Last updated: 17.09.2026
Where Gymtrainer s.r.l. processes personal data on behalf of the Customer in connection with the provision of BookyWay, Gymtrainer s.r.l. acts as a Data Processor pursuant to Article 28 of Regulation (EU) 2016/679 (“GDPR”).
For the provision, operation, security and maintenance of the service, Gymtrainer s.r.l. may engage third-party providers that process personal data on its behalf as sub-processors.
The Customer generally authorises the engagement of such sub-processors in accordance with the BookyWay Terms and Conditions.
Gymtrainer s.r.l. requires its sub-processors to comply with appropriate data protection obligations substantially equivalent to those applicable to Gymtrainer s.r.l., to the extent required by applicable law.
| Provider | Service and purpose | Personal data that may be processed | Processing location / transfers |
| Microsoft Ireland Operations Limited (Microsoft Azure) | Cloud infrastructure used for hosting, storing and technically processing the data required to provide BookyWay. | Customer and authorised-user data; End User data; account, activity, booking, content and other information processed through BookyWay. | BookyWay’s main resources are hosted in the Microsoft Azure West Europe region, located in the Netherlands. Microsoft may engage its own sub-processors; any further processing or international transfers are governed by Microsoft’s Data Protection Addendum and applicable data protection law. |
| Twilio Ireland Limited (Twilio SendGrid) | Service used to send and manage system emails and email communications generated through BookyWay. | Recipient email address, where applicable name, message content and technical delivery data. Email event data such as delivery, bounce, open, click or unsubscribe data may also be processed where the relevant features are used. | The SendGrid configuration currently used by BookyWay is not configured for EU Data Residency and uses dedicated IP addresses in the US region; processing may therefore also take place in the United States. Twilio states in its DPA that, for applicable transfers, it relies on the mechanisms provided by data protection law, including the EU-US Data Privacy Framework and, where necessary, Standard Contractual Clauses. Twilio may also engage its own sub-processors. |
| Functional Software, Inc. d/b/a Sentry (Sentry) | Error monitoring, crash reporting and application-stability service used to identify and resolve technical malfunctions. | Technical and diagnostic data relating to the error and device, such as device model and type, operating system, app version, available memory, date and time of the event, and technical error details. Under BookyWay’s currently stated configuration, directly identifying data (such as name, surname, email address or date of birth) are not intentionally sent and the IP address is anonymised or minimised. | Functional Software, Inc. is a US-based company. Processing may involve transfers to or access from the United States. Sentry offers data-storage regions in the United States and in the EU (Frankfurt); even where the EU region is selected, some account, integration and organisation metadata may be processed in the United States. International transfers are governed by Sentry’s DPA; Sentry states that it participates in the EU-U.S. Data Privacy Framework and uses the Standard Contractual Clauses where applicable. |
Microsoft – Data Protection Addendum: Microsoft Products and Services Data Protection Addendum
Microsoft – sub-processor information: Microsoft Data Access / Online Services Subprocessors
Twilio – Data Protection Addendum: Twilio Data Protection Addendum
Twilio – sub-processor list: Twilio Sub-processors
Twilio SendGrid – EU Data Residency information: SendGrid EU Data Residency FAQ
Sentry – Data Processing Addendum / DPA acceptance instructions: Sentry Data Processing Addendum instructions
Sentry – international transfers and GDPR transfer mechanisms: International Data Transfers with Sentry
Sentry – EU Region FAQ: Sentry EU Region FAQ
Gymtrainer s.r.l. keeps this list up to date.
Where sub-processors are added or replaced, Gymtrainer s.r.l. will inform the Customer in accordance with the BookyWay Terms and Conditions, allowing the Customer to raise any objections based on data-protection grounds.
For further information regarding personal data processing through BookyWay, please contact support@bookyway.com or admin@pec.gymtrainer.net.