Institutions
Subprocessors
The service providers that process personal data for us, what they do, and where.
Effective · Last updated
1. Current subprocessors
These providers process personal data on our behalf to run ITSPracticing. Each is bound by a written agreement with data-protection obligations at least as protective as our Data Processing Agreement.
| Provider | What they do | Personal data involved | Location |
|---|---|---|---|
| Neon, Inc. (on Amazon Web Services) | Primary database; storage for session-recording files | All Service data: accounts, institutional data, work product, activity, assessment, recordings | European Union — Frankfurt, Germany (AWS eu-central-1) |
| Vercel Inc. | Application hosting, serverless functions, content delivery | Data passing through requests; technical logs | United States, with a global edge network |
| Clerk, Inc. | Sign-in, sign-up, sessions, invitation and verification emails | Name, email, password hash, sign-in history, IP address, browser and device details | United States |
| Cloudflare, Inc. (through Clerk) | Bot protection on account creation (Turnstile) | Browser and device signals, IP address, at sign-up | Global network |
| Hangzhou DeepSeek Artificial Intelligence Co., Ltd. — only if an Institution enables AI | Generating replies for AI-played characters and the coach | The text of the learner's message and the fictional mission context; no name or email address is sent | People's Republic of China, according to the provider's published privacy policy |
2. Services you choose to use
If you choose “Continue with Google”, Google LLC confirms your identity and shares your name and email address with us. Google acts as an independent controller under its own privacy policy, not as our subprocessor.
3. Changes
We will update this page before a new subprocessor starts processing personal data, and Institutions that have signed our Data Processing Agreement will be notified at least 30 days in advance, with the right to object as set out in that agreement. To be notified, or for copies of transfer safeguards, write to privacy@itspracticing.com.