Sub-processors

Tuskerly is operated by XES Event Management, Thrissur, Kerala (the "Operator") as a data processor for each association that uses the platform. To run the service the Operator uses the sub-processors listed here. Each handles personal data only as needed for its part of the service and under written terms that protect it. See the data processing agreement.

In use

• Google Cloud (Google LLC), Belgium (europe-west1). Runs the application, holds encryption keys and secrets, runs the background job queue and scheduler, and stores security logs. Handles all data the application processes while it runs; encryption keys are wrapped by Cloud KMS.
• Neon (Databricks, Inc.), Frankfurt, Germany (AWS eu-central-1). Managed PostgreSQL database for member records, configuration and the audit log. Contact details and sensitive fields are encrypted by the application before they reach the database.
• Backblaze, Inc., United States (us-east-005). Object storage for uploaded documents and generated export files. Files are encrypted by the application with each association's own key before upload, so Backblaze holds only ciphertext and cannot read them.
• Amazon Web Services (Amazon SES), Mumbai, India (ap-south-1). Sends email to members and account security mail such as notices, reminders, receipts and password resets. Handles recipient addresses, names and the message text.
• Meta Platforms (WhatsApp Business Platform), Meta's global infrastructure; the Operator does not control the location. Sends one-time verification codes by WhatsApp so that a phone number is confirmed before it is accepted. Only the phone number and the code are sent. No other member data is shared.

Planned, not yet in use

These will be added to the list above, with notice to associations, before they process any personal data.

• Razorpay, for online membership payments, for associations that switch the Payments module on.
• MSG91 (SMS) and Meta (WhatsApp Business Cloud API), each with the association's own account, for text and WhatsApp messages from an association to its members. The verification codes above are separate.
• Google Cloud, India region, for a copy of security logs kept in India for 180 days or more, as required by CERT-In directions.

Changes to this list

The Operator will give associations 30 days' written notice before adding or replacing a sub-processor that will process personal data. An association may object on reasonable data protection grounds within that period. The parties will then try to resolve it in good faith, and if they cannot, the association may end the service as set out in the data processing agreement.

Questions

Contact hello@tuskerly.com.