Effective version: 2026-05-02
Subprocessor List
Conexion Platform — Community Intelligence LLC
Last Updated: 2026-05-02
DISCLAIMER: This document is a template and should be reviewed by qualified legal counsel before use with clients.
1. Overview
This document lists the third-party service providers ("Subprocessors") that may process Client Data on behalf of Community Intelligence LLC in connection with the Conexion platform.
Subprocessors are engaged in accordance with our Data Processing Agreement. For Clients who process Protected Health Information (PHI), we maintain signed Business Associate Agreements (BAAs) with all Subprocessors that are capable of accessing PHI in unencrypted form.
We notify Clients at least 30 days before adding a new Subprocessor.
2. Active Infrastructure Subprocessors
These providers operate the Platform infrastructure for the current production deployment.
| Provider | Service | Data Processed | Location | BAA Status |
|---|---|---|---|---|
| Google Cloud Platform | Cloud Run (compute) | All Client Data | US (multi-region, configurable) | Covered by signed Google Cloud HIPAA BAA |
| Google Cloud Platform | Cloud SQL for PostgreSQL (database) | All Client Data | US | Covered by signed Google Cloud HIPAA BAA |
| Google Cloud Platform | Cloud Storage (uploaded documents + media) | Files uploaded by Client staff | US | Covered by signed Google Cloud HIPAA BAA; bucket-level encryption with Google-managed keys |
| Google Cloud Platform | Memorystore for Redis (cache + Celery broker) | Session data, transient task payloads | US | Covered by signed Google Cloud HIPAA BAA |
| Google Cloud Platform | Secret Manager | Encryption keys, OAuth credentials, API keys | US | Covered by signed Google Cloud HIPAA BAA |
| Google Cloud Platform | Cloud Logging | Application logs (PII-redacted) | US | Covered by signed Google Cloud HIPAA BAA |
3. Active AI Processing Subprocessors
These providers process data only when Client staff initiate AI-powered features (grant writing, data analysis, chat assistant).
| Provider | Service | Data Processed | Location | BAA Status |
|---|---|---|---|---|
| Anthropic (via Google Vertex AI) | Claude family of large language models | Prompt content as composed by Client staff (may include grant text, funder information, program descriptions, and Client-selected entity context) | US | Covered by Google Cloud HIPAA BAA — all model traffic is routed through Vertex AI; the direct Anthropic API is disabled in the production environment via the AI_HIPAA_MODE setting |
Important Notes:
- Conversation history is stored in the Client's own Conexion database, not retained by the model provider beyond the API request.
- Data sent through Vertex AI is not used to train Anthropic or Google models, per Vertex AI enterprise terms.
- Tracing is configured to record metadata only (
AI_TRACE_CONTEXT="metadata_only") — full prompt content is not retained in trace logs. - Clients should still avoid pasting specific participant identifiers alongside health information into AI prompts as a defense-in-depth measure.
4. Off-Site Backup Storage
| Provider | Service | Data Processed | Location | BAA Status |
|---|---|---|---|---|
| Google Cloud Platform | Cloud Storage bucket in a separate GCP region | Encrypted database and media backups | US (different region from primary) | Covered by signed Google Cloud HIPAA BAA |
Backups are encrypted both at the application layer (GPG / AES-256 before upload) and at the storage layer (Google-managed encryption keys). The off-site region is geographically separated from the primary deployment region for disaster-recovery purposes.
5. Monitoring Subprocessors
For the current production deployment:
| Provider | Service | BAA Status | Notes |
|---|---|---|---|
| (none) | Application error tracking is disabled in this deployment | N/A | Sentry is supported by the Platform but is not enabled for PHI-bound deployments. Errors are surfaced via Cloud Logging only. |
If error tracking is enabled in the future for this Client, we will sign Sentry's BAA before activation, notify the Client at least 30 days in advance per Section 7 of the DPA, and update this list.
6. Client-Configured Integration Subprocessors
These services become Subprocessors only when the Client enables the integration. They are not active by default.
Currently active for this deployment
| Provider | Service | Data Processed | BAA Status |
|---|---|---|---|
| Google Workspace (Drive) | Document storage and retrieval | Documents the Client elects to sync to or from Google Drive | Covered under the Client's Google Workspace BAA (the Client is the Google Workspace customer) |
Available but not currently active
The following integrations are supported by the Platform but are not configured for this deployment. If the Client enables any of these in the future, we will notify the Client and update this list.
| Provider | Service | Data Categories |
|---|---|---|
| Microsoft 365 (Outlook + OneDrive/SharePoint) | Email sync, document storage | Email messages, attachments, documents |
| Gmail (Google) | Email sync | Email messages, attachments |
| Monday.com | Project and grant management sync | Grant data, program data, task data, contact names |
| Salesforce | CRM data import | Participant data, organizational data |
| Meta (Facebook/Instagram) | Page insights connector | Public engagement metrics only |
| QuickBooks Online | Financial data sync | Budget, expense, transaction data |
| Xero | Financial data sync | Budget, expense, transaction data |
7. Services NOT Used
For clarity, we do not use the following types of services:
- No advertising or marketing analytics platforms
- No social media tracking or pixels embedded in the Platform
- No customer data platforms (CDPs)
- No data brokers or enrichment services
- No cookie-consent management platforms (we use only strictly-necessary cookies)
- No third-party AI providers other than those listed in Section 3 (OpenAI and Google Gemini SDK code paths exist but are disabled in production by
AI_HIPAA_MODE)
8. Changes to This List
We will notify Clients at least 30 days before adding a new Subprocessor or before enabling a Client-Configured Integration on the Client's behalf. Clients may object to new Subprocessors per the terms of our Data Processing Agreement.
To subscribe to Subprocessor change notifications, contact: privacy@communityintelligence.io
9. Contact
For questions about our Subprocessors:
Email: privacy@communityintelligence.io