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Subprocessor Schedule

Schedule version 2026-10-01

How approval works

This page must match production and the Order Form. Code support or a provider’s marketing page does not approve it for School Data. Each active school subprocessor requires legal entity verification, a DPA/flow-down, security review, country/transfer analysis, retention/deletion terms and incident duties. The downstream model endpoint behind an AI gateway is also a subprocessor.

Default Cloudflare service

ProviderPurpose / dataLocation and status note
CloudflareWorkers, D1, R2, KV, Durable Objects, Vectorize, delivery, security and operational analytics; account, School Data, files, application/security eventsThe standard service uses Cloudflare infrastructure and may process data internationally. Product-specific storage jurisdictions do not establish an EU-only boundary for the whole service.
ClerkAuthentication and account administration; name, email, ID, profile, auth/security eventsSeparate identity system. Current contract, transfer mechanism, retention and subprocessor evidence required for European/Swiss School use.
OpenRouter + named model endpointAI gateway/inference; feature-specific prompt, selected content, image/audio when used, outputSchool requests require ZDR/no-training and allowlisted endpoint. A gateway alone does not establish where the downstream model processes data.
Google Cloud / Google APIsOptional text-to-speech; Google Classroom connection, identifiers, roster/course data and OAuth token when enabledService/location depends on product and contract. Classroom is School-enabled; OAuth scopes must stay minimal.
StripeCheckout, subscription, invoice and payment administration; purchaser and transaction dataAdministrator/billing data, not intended for Student educational content. Ekadem does not store full card details.
Cloudflare Email Routing / bound senderInvitations and service messages; recipient email and necessary school/class message detailsThe actual production sender/provider and region must be named and reviewed before School launch.
KLIPYUser-requested sticker search/delivery; search text and network request dataOptional content feature. Disable for School use until child/privacy, content-safety, contract and transfer review are complete.

Requested custom school deployment

A school may request a separate Ekadem installation on a school-specific subdomain, such as bergfeld.ekadem.com. When agreed in its Order Form and DPA, the core application uses Hetzner, Clerk and TensorX in place of the default hosting and AI stack, and its email is delivered by Cloudflare Email Service. This is a separately configured installation; changing an AI setting on the shared Cloudflare service does not move a school’s data.

ProviderPurpose / dataLocation and limits
Hetzner Online GmbHDedicated school application hosting, database, uploaded files, realtime state, processing jobs, application logs and agreed backupsAn EU facility is selected for the installation and its backup destinations. The Order Form identifies the actual locations, retention and support arrangements.
ClerkAuthentication and account administration; account identifiers, names, email, profile and authentication/security eventsRemains a separate identity provider. Its processing locations, subprocessors and transfer safeguards follow the applicable Clerk agreement; an EU application server does not establish EU-only identity processing.
TensorXAI inference; necessary feature inputs and context, outputs and operational usage metadataThe agreed EU endpoint and provider/model chain must be approved for the school. AI requests are locked to TensorX and never fall back to OpenRouter or another AI provider. A feature without a supported endpoint or configured model is unavailable.
Cloudflare Email ServiceDelivery of invitations, reminders, announcements and service alerts; recipient email address and name where given, sender, subject, message content with the necessary school/class details and links, announcement attachments, and delivery statusUsed only to send email. The LMS, its database and stored files stay on the Hetzner installation; each message leaves it for delivery. Cloudflare processes messages on its global network, so email delivery is not EU-only. The installation sends through Cloudflare alone and refuses any other mail relay.

OpenRouter, Google AI, KLIPY and the default Cloudflare application services are not used to process School Data in this profile; Cloudflare receives only the email it delivers. Integrations or other optional services require agreement and an updated school-specific schedule before activation. Commercial billing for the Order Form may be administered separately from the school LMS and is disclosed separately.

The core provider list does not remove those providers’ own subprocessors. Their current chains and contracts must be included in the school’s evidence register. See TensorX subprocessors, Clerk’s DPA and Cloudflare’s DPA. Public website access and DNS administration may continue using Cloudflare separately from the custom LMS.

To discuss a custom deployment, contact privacy@ekadem.com. Availability and any geographic commitments are confirmed in the school’s Order Form, DPA and provider schedule.

Changes and objections

Schools receive the DPA notice before a new subprocessor handles School Data and may object on reasonable data-protection grounds. Questions, evidence requests and objections: privacy@ekadem.com.

Production blockerThe actual deployment and signed vendor evidence determine the school’s approved provider chain. A listed technical option is not confirmation that contracts, locations and feature approvals have been completed.
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