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TPA Ventures

Legal

Subprocessors

Third parties that process customer data on TPA Ventures' behalf, what they process and where.

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How we choose subprocessors

We use the smallest set of providers needed to run the service. Each is reviewed for security, bound by written data protection terms at least as protective as our customer agreements, and limited to U.S. data locations for any student data.

Amazon Web Services (infrastructure)

Purpose: application hosting, databases, file storage, backups and encryption key management. Data: all customer data, including student data. Location: United States (us-east-1, with disaster recovery in us-west-2).

Amazon Bedrock (AI model hosting)

Purpose: hosted large language model inference for drafting PLAAFPs, goals and prior written notices. Data: the student data needed for each drafting request. Location: United States AWS regions. Inputs and outputs are not used to train models and are not retained by the model provider.

Cloudflare (network security)

Purpose: DNS, TLS termination, web application firewall and DDoS protection. Data: encrypted traffic in transit and request metadata such as IP addresses. Location: global edge network; no student data is stored by Cloudflare.

Twilio SendGrid (email delivery)

Purpose: account and timeline notification emails to School staff. Data: staff names and email addresses, and notification text that refers to students by internal reference rather than name. Location: United States.

Datadog (monitoring)

Purpose: application performance monitoring and logging. Data: system logs and metrics. Student identifiers and document content are scrubbed before logs leave our environment. Location: United States (US1 region).

Zendesk (customer support)

Purpose: support ticketing for School staff. Data: staff contact details and ticket content. Our support policy prohibits student data in tickets, and support staff redact any that is submitted. Location: United States.

Okta (workforce identity)

Purpose: single sign-on and multi-factor authentication for TPA Ventures employees accessing internal systems. Data: TPA Ventures employee identities only. Location: United States.

Changes and notice

We give School administrators at least 30 days' notice before adding a subprocessor that processes student data. Schools may object in writing to privacy@tpaventures.si; if we cannot address the objection, the School may terminate the affected service with a prorated refund.