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Register
Group 1: 1 listed
Each of these processes Customer Data as defined in DPA-GL-001, in the deployment models marked. Adding one, replacing one, or moving one to a different country is a change notified 30 days in advance with a right to object.
| Sub-processor | Purpose | Data categories | Location | Applies to | Status | Added |
|---|---|---|---|---|---|---|
| Google Cloud Platformcloud.google.com | Primary platform hosting: Cloud Run, Cloud SQL, Cloud Storage, Cloud KMS | All Customer Data, in the region selected for the deployment | asia-south1 (Mumbai) by default; region selectableIN | 1234 | active | 31 July 2026 |
Group 2: 3 listed
These serve trust.pensievelabs.org, the site you are reading. They hold visitor records, access requests, NDA acceptances, document instances and the addresses this Trust Center mails. They hold no patient record, no clinical document and no hospital operational data, in any deployment model. Most vendors do not publish their own trust center’s supply chain; a trust center that hides its own is not one.
| Sub-processor | Purpose | Data categories | Location | Applies to | Status | Added |
|---|---|---|---|---|---|---|
| Neon Inc.neon.tech | Managed Postgres for the Trust Center application only | Trust Center visitor, access and document-instance data | AWS ap-south-1 (Mumbai)IN | 1234 | active | 31 July 2026 |
| Resend Inc.resend.com | Transactional email: access decisions, nudges, invoices, bulletins | Name and email address of recipients | United StatesUS | 1234 | active | 31 July 2026 |
| Vercel Inc.vercel.com | Hosting for the Trust Center application only. No Customer clinical data. | Trust Center visitor and workspace data | Global edge; functions pinned to MumbaiUS | 1234 | active | 31 July 2026 |
The commitment
The mechanism is published rather than negotiated, in POL-GL-055, and the notice instrument is NTC-GL-001. A notice that does not state the objection deadline is not a valid notice, and the period runs again from a corrected one.
| Change | Notice | Objection window |
|---|---|---|
| Adding a sub-processor that will process personal data | 30 days, before | 15 days |
| Replacing a sub-processor | 30 days, before | 15 days |
| Materially extending what an existing sub-processor does | 30 days, before | 15 days |
| Moving processing to a different country | 30 days, before | 15 days, and see DIS-GL-008 |
| Emergency replacement to preserve security or availability | Immediate, notice within 3 business days | 15 days from that notice |
Silence for fifteen days is acceptance. An objection is answered by the person who made the decision, within five business days, and most objections end there because most are questions. Where no alternative can be offered within thirty days, the customer may terminate the affected service. That is the sole remedy, and it is stated here rather than discovered later.
DM-3 and DM-4
| Model | Who owns the infrastructure | Pensieve cloud sub-processors involved |
|---|---|---|
| DM-1, DM-2 | Edsol Edtech Pvt. Ltd. | The platform group above, in full |
| DM-3 | The hospital owns and pays for the cloud project | None. The cloud provider is the hospital’s own supplier, contracted directly by the hospital |
| DM-4 | The hospital owns the hardware and the room | None. There is no cloud provider at all |
Stated plainly so nobody has to work it out: a hospital on DM-3 or DM-4 has zero Pensieve cloud sub-processors in its data path. The register above still matters to it, because this Trust Center still holds its access records and its executed documents, but its patients’ records never leave infrastructure it owns.
Sources
This page is a rendering of the register, not a second copy of it. Where this page and a document disagree, the document governs.
Accept the mutual NDA to request access to this tier. Your acceptance is recorded at once and protects both sides; an administrator then grants access, with a target of four business hours.Accept the mutual NDAWait: four business hours (target)
Accept the mutual NDA to request access to this tier. Your acceptance is recorded at once and protects both sides; an administrator then grants access, with a target of four business hours.Accept the mutual NDAWait: four business hours (target)
Accept the mutual NDA to request access to this tier. Your acceptance is recorded at once and protects both sides; an administrator then grants access, with a target of four business hours.Accept the mutual NDAWait: four business hours (target)
Accept the mutual NDA to request access to this tier. Your acceptance is recorded at once and protects both sides; an administrator then grants access, with a target of four business hours.Accept the mutual NDAWait: four business hours (target)
Accept the mutual NDA to request access to this tier. Your acceptance is recorded at once and protects both sides; an administrator then grants access, with a target of four business hours.Accept the mutual NDAWait: four business hours (target)
Accept the mutual NDA to request access to this tier. Your acceptance is recorded at once and protects both sides; an administrator then grants access, with a target of four business hours.Accept the mutual NDAWait: four business hours (target)