Czech creator membership platform (Herohero a.s., Prague): flat 10% all-in fee and strong local reach, but the terms also contract through a Delaware corporation and content sits on Google Storage.
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- CLOUD ACT
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A single roll-up of ownership and CLOUD Act exposure.
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, in the Membership platforms category, offers EU hosting with Germany as its hosting location, but a US parent or sub-processor leaves material CLOUD Act exposure.
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.
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
Where ultimate control over the operating company sits.
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.
Member payments via Apple Pay
CDN and DDoS protection in front of steady.page and steadyhq.com
Embedding third-party media on publisher pages
Website analytics (consent-gated); data may be transferred to Google sub-processor facilities outside the EU under SCCs
Corporate and support email (from public MX and SPF records)
Image content delivery network
In-product chat support (stores message content and IP addresses)
Marketing email delivery (from public SPF record)
Meta pixel conversion tracking and advertising (consent-gated); event data forwarded to Meta Platforms, Inc. in the US
Member payments via PayPal
Conversion tracking for advertising (consent-gated)
Support ticketing and support email (from public SPF record)
Member payments via SEPA direct debit
Heatmaps and on-site behaviour analytics (consent-gated)
Marketing automation email delivery (from public SPF record)
Referral tracking and referral rewards
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 |
Czech creator membership platform (Herohero a.s., Prague): flat 10% all-in fee and strong local reach, but the terms also contract through a Delaware corporation and content sits on Google Storage.
UK creator platform (Ko-fi Labs Limited) for tips, memberships and digital shops: 0-5% service fee, but payouts run only through PayPal, Inc. or Stripe, Inc., with no EU payment option.
French non-profit association running an open-source recurring-donation platform: 0% platform cut, but hosted on AWS Ireland with Stripe and PayPal as the only payment routes.