Subprocessors

Effective: September 28, 2026 · Version 1.5

This page lists the third-party service providers ("Subprocessors") that PrepIEP uses to deliver the Service. PrepIEP is a product of Kova Systems LLC, a Massachusetts limited liability company ("Kova Systems," "we," "our," or "us"). This page is incorporated by reference into our Privacy Policy and is the authoritative version of the list. We update this page whenever we add, remove, or materially change a subprocessor.

AI processing for parent-directed use. PrepIEP does not train or fine-tune models on customer content. AI requests use Google Cloud Vertex AI through U.S. endpoints as of October 7, 2026. Google’s separate safety-monitoring and retention terms apply; this is not a zero-retention promise. See Privacy Policy §3 for processing details and §4 for supported family use.

1. Current subprocessors

1.1 Google Firebase

• Provider: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
• Purpose: User authentication (Firebase Auth, Google Sign-In, Sign in with Apple), document storage (Cloud Storage for Firebase), database (Cloud Firestore), serverless backend (Cloud Functions for Firebase), web and mobile hosting (Firebase Hosting), client integrity (Firebase App Check).
• Data processed: Account credentials, uploaded education records (IEPs, evaluations, related correspondence), extracted structured data, chat history, AI inputs and outputs, billing identifiers, device-and-connection metadata, security and audit logs, and a first-party product-funnel ledger containing an opaque account identifier and limited milestone metadata.
• Region: Primary data stores: United States (Firestore nam5; Cloud Functions us-central1; Cloud Storage us). Authentication, delivery, and vendor operational processing follow the provider’s terms; this is not a blanket United States-only processing promise.
• Encryption: AES-256 at rest; TLS 1.2+ in transit.
• Retention: Per Privacy Policy §7. Meeting workspaces, documents, and extracted education data: account lifetime, including after an ordinary subscription cancellation returns the account to the Free tier, unless the user deletes the account or content. Refund, dispute, fraud-prevention, and legal-hold circumstances may require different retention or deletion. Chat history and AI defensive records: 90 days. Account metadata and account-level product-funnel rows: account lifetime, with deletion initiated when the user deletes the account. Completed minimal deletion receipts remain 90 days; production database and storage recovery copies expire over seven-day windows. Minimal billing-cleanup records contain account/provider identifiers and retry state, no education text or email address; unresolved manual-recovery records remain until resolved. Ordinary Cloud logs: 30 days; required audit logs: 400 days. See Privacy Policy §7 for deletion and retry details.
• No-AI-training mechanism: Standing terms — Google Cloud Platform's data-processing terms forbid use of customer data for training Google's models.
• Security certifications: SOC 2 Type II, ISO 27001, ISO 27017, ISO 27018, ISO 27701. See Firebase Privacy and Security.

1.2 Google Cloud Vertex AI — Gemini models

• Provider: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. (Service: Vertex AI, authenticated by our server identities.)
• Purpose: Large-language-model inference for document extraction, advisor chat, suggested goals, suggested requests, suggested rights questions, and meeting agenda generation.
• Data processed: Document content, prompts, prompt-template wrapping, model responses. Sent over TLS 1.2+ directly to Google Cloud Vertex AI endpoints. Persisted on PrepIEP-controlled infrastructure (see §1.1) after the response is returned.
• Region: U.S. endpoints: us-central1 for Gemini 2.5 and embeddings; us multi-region for Gemini 3.8.
• Retention by Google (the inference provider): Google may retain safety and abuse-monitoring logs. Default in-memory caching has a 24-hour limit. PrepIEP does not promise zero retention by Google. See Privacy Policy §3 before uploading any real record.
• AI data use: Google’s Cloud terms prohibit using customer data for training or fine-tuning without permission or instruction. PrepIEP does not grant that permission. See Google Cloud AI data use and retention.

1.3 Stripe

• Provider: Stripe, Inc., 354 Oyster Point Boulevard, South San Francisco, CA 94080, USA.
• Purpose: Subscription billing for the paid plans, payment-card processing, invoicing, refund issuance, dispute management, customer-portal cancellation flow.
• Data processed: Cardholder name, card number (held by Stripe; never seen by PrepIEP), card brand, last-four card digits, billing postal code, billing email, charge IDs, invoice metadata, subscription state, refund records, dispute records.
• Region: United States.
• Retention: Stripe retains billing records on its own systems independently. PrepIEP retains the non-card billing metadata it receives back from Stripe for 7 years (U.S. tax recordkeeping).
• No-AI-training mechanism: Stripe does not provide an AI service to PrepIEP, so no AI-training risk is in scope. Stripe's own use of payment data is governed by its Privacy Policy and its Data Processing Agreement.
• Security certifications: PCI DSS Level 1, SOC 2 Type II, ISO 27001.

1.4 Sentry — bounded backend diagnostics

Backend Sentry error reporting is configured across our deployed functions. Server and client implementations permit only bounded diagnostic fields and remove document content, free-form errors, breadcrumbs, user context, and request details. Tracing and profiling are disabled. Configuration does not prove event delivery: end-to-end transport, alert routing, and the account’s region, retention, and contractual settings remain unverified. Client configuration can differ from the backend; we do not claim verified client delivery or a verified Sentry retention period.

1.5 Google Analytics

• Provider: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
• Purpose: Consented aggregate analytics for public-site usage and content performance, on approved public routes. Authenticated product-funnel measurement remains in PrepIEP's first-party Firebase ledger and is not sent to Google Analytics.
• Data processed: Public-page path, referrer, basic device/browser metadata, coarse geography, and public-site interaction event names and parameters. Path exclusions: PrepIEP initializes Google Analytics only on public marketing, help, blog, state-resource, legal, and subprocessor pages. It does not emit page views or custom events on authenticated app routes that can display IEP content, including /understand, /documents, /build, /build/requests, /requests, /requests/wording, /goals, /track, /pack, /account, and /admin.
• Region: United States / European Union, depending on Google's processing and transfer controls for Google Analytics.
• Retention: The deployed Google Analytics property’s event-retention and enhanced-measurement settings require owner verification. They are not established by the client code.
• Consent controls: Analytics loads only after opt-in on approved public routes. Advertising storage and signals stay disabled. Global Privacy Control is treated as rejection. Automatic page views are disabled in code; provider-console settings also need verification.
• No-AI-training mechanism: Google Analytics is not an AI inference service for PrepIEP. Google's Google Ads Data Processing Terms and Google Analytics service terms govern processing for analytics and advertising integration.

1.6 Google Workspace Gmail — optional reminder delivery

• Provider: Google LLC. This uses our existing Google Workspace mailbox.
• Purpose: Send optional reminders to parents who enable email alerts.
• Data processed: The verified recipient email address, generic reminder categories, an application sign-in link, an opaque unsubscribe link, and delivery metadata. Messages exclude student names, education-document content, saved questions, and school-response notes.
• Security and retention: Authenticated TLS mail delivery. Google Workspace and recipient mail providers process and retain delivered mail according to their applicable terms and account settings. PrepIEP's minimal server delivery receipts expire after 90 days and are removed asynchronously; they do not contain email addresses or message text.
• Control: Email alerts default to off. Parents can disable them in Notifications or through the email's unsubscribe link.

2. What we use, but is not a subprocessor

The Service is hosted on Firebase Hosting (§1.1) and is delivered to your browser through Cloudflare's anycast network for static assets. Cloudflare is a transit-only edge provider for our static HTML, CSS, JavaScript, and font assets; it does not store user-uploaded content or persistent personal information on our behalf, so we do not list it as a subprocessor.

The Apple Sign-In and Google Sign-In identity providers are authentication providers. They send PrepIEP a name, email, and stable user identifier when you choose to sign in through them. They are not subprocessors because PrepIEP does not direct them to process data on its behalf — you instruct them to send their identity assertion to PrepIEP. Their handling of your data is governed by their own privacy policies.

3. Notification of changes

We will give at least 30 days' advance notice on this page and via in-app notice before adding a new subprocessor that will process user-uploaded education records or AI-related content. We will give shorter or no advance notice for emergency replacements (for example, replacing a subprocessor whose service is unexpectedly discontinued), but we will document any such emergency replacement here within 7 days after it takes effect.

Removal of a subprocessor (for example, retiring an analytics provider) is announced here at the time the change takes effect.

4. Versioning

This page is versioned in the same way as our Privacy Policy and Terms of Service. Prior versions are available on request by emailing contact@prepiep.com.

5. Contact

Questions about subprocessors:

• Privacy contact: contact@prepiep.com

Effective: September 28, 2026 · Version 1.5.