European infrastructure

Chobble is a UK company hosted on Bunny.net in Slovenia. Attendee data stays in the EU, so processing is covered by UK-GDPR and EU data protection law rather than the US CLOUD Act.

Where each part of Chobble is based

The companies that Chobble Tickets depends on are listed below, along with where they are headquartered. Most of the stack is based in the UK or EU. The payment processors are the main exception, and that trade-off is explained further down this page.

Part of the stack Company Headquartered in
Ticketing software Chobble United Kingdom
Hosting and CDN Bunny.net Slovenia
Domain registrar Njalla Sweden
Default email provider Mailgun EU EU endpoint (US parent company)
Payment processor Stripe or Square United States

Chobble is a community interest company registered in England. A community interest company cannot distribute profit to shareholders, and its assets are locked to its stated social purpose.

Hosting in the EU

Chobble Tickets runs on Bunny.net, a content delivery network and edge computing platform headquartered in Ljubljana, Slovenia. Bunny operates its own infrastructure across Europe rather than reselling capacity from Amazon, Google, or Microsoft.

Bunny lets you restrict where your data is stored. Edge storage zones can be configured to replicate only within specified regions, so attendee data can be kept inside the EU. If you host Chobble Tickets yourself, you choose which Bunny region your instance runs in and where the database sits.

On Chobble's managed hosting, attendee data is encrypted at rest and the storage zone is configured to keep data in EU regions. You can also run your own instance and pick whichever region suits you.

What this means for GDPR

If your attendees are in the UK or EU, you are the data controller under UK-GDPR or the EU General Data Protection Regulation. On managed hosting, attendee data is stored on EU infrastructure by an EU-headquartered provider, and Chobble itself is a UK company. This keeps the processing within one compatible legal regime, which has a few practical effects:

  • You do not need to rely on the EU-US Data Privacy Framework or Standard Contractual Clauses to justify transferring attendee data outside the EU. The data does not leave the EU.
  • Your privacy policy does not need a section explaining an international data transfer.
  • If there is a data breach, you report it to the ICO in the UK or your national data protection authority, under GDPR procedures you already understand.

The UK has an adequacy decision with the EU, so attendee data can flow between Chobble (UK) and Bunny (Slovenia) without additional safeguards.

Email provider choice

Chobble Tickets lets you pick which email provider sends confirmation emails. The managed hosting default is Mailgun's EU endpoint, which stores email data inside the EU.

The supported providers and where they are based are listed below. You can switch at any time.

Provider Data location
Mailgun EU EU endpoint (Frankfurt)
Mailgun US United States
Postmark United States
Resend United States
SendGrid United States

If you do not configure an email provider, no emails are sent and no third party sees attendee email addresses. Attendees still receive their tickets on the confirmation page and can add them to Apple or Google Wallet.

Where Chobble cannot avoid US companies

Chobble Tickets depends on a few US-based services. This page lists them rather than hiding them.

Payment processors. Chobble Tickets supports Stripe and Square. Both are US companies. Both operate EU subsidiaries (Stripe Payments Europe in Ireland, Square Up Europe in Ireland) that process European transactions under GDPR, but the parent companies are US-domiciled and subject to the US CLOUD Act. There are no equivalent EU-based payment processors with the same reach. If you run free events, no payment processor is involved.

Apple and Google Wallet. Chobble Tickets can generate passes for Apple Wallet and Google Wallet. Both are US companies. Wallet passes are optional. Tickets also work as QR codes on the confirmation page and in email.

GitHub. The source code is hosted on GitHub, which is owned by Microsoft. GitHub holds the code, not attendee data. The code is also mirrored on git.chobble.com, a self-hosted Forgejo instance. You can fork from either one.

Who can legally compel access to the data

When a government wants access to data held by a company, the law that applies depends on where the company is based, not where the data is stored.

The US CLOUD Act, passed in 2018, allows US authorities to compel US-based companies to hand over data they hold, regardless of where the data physically sits. This applies to the US parent of any company with a US presence, including the EU subsidiaries of US cloud providers.

Chobble is a UK company and Bunny is a Slovenian company. Neither is in scope for the CLOUD Act. A request for attendee data would have to go through UK or Slovenian courts under their respective data protection laws, which include judicial oversight and notice requirements that the CLOUD Act does not.

For most organisers this is background detail. For groups running events that might attract official attention - political organising, campaigns on contested issues, migrant and refugee support, reproductive healthcare - it is a more immediate concern.

A note on the domain registrar

The chobble.com domain is registered with Njalla. Njalla operates from Sweden and is incorporated in Saint Kitts and Nevis. It was founded by Peter Sunde, one of the co-founders of The Pirate Bay.

Njalla works differently from most registrars. It takes legal ownership of the domain on the customer's behalf and passes the usage rights to the customer. Takedown requests and legal process go to Njalla first. Njalla publishes the notices it receives alongside its responses, so its approach is a matter of public record.

For most Chobble Tickets organisers, the registrar is invisible in day-to-day use. The reason to name it here is that the domain sits with a small Swedish operator rather than a US-based registrar, which is consistent with the rest of the stack. If you self-host, you pick your own registrar.

For self-hosters

If you self-host Chobble Tickets, you choose the hosting region, the email provider, the payment processor, and the domain registrar. Chobble has no access to your data at all. The encryption keys never leave your environment.

The recommended deployment path uses Bunny.net with EU regions selected. You can also deploy to any Deno-compatible host, including Fly.io (regions include Frankfurt, Amsterdam, Madrid, Paris, Stockholm, and Warsaw), Scaleway in France, or Hetzner in Germany and Finland.

References