Skip to main content
sabondojo

Subprocessors

We use infrastructure providers to run the service. They act as subprocessors: they may only process data on our instructions, which in turn follow the school's. This list is public and versioned, and nothing is added to it quietly.

Version 2026-08-16 · effective 2026-08-16

Draft

Draft — pending legal review

We wrote this ourselves at sabondojo, from our own reading of Ley 25.326 (Argentina), the LGPD (Brazil), the GDPR (EU), Ley 21.719 (Chile), the LFPDPPP (Mexico), Ley 1581 (Colombia) and COPPA (United States). No lawyer has reviewed it yet. We are publishing it as a draft anyway, because a school needs something concrete to read before trusting us with its students' data — and a text you can argue with beats a text that does not exist. Nothing here is legal advice.

Current providers

ProviderRoleData processedRegionStatus
NeonManaged PostgreSQL databaseAll application data, including health data and consent recordsConfirmed per school; pinned to the EU for EU schoolsIn use
VercelApplication hosting, private file storage (Blob) and cookieless aggregate analyticsApplication content in transit, payment receipts, profile pictures, scanned consent formsGlobal network; functions and storage in the configured regionIn use
MercadoPagoBilling the school's subscriptionThe school's billing details. Receives no student dataArgentina and LATAMIntegration in progress

"Integration in progress" means the provider is planned and contracted but is not yet receiving personal data from the system. When it starts to, we change the status and publish a new version of this page.

How we announce a change

Before adding a new subprocessor, or changing the role of an existing one, we publish the change here and notify each school at least 30 days in advance.

During that period the school may object in writing, with reasons. If we cannot find a reasonable alternative, it may cancel the service without penalty and export its data.

An urgent replacement caused by a serious provider failure may happen before the notice period ends; in that case we notify immediately and explain why.

Contractual instruments

We have each provider's data processing agreement in place, with standard contractual clauses where there is an international transfer. Schools can ask us for copies of the publicly available ones and for the effective hosting region.

Subprocessors — sabondojo