency's instruction, after the account is connected | not checked |
| LinkedIn Ads (read only) | on the agency's instruction, after the account is connected | not checked | |
| Shopify | shop orders (read only) | when the agency connects a client's shop | not checked |
| Microsoft Clarity | aggregate on-site behaviour numbers (read only) | when the agency connects the client's project | not checked |
| Microsoft | Microsoft Advertising (read only) | on the agency's instruction, after the account is connected | USA |
§ 3Paid data sources
| Who | What for | When | Based in |
|---|---|---|---|
| DataForSEO | keyword rank tracking | only after you approve the amount shown | not checked |
§ 4Public data sources
| Who | What for | When | Based in |
|---|---|---|---|
| Eurostat (European Commission) | number of businesses by industry and region, for market analysis | during market analysis; we send only a region and industry code | EU |
| Statistics Poland (GUS), Local Data Bank | business statistics for Polish regions, for market analysis | during market analysis; we send only the region name and industry | Poland |
| National Bank of Poland | exchange rates for prices in euro and dollars | when checking the rate; we send only the currency code and dates | Poland |
| IMGW-PIB | weather in the business's city when explaining a drop | hourly, and monthly from the archive, once the terms are confirmed; we send no business or personal data | Poland |
| CEIDG business register (biznes.gov.pl) | sole traders from the public register, for the list of businesses to win | when the agency adds its own CEIDG token and starts a search; we send an industry code, region or tax ID | Poland |
| National Court Register (KRS, Polish Ministry of Justice) | companies from the public register, for the list of businesses to win | when searching or adding a company by its KRS number; no key needed | Poland |
§ 5Payments
| Who | What for | When | Based in |
|---|---|---|---|
| Przelewy24 | the agency's plan payment (BLIK, bank transfer) | at payment, when the agency chooses Przelewy24 | Poland |
§ 6Agency channels and integrations
Chat and sign-in
| Who | What for | When | Based in |
|---|---|---|---|
| Slack | chatting with Torin | when the agency connects it | USA |
| Telegram | chatting with Torin | when the agency connects it | not checked |
| Microsoft | Teams, company sign-in | when the agency connects it | USA |
| Okta | company sign-in | when the agency sets it up | USA |
Work tools and data
| Who | What for | When | Based in |
|---|---|---|---|
| Brave Search | search through the agency's own MCP server | when the agency connects its own key | USA |
| HubSpot | CRM | when the agency connects it | USA |
| Notion | documents | when the agency connects it | USA |
| GitHub | code repositories | when the agency connects it | USA |
| Stripe | payments of the agency's clients | when the agency connects it | USA |
| Make | automations | when the agency connects it | Czechia |
| Zapier | automations | when the agency connects it | USA |
| Ahrefs | SEO data | when the agency connects it | Singapore |
| Asana | tasks | when the agency connects it | USA |
| Atlassian | Jira, Confluence | when the agency connects it | Australia |
| Canva | graphics | when the agency connects it | Australia |
| Fakturownia | invoices | when the agency connects it | Poland |
| Figma | designs | when the agency connects it | USA |
| Linear | tasks | when the agency connects it | USA |
| MailerLite | email campaign results | when the agency connects it | not checked |
| Brevo | email campaign results | when the agency connects it | not checked |
| Mailchimp | email campaign results | when the agency connects it | not checked |
| Klaviyo | email campaign results | when the agency connects it | not checked |
| GetResponse | email campaign results | when the agency connects it | not checked |
| Pipedrive | CRM | when the agency connects it | not checked |
| ClickUp | tasks | when the agency connects it | not checked |
| monday.com | tasks | when the agency connects it | not checked |
| Trello | tasks | when the agency connects it | not checked |
| Wix | client websites | when the agency connects it | not checked |
§ 7Image and sound
| Who | What for | When | Based in |
|---|---|---|---|
| Deepgram | transcribing recordings | when someone sends a recording | USA |
| ElevenLabs | speech synthesis | on request | not checked |
| Runway | video | on request | USA |
| Google (Gemini API) | scenes around a product photo in Creative Studio | only after you approve the amount shown | USA |
| Stability AI | images | on request | United Kingdom |
§ 8Infrastructure
| Who | What for | When | Based in |
|---|---|---|---|
| Cloudflare | checking DNS records of client domains, MCP | when a domain is connected | USA |
| Service hosting | hosting the database and the application | always | not checked |
| Email provider | sign-in codes, notifications | at sign-in | not checked |
| Payment provider | the agency's prepaid plan | at payment | not checked |
| Postmark | sending Torin's emails (sign-in codes, notifications, reports) | when the installation picks this email provider | not checked |
| Mailgun | sending Torin's emails (sign-in codes, notifications, reports) | when the installation picks this email provider | not checked |
| Amazon Web Services (SES) | sending Torin's emails (sign-in codes, notifications, reports) | when the installation picks this email provider | USA |
Working draft, before final legal review. It describes what the system actually does and does not replace a contract.