Sub-Processors
Summary
Every vendor that touches your data is listed here with exactly what data they receive and why. We use the minimum number of vendors needed to run EMStudio. Most vendors never see student data at all.
1. What Is a Sub-Processor?
A sub-processor is any third-party company that processes personal data on our behalf to help operate EMStudio. Under GDPR Article 28 (see also our GDPR compliance page), we are required to disclose every sub-processor and ensure each one protects your data to the same standard we do. We also maintain this list to satisfy the record-keeping requirements of Article 30.
This page is the authoritative, complete list. If a vendor is not listed here, it does not have access to your data. For a broader overview of how we handle personal information, see our Privacy Policy.
2. Our Commitments
For every sub-processor we use, we commit to:
- Contractual controls: Every vendor is under a data processing agreement that restricts how they may use your data
- Minimum necessary data: We share only the data each vendor needs to perform its function — nothing more (see our data-sharing principles)
- No student data to analytics or marketing vendors: PostHog, Google Analytics, and Kit never receive student names, grades, attendance, or any student information. See our Cookie Policy for analytics details.
- No student data to AI: OpenRouter receives only lesson metadata (title, subject, class name, content preview) — never student data. Read more in our AI features disclosure.
- Advance notice of changes: We notify users 30 days before adding any new sub-processor that processes personal data (see Section 6)
3. Current Sub-Processors
| Vendor | Purpose | Data Shared | Location | Privacy Policy |
|---|---|---|---|---|
| Supabase | Database, authentication, and real-time subscriptions | All teacher and student data entered in the app | United States (AWS us-east-1) | View |
| Cloudflare R2 | File storage for lesson attachments, avatars, and uploads | Teacher-uploaded files (documents, images) | Global edge network | View |
| Stripe | Payment processing and subscription management | Teacher billing email, last four card digits, country | United States | View |
| OpenRouter (Google Gemini) | AI-powered lesson planning assistance | Lesson title, subject, class name, content preview — no student data, no grades | United States | View |
| PostHog | Product analytics (consent required in EU/UK/CA) | Teacher usage events, page views — no student data | United States | View |
| Google Analytics | Marketing analytics and conversion tracking (consent required in EU/UK/CA) | Page views, conversion events — no student data | United States | View |
| Kit (ConvertKit) | Transactional and marketing email delivery | Teacher email, first name, trial date | United States | View |
| Vercel | Application hosting, CDN, and serverless functions | Request metadata (scrubbed of PII) | Global edge network | View |
4. What Student Data Reaches Each Vendor
Most of our sub-processors never see student data. Here's the breakdown:
| Vendor | Receives Student Data? | Details |
|---|---|---|
| Supabase | Yes | Stores all app data including student records. Encrypted at rest (AES-256). Row-level security ensures per-teacher isolation. See Supabase Security and our Security page. |
| Cloudflare R2 | Possibly | Only if a teacher uploads files containing student information (e.g., a PDF report). R2 stores files; it does not read or index their content. See Cloudflare Trust Hub. |
| Stripe | No | Only receives teacher billing information. See Stripe Security. |
| OpenRouter | No | Receives only lesson metadata. Student names, grades, and all PII are stripped by our AI privacy guard before any data leaves our servers. |
| PostHog | No | Receives only anonymized teacher usage events (feature clicks, page views). Consent-gated in the EU/UK/CA per our Cookie Policy. |
| Google Analytics | No | Receives only page views and conversion events. |
| Kit | No | Receives only teacher email for transactional and marketing emails. |
| Vercel | No | Receives only HTTP request metadata. Query strings and PII are scrubbed before storage. |
Only 1 of 8 vendors stores student data
Supabase is the only sub-processor that stores student education records. All other vendors either receive no student data at all or receive only teacher-level information. For details on how we safeguard those records, see our Security and Commitments pages.
5. Sub-Sub-Processors
Our sub-processors may use their own sub-processors (e.g., Supabase uses AWS for hosting, Stripe uses banking partners for payment processing). We inherit these relationships through our contracts with each vendor. Our GDPR international transfers section explains how we ensure adequate protection for cross-border data flows.
Each vendor's privacy policy (linked in the table above) describes their own sub-processor relationships. If you have questions about a specific vendor's sub-processors, we recommend reviewing their privacy policy directly or contacting us at info@emstudio.pro.
6. Change Notification
Before adding a new sub-processor that processes personal data, we will:
- Update this page with the new vendor's details
- Provide 30 days' advance notice before the change takes effect
- Update the “Last updated” date on this page
- Record the change in our Transparency Report
If you have a DPA with us, you will receive direct email notification of any sub-processor change, with an objection period as described in the DPA.
7. Objection Rights
If you object to a new sub-processor, you may contact us at info@emstudio.pro within 30 days of the notification. We will work with you to address your concerns. If we cannot resolve the objection, you may terminate your account and receive a full export of your data as described in our Terms of Service. School administrators operating under FERPA or COPPA requirements may also reference those compliance pages for additional context.
8. Contact
For questions about our sub-processors or to be notified of changes:
Education Management Studio
d/b/a EMStudio
Email: info@emstudio.pro