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Compliance & Security

Sub-Processor Registry

Current truthRōvn master canon generation 8 · effective 2026-07-21. Earlier dated diligence documents are historical snapshots, not current deployment proof.Ask the canon-grounded agent →
AI Diligence Console

Sub-Processor Registry

Reviewed: 2026-07-22 · Canon: generation 8, effective 2026-07-21 · Purpose: the customer-facing disclosure register that attaches to the BAA flow-down. Because the deployed environment carries synthetic data only, the PHI columns below describe gated exposure, not current processing.


1. Current processing vendors (deployed, synthetic environment)

VendorPurposeData todayLocation
Google CloudCloud Run compute, Cloud SQL database, storage, Secret Manager, Vertex AI (investor-room agent)Synthetic corpus, application data, diligence contentUnited States
CloudflareDNS and selected public or static deliveryPublic content onlyGlobal edge
GitHubSource code hosting and CISource code, no PHIUnited States

2. PHI-contingent vendors (gated behind real-data activation)

These vendor classes process regulated data only after the real-data gates pass and the applicable agreement is executed. Execution status is stated only with the signed document on file.

Vendor classPurposeData if activatedGate
Cloud provider (Google Cloud)PHI storage and computePHI at rest and in transitCloud BAA on HIPAA-covered services
AI model providersExtraction, drafting, agent workflowsMinimized credential metadataProvider BAA plus the 06.5 configuration, minimization, and logging gates
Identity verificationGovernment-ID identity proofingIdentity documents, PIIBAA or equivalent before real workers onboard
Background screeningBackground checks where requiredPII and screening dataBAA plus counsel review of the FCRA workflow
Enterprise SSOCustomer SSO federationOrganization user identityContract review; BAA if scope includes PHI
Communications (email, SMS)Workflow notificationsContact details; PHI excluded by designBAA before any PHI-bearing content
Error trackingApplication faultsScrubbed frames onlyScrub verification as a real-data gate
BillingInvoicingBilling metadata only, never PHINo BAA required by design

3. Source authorities (not sub-processors)

Primary sources and registries (practitioner data banks, licensure systems, exclusion lists, certification boards) are verification destinations, not processors of customer data on Rōvn's behalf. Rōvn queries them under their own terms, preserves the response as a Source Receipt, and labels the evidence class accordingly.

  • Adapter states vary: registered, contract-ready, sandbox, and live transport-proven are different states.
  • A source is described as live only with contract, credentials, allowed-use review, and current transport proof.
  • Where automation is not live, manual primary source verification is the documented fallback.

4. Customer disclosure language (template)

Rōvn engages the sub-processors disclosed in this register to perform services on the customer's behalf. Rōvn maintains a Business Associate Agreement or equivalent with each PHI-touching sub-processor before PHI reaches it. The customer may raise objections to specific sub-processors, subject to feasibility, via legal@rovn.to.

Rōvn provides 30 days' advance notice of material changes to this register: addition of a PHI-touching sub-processor, a change in jurisdiction, or termination of a vendor agreement.


5. Review cadence

The register is reviewed quarterly with outside counsel. Changes are logged in the audit ledger, communicated per the disclosure language above, and reflected in the vendor BAA matrix (06.4) and the flow-down narrative (08.11).

End of sub-processor registry.

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