Legal

Sub-processors

Version 1.0.0Drafted 2026-10-30

Last updated: 30 October 2026

Commonkeep uses a small number of service providers ("sub-processors") to run the service. Each one processes data only on our instructions, under a written contract with data-protection terms at least as strict as those in our agreement with your society (Terms, Schedule 1). We stay responsible for them.

We tell every society's admins 30 days before we add or replace a sub-processor. Your society can object on reasonable data-protection grounds; if we can't accommodate the objection, it can end the agreement without penalty.

Current sub-processors

Sub-processorWhat it does for usData involvedWhere the data is processedSafeguards
DigitalOcean, LLCHosting: application servers, database, receipt file storage and backupsAll society data: members, flats, roles, expenses, receipts, approvals, dues, payments, audit trailIndia (Bangalore): app and database · Singapore: receipt files and backupsData processing agreement; encryption at rest; access limited to named staff
Twilio Inc. (Verify)Sending one-time login codes by SMSMobile number, the code. Also the number and code typed at login or sign-up by anyone, member or not, to check the codeUnited States, delivered through local mobile networksData processing agreement; codes only, never financial details
Expo (650 Industries, Inc.), then Google (Firebase Cloud Messaging, Android) or Apple (Push Notification service, iPhone)Delivering push notifications to the mobile app. Expo passes each message to Google's or Apple's service, which delivers it to the phone. Used only when push notifications are switched on for the serviceThe phone's push token and platform. The message is content-free: a title ("Commonkeep"), one fixed sentence such as "You have 1 thing to sign.", and reference numbers (item type and id) so the app can open the right screen after sign-in. Never a vendor, amount, name, comment or receipt imageUnited StatesData processing terms with Expo; the message holds no society record
OpenRouter, Inc.Routing receipt images to the AI modelThe receipt image with location and camera data removed, the society's currency, country and category names. No names, phone numbers or flat numbers.United StatesData processing agreement; zero data retention enforced on every request; routing pinned to first-party providers only (Google Vertex AI for receipts), no reseller fallback
Google LLC (Google Cloud, Vertex AI)Reading receipts with the Gemini model: suggests amount, vendor, date and category for a person to checkAs for OpenRouterUnited StatesGoogle Cloud terms: no training on our data; zero data retention

Planned

These are not processing any data yet. They will be added to the table above, with 30 days' notice, before they start.

Sub-processorWhat it will doData involvedWhereWhen
Anthropic, PBCPreparing set-up drafts from records a treasurer drops in, after two separate confirmations (Privacy Notice §4A)The text read from the dropped files, with names and flat numbers; phone numbers replaced with placeholdersUnited StatesWhen Add your records is switched on

Not sub-processors

  • WhatsApp. Invites and reminders are prepared by Commonkeep and sent by your treasurer or committee from their own WhatsApp. Commonkeep does not send them and WhatsApp does not process data on our behalf; WhatsApp's own terms apply to those messages.
  • Your bank or UPI app. Owners pay the society directly. Commonkeep never handles money or payment credentials; it records only the reference you enter.
  • Analytics, crash reporting and advertising. We use none: no analytics, crash-reporting, tracking or advertising services in the app or on this website. In particular, Sentry is not used. The app records one first-party counter in our own database ("opened the monthly summary"); no outside company receives it.

Questions

Write to [email protected].