Subprocessor List — CANOA Edu
Last updated: 6 August 2026 · Contact: privacy@canoanumis.org
A subprocessor is a third-party company that processes data on our behalf as part of running CANOA Edu. In line with our data-minimization design, this list is short — and we intend to keep it that way.
Remember what "data" means here: an anonymous LTI identifier, assignment answers, scores, and (for teachers who opted in) teacher emails. No student names or emails exist anywhere in our systems, so no subprocessor ever touches them either.
Current subprocessors
| Subprocessor | Role | Data processed | Location |
|---|---|---|---|
| REG.RU | Cloud infrastructure: virtual servers, managed database, encrypted backups | All CANOA Edu data listed above, encrypted at rest | Moscow, Russian Federation |
| REG.RU mail (canoanumis.org mailboxes) | Transactional email: teacher opt-in confirmations, pilot coordination | Teacher email addresses only; never student data | Moscow, Russian Federation |
That is the complete list. We use no external marketing platform, no third-party email delivery service, and no cloud AI provider.
For clarity, here is what we deliberately do not use on /edu/ pages: third-party analytics, advertising networks, session-recording tools, social media widgets, external font or script CDNs, marketing automation platforms, and AI services processing student submissions. Every asset on these pages is served from canoanumis.org — verifiable in your browser's network inspector in under a minute.
A note on hosting location
We state our hosting location plainly because an empty field is worse than any answer. Our infrastructure is operated in the Russian Federation. For US districts this is a factual matter for your review rather than a legal barrier — no student names or emails exist in the system to be transferred, and the data at rest is an opaque identifier attached to an answer about an ancient coin. If your district or state policy requires domestic hosting for any student-generated content, tell us at privacy@canoanumis.org before you start a review: we will say honestly whether we can meet the requirement in your timeframe rather than let you spend weeks on a vendor file that cannot be approved.
How changes work
When we add or replace a subprocessor, we will update this page and email district contacts at least 30 days before the new subprocessor touches any data. Districts may object during that window as provided in our agreement (NDPA/DPA); if we cannot resolve an objection, the district may terminate and receive deletion of its data with written confirmation, per the Data Deletion Procedure.
District contacts are subscribed to change notifications automatically upon signing; anyone else may request notifications at privacy@canoanumis.org.
Due diligence
Each subprocessor is bound by a written agreement with data-protection obligations no weaker than ours, processes data only on our instructions, and is reviewed before engagement and annually thereafter. Copies of relevant certifications or terms are available to districts on request.