Steady
A single roll-up of ownership and CLOUD Act exposure.
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EU-Sovereign EU/EEA/Switzerland-owned and -operated, with no identified CLOUD Act exposure.
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EU-Based EU-operated, with at most minor or transient US exposure.
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EU-Hosted This listing EU hosting available, but a US parent or hyperscaler sub-processor creates material exposure.
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US-Linked Operated by a US-incorporated entity, directly subject to US jurisdiction.
Steady Media GmbH, Voltastr. 5, 13355 Berlin, Germany
Berlin membership platform for publishers (Steady Media GmbH): 10% commission, acts as merchant of record and handles EU VAT, but publishes no DPA and no sub-processors list.
Steady offers EU hosting in Germany, but a US parent or sub-processor leaves material CLOUD Act exposure. It is listed under Membership platforms.
Assessment notes
Steady is a Berlin membership platform for publishers and media makers, operated by Steady Media GmbH and backed by German investors (Müller Medien and the Berlin public VC fund IBB Ventures / VC Fonds Kreativwirtschaft), so ownership is unambiguously EU. It is also the only platform in this category that acts as the merchant of record: Steady bills members, collects and remits VAT across EU member states, and pays creators out in one settlement, which removes the cross-border VAT work a creator would otherwise carry. The compliance picture is weaker than the ownership picture. Steady publishes no DPA and no sub-processors list, its privacy notice is dated February 2022, and it does not state where the platform is hosted. The notice itself names a long US chain: Cloudflare (DDoS and CDN), Intercom, Inc. (in-product chat, San Francisco), imgix (image CDN), embed.ly / A Medium Corporation (embedded content), Google Analytics, and the Meta pixel, with Google Workspace, Zendesk and Mailchimp visible in the mail configuration: Material. Member payments run over PayPal (Europe) S.à r.l., Apple Pay via Apple Distribution International, and SEPA direct debit via GoCardless Ltd (UK); no EU-incorporated card acquirer is named. Missing DPA caps this at 3/5 on its own.
Findings
- CLOUD Act
- CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
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None EU operator, no US parent, no US sub-processors of note.
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Minor A transient US sub-processor (CDN, maps); data at rest stays in the EU.
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Material This listing US parent, or a core sub-processor is a US-owned hyperscaler.
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Direct The operator itself is US-incorporated.
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- Ownership
- Ownership
Where ultimate control over the operating company sits.
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EU-owned This listing EU-incorporated and EU-controlled; no significant US ownership.
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EU HQ, US-funded EU-headquartered but US venture- or PE-controlled.
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EU subsidiary, US parent European operating company owned by a US parent company.
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US-owned The operating company itself is US-headquartered.
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Other A non-EU jurisdiction. Swiss/EEA-owned vendors count as European here; the UK and others do not.
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- Sub-processors
- 17 · 12 US
Verified signals
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EU / adequacy hosting: Yes
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EU / adequacy operator: Yes
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No US CLOUD Act exposure: No
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Public DPA: No
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Sub-processors disclosed: No
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Open-source clients: No
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Third-party certification: No
Jump to
About Steady
Steady is a membership platform built for publishers and independent media, operated by Steady Media GmbH from Voltastraße in Berlin. Founded in 2016 by the team behind Krautreporter, it sells memberships for newsletters, magazines, podcasts and video channels, with a hosted member area, an email sending layer, member analytics and a public API. Its investors are German: Müller Medien and the Berlin public venture fund IBB Ventures (VC Fonds Kreativwirtschaft), which is why ownership reads as EU-owned with no US capital in the cap table.
The commercial model is a flat 10% commission on member revenue, plus the payment provider's own fee, with nothing to pay until money comes in. What genuinely separates Steady from the rest of this category is that it is the merchant of record: it contracts with the member, issues compliant invoices, collects and remits VAT at the member's own country rate across the EU, and transfers the creator one consolidated payout. For a German or French creator with subscribers in a dozen member states, that removes the single most tedious part of running paid memberships. Members can pay by card, PayPal, Apple Pay or SEPA direct debit.
For a sovereignty audit the record is mixed and the gaps are documentation gaps. Steady publishes no data processing agreement and no sub-processors list, the privacy notice carries a February 2022 date, and nowhere does the company state which data centre or country the platform runs in. What the notice does disclose is a substantial US chain: Cloudflare in front of the site, Intercom, Inc. for in-product chat, imgix as image CDN, embed.ly (A Medium Corporation) for embedded media, Google Analytics and the Meta pixel, and Google Workspace, Zendesk and Mailchimp visible in the mail records: Material. On the money side, PayPal (Europe) S.à r.l. is a Luxembourg entity under US ownership, Apple Pay runs through Apple Distribution International, and SEPA direct debit goes through GoCardless Ltd in the UK; no EU-incorporated card acquirer is named anywhere. Best fit: European publishers that value the VAT and invoicing work being done for them, and that can accept a vendor which has not yet published the procurement paperwork.
Sub-processor map · 17
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Apple Distribution International USIreland
Member payments via Apple Pay
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Cloudflare, Inc. USUnited States
CDN and DDoS protection in front of steady.page and steadyhq.com
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embed.ly (A Medium Corporation) USUnited States
Embedding third-party media on publisher pages
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Google Ireland Limited (Google Analytics) USIreland
Website analytics (consent-gated); data may be transferred to Google sub-processor facilities outside the EU under SCCs
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Google Ireland Limited (Google Workspace) USIreland
Corporate and support email (from public MX and SPF records)
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imgix USUnited States
Image content delivery network
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Intercom, Inc. USUnited States
In-product chat support (stores message content and IP addresses)
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Intuit Mailchimp USUnited States
Marketing email delivery (from public SPF record)
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Meta Platforms Ireland Limited USIreland
Meta pixel conversion tracking and advertising (consent-gated); event data forwarded to Meta Platforms, Inc. in the US
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PayPal (Europe) S.à r.l. et Cie, S.C.A. USLuxembourg
Member payments via PayPal
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Twitter International Company USIreland
Conversion tracking for advertising (consent-gated)
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Zendesk, Inc. USUnited States
Support ticketing and support email (from public SPF record)
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GoCardless Ltd non-USUnited Kingdom
Member payments via SEPA direct debit
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Hotjar Ltd EUMalta
Heatmaps and on-site behaviour analytics (consent-gated)
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Ortto (Autopilot) non-USAustralia
Marketing automation email delivery (from public SPF record)
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Powerplay GmbH (Cello) EUGermany
Referral tracking and referral rewards
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Tally BV EUBelgium
In-product feedback surveys
| Vendor | Country | Purpose | Owner |
|---|---|---|---|
| Apple Distribution International | Ireland | Member payments via Apple Pay | US |
| Cloudflare, Inc. | United States | CDN and DDoS protection in front of steady.page and steadyhq.com | US |
| embed.ly (A Medium Corporation) | United States | Embedding third-party media on publisher pages | US |
| Google Ireland Limited (Google Analytics) | Ireland | Website analytics (consent-gated); data may be transferred to Google sub-processor facilities outside the EU under SCCs | US |
| Google Ireland Limited (Google Workspace) | Ireland | Corporate and support email (from public MX and SPF records) | US |
| imgix | United States | Image content delivery network | US |
| Intercom, Inc. | United States | In-product chat support (stores message content and IP addresses) | US |
| Intuit Mailchimp | United States | Marketing email delivery (from public SPF record) | US |
| Meta Platforms Ireland Limited | Ireland | Meta pixel conversion tracking and advertising (consent-gated); event data forwarded to Meta Platforms, Inc. in the US | US |
| PayPal (Europe) S.à r.l. et Cie, S.C.A. | Luxembourg | Member payments via PayPal | US |
| Twitter International Company | Ireland | Conversion tracking for advertising (consent-gated) | US |
| Zendesk, Inc. | United States | Support ticketing and support email (from public SPF record) | US |
| GoCardless Ltd | United Kingdom | Member payments via SEPA direct debit | non-US |
| Hotjar Ltd | Malta | Heatmaps and on-site behaviour analytics (consent-gated) | EU |
| Ortto (Autopilot) | Australia | Marketing automation email delivery (from public SPF record) | non-US |
| Powerplay GmbH (Cello) | Germany | Referral tracking and referral rewards | EU |
| Tally BV | Belgium | In-product feedback surveys | EU |
Source: the vendor’s published sub-processor list, read 10 Aug 2026.
Frameworks & certifications · none listed
Capability matrix
Table 2Capabilities of Steady
Integration & access
Compliance & governance
Pricing & tiers
Public documents
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missingData Processing Addendum (DPA)— missing
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missingSub-processors list— missing
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OpenTerms of Servicesteady.page/en…
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How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
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Minor A transient US sub-processor (CDN, maps); data at rest stays in the EU.
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Material US parent, or a core sub-processor is a US-owned hyperscaler.
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Direct This listing The operator itself is US-incorporated.
Public DPA: No Sub-processors: No Open source: No -
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How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
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Minor A transient US sub-processor (CDN, maps); data at rest stays in the EU.
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How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
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None EU operator, no US parent, no US sub-processors of note.
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Minor A transient US sub-processor (CDN, maps); data at rest stays in the EU.
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Material This listing US parent, or a core sub-processor is a US-owned hyperscaler.
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Direct The operator itself is US-incorporated.
Public DPA: No Sub-processors: Yes Open source: Yes -
| Product | Sovereignty | CLOUD Act | Signals | From |
|---|---|---|---|---|
|
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US-Linked | CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
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Public DPA: No
Sub-processors: No
Open source: No
|
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|
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EU-Hosted | CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
|
Public DPA: No
Sub-processors: No
Open source: No
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$12/mo |
|
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EU-Hosted | CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
|
Public DPA: No
Sub-processors: Yes
Open source: Yes
|
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