Sub-processors
Draft for pilot use. Review by a solicitor before relying on it.
These are the suppliers TutorMaestry uses that may process personal data in your account, on our behalf, under the Data processing agreement. Each is bound by a written contract with data protection terms at least as protective as ours.
Some are used only if you connect them or use the feature: the "When it is used" column says which.
| Sub-processor | Company | What for | Personal data | Where | When it is used | Transfer safeguard |
|---|---|---|---|---|---|---|
| Fly.io | Fly.io, Inc. | Hosting: runs the application and stores its database and uploaded files | All customer data held in the service | Paris, France (EU) | Always | Held in the EU (UK adequacy regulations). Any access from the US is covered by the provider's DPA with the UK Addendum to the EU Standard Contractual Clauses |
| Tigris | Tigris Data, Inc. | Off-site backups | Encrypted copies of the database and files. Encrypted before upload; the provider cannot read them | EU storage region | Always | UK Addendum to the EU Standard Contractual Clauses (the provider's DPA); the content is unreadable to the provider |
| Anthropic | Anthropic, PBC | The AI report writer and assistant | What a feature sends: for a report, a pupil's first name, curriculum objectives and levels and notes the tutor has allowed; for the assistant, what the tutor types. Not used to train AI models | United States | Only on plans with AI, when the tutor uses an AI feature | UK International Data Transfer Addendum to the EU Standard Contractual Clauses (the provider's commercial DPA) |
| Google LLC | Signing in with Google and calendar sync | The tutor's Google account email; calendar event titles, times and attendees | United States and global | Only if the tutor connects a Google account | UK Extension to the EU-US Data Privacy Framework, and the UK Addendum in Google's DPA | |
| Stripe | Stripe Payments Europe, Ltd. and Stripe, Inc. | Taking subscription payments; card payments from families if the tutor connects Stripe | Billing name, email and payment details (card details go straight to Stripe, never to TutorMaestry); for family payments, the payer's name, email and amount | Ireland (EU) and United States | Paid plans; family payments only if the tutor connects Stripe | UK Extension to the EU-US Data Privacy Framework, and the UK Addendum in Stripe's DPA |
| GoCardless | GoCardless Ltd | Direct Debit payments from families | The payer's name, email and the amount; bank details are handled by GoCardless directly | United Kingdom | Only if the tutor connects GoCardless | None: processed in the UK |
| Email delivery | [CONFIRM: email delivery provider] | Sending the emails the tutor sends or approves, and account emails | Recipient address and the email's content | [CONFIRM: location] | When email is set up for the account | [CONFIRM: transfer mechanism, if outside the UK or EU] |
| Sentry | Functional Software, Inc. (Sentry) | Error monitoring | Technical error details. Configured to send no personal data: no request bodies, no form values, no names or emails, links carrying a secret scrubbed | Frankfurt, Germany (EU) | Always | Held in the EU (UK adequacy regulations); the provider's DPA includes the UK Addendum for any US access |
Changes to this list
We tell you at least 30 days before we add or replace a sub-processor: this page is updated with a new version and effective date, a notice appears in the app, and the account owner is emailed where email is set up. You can object, as the Data processing agreement (section 9) explains.
Not on this list
Suppliers that never receive personal data are not sub-processors (for example, the public exchange-rate service used to convert currencies, which is sent only currency codes and dates).
Questions: [CONFIRM: support email].