DPA Annex 3 — Subprocessors
Annex 3 — Subprocessors
Document ID: BRA-LEGAL-003C
Title: DPA Annex 3 — Subprocessors
Version: 1.0
Last updated: 2026-10-24
Publisher: Timecampus Technologies Pvt. Ltd. (Burdenoff Group)
Canonical location: https://burdenoff.com/contracts/brainyrich/BRA-LEGAL-003C
Burdenoff Group Contract Registry — root at https://burdenoff.com/contracts (one subgroup per product). The contracts referenced in this document belong to the BrainyRich subgroup at https://burdenoff.com/contracts/brainyrich/. Every referenced contract is identified by its Document ID (BRA-LEGAL-### / BRA-PRICING-###) and incorporated by reference.
Status: Published v1.0 — effective 2026-10-24. Reviewed against the production platform and approved for publication on 2026-10-24 under the founder's delegated legal sign-off (India jurisdiction); outside-counsel review checkpoints are tracked in BRA-LEGAL-REG.
This list was reconciled on 2026-10-24 against the vendor inventory of the running Service (production configuration of wspace-brainyrich-svc, the BrainyRich app shell and website, and the shared Burdenoff platform). BrainyRich has run on AWS-only infrastructure since 2026-08-15; Microsoft Azure was decommissioned on that date and no longer processes any Customer Data. The list matches the public disclosure at https://brainyrich.com/subprocessors. Rows marked conditional apply only when Customer, or an Authorized User, uses the relevant feature.
| Subprocessor | Service / role | Processing location(s) | Personal Data categories |
|---|---|---|---|
| Amazon Web Services, Inc. (AWS) | Cloud infrastructure — compute (Amazon EKS), databases (Amazon RDS for PostgreSQL, Amazon Neptune), cache (Amazon ElastiCache for Valkey), secrets and key management (AWS Secrets Manager, AWS KMS), object storage (Amazon S3) for documents and attachments, and frontend delivery (Amazon CloudFront) | ap-south-1 (Mumbai, India); CloudFront edge for static frontend assets | All categories under Customer Data hosted on the Service |
| Amazon Simple Email Service (SES) | Transactional email | ap-south-1 (Mumbai, India) | Email address, message content of transactional emails |
| Cloudflare, Inc. | CDN, WAF, DNS, Zero Trust | Global edge | Connection metadata, IPs, request headers; cached static assets |
| Conditional: Anthropic, PBC — Claude API (primary); OpenRouter, Inc. and OpenAI, L.L.C. (failover only) | Large-language-model inference for the AI wealth assistant, which runs on the shared Burdenoff AI-assistant runtime; content is sent only when an Authorized User invokes the assistant, and the failover providers receive it only if the primary provider is unavailable | United States (provider-managed) | Prompt content and the account, portfolio, goal or insight context the user submits to the assistant |
| Stripe, Inc. | Subscription payment processing — international (invoiced by Algoshred Technologies Corp, Delaware) | US / EU | Billing identifiers, tokenised card data (Stripe acts as PCI-DSS processor) |
| Razorpay Software Pvt. Ltd. | Subscription payment processing — India and other regional (invoiced by Timecampus Technologies Pvt. Ltd.) | India | Billing identifiers, tokenised UPI/card data |
| Conditional: Google LLC — Firebase Cloud Messaging, and Apple Inc. — Apple Push Notification service | Push notification delivery to the BrainyRich mobile apps, only on devices where the user allows notifications | Global (provider-managed) | Device push token, notification title and body |
| Rybbit (managed cloud, rybbit.com) | Product and website analytics; sets no cookies and uses no local storage | European Union | Page views and product events with anonymous session identifiers |
| Apache Answer (self-hosted by Timecampus) | Support community at community.brainyrich.com (open-source, operated by us) | India | Community profile and post content |
| Timecampus-operated support tooling | In-house ticketing and customer success — no third-party SaaS support desk | India | Support content |
| GitHub, Inc. | Source-code hosting (Timecampus internal); also referenced by Customer integrations | US | Issue/ticket metadata where Customer engages support via GitHub |
| Linear (Linear Orbit, Inc.) | Internal project tracking | US | Support ticket metadata if Customer escalates |
| Google Workspace (Google LLC) | Internal team collaboration only — email, calendar, docs used by Burdenoff Group personnel for internal operations. Customer Data is not stored in Google Workspace as part of the Service. | US / EU (Google managed) | Internal operational data only |
| Burdenoff Consultancy Services Private Limited | Manpower house — provides engineering, support, security and operations personnel that deliver the Service on Timecampus's behalf (see DPA §1.4) | India | All categories, on Timecampus's instructions |
| Algoshred Technologies Corp (Delaware, USA; EIN 35-2845680) | Burdenoff Group affiliate that invoices international customers via Stripe | USA | Billing identifiers for international invoicing |
Notes
- No account-aggregation provider is engaged. The Service can link brokerage and bank accounts through Plaid, but that integration is not enabled for the production Service today; accounts, holdings and transactions are entered or imported by Customer. Enabling Plaid, an India Account Aggregator or any other aggregation provider is a Subprocessor addition and will be notified under DPA §6 at least 30 days in advance.
- Market and FX data. Security quotes and currency rates are fetched from public market-data and exchange-rate endpoints (Yahoo Finance chart data and open.er-api.com). Only instrument symbols and currency codes are sent; no Personal Data or Customer Data leaves the Service on these calls, so these sources are not Subprocessors.
- No SMS provider and no KYC or identity-verification provider is engaged. BrainyRich does not send SMS and does not run KYC checks. If either is introduced, the provider will be added here and notified under DPA §6 before it processes any Customer Data.
- AI providers. The AI wealth assistant uses Anthropic's Claude API by default and fails over to OpenRouter or OpenAI only when Anthropic is unavailable; all three are used under their commercial API terms, and Timecampus does not opt in to any provider programme that trains on submitted content. The BrainyRich service's own narrative risk summaries can also route to Google's Gemini API, OpenAI or Anthropic, but no provider key is configured for that feature in production today, so it sends nothing. Enabling it, or adding any other model provider, is a Subprocessor addition and will be notified under DPA §6 at least 30 days in advance. Where an Order Form enables a customer-selected ("bring-your-own-key") provider, that provider is Customer's own vendor and is not a Timecampus Subprocessor.
- No marketplace payouts or escrow. The services marketplace described in BRA-LEGAL-011 is not live. Stripe and Razorpay process subscription payments only; Timecampus holds no client funds and executes no trades.
- Customer-contracted integrations (the Customer's own custodian or brokerage feed, aggregator, accounting system, identity provider, or a verification provider the Customer engages directly) are not Timecampus Subprocessors; Customer is responsible for those relationships and their data-processing terms.
- For Enterprise / dedicated tenant deployments, the Subprocessor list may be narrowed in the Order Form (e.g., AWS ap-south-1 only, AI features disabled).
- The authoritative live list is published at https://brainyrich.com/subprocessors and changes are notified per DPA §6.
Last reviewed: 2026-10-24 (reconciled against the production vendor inventory)
Reference and incorporation
All Burdenoff Group contracts, addenda, exhibits, policies and registers referenced in this document are identified by their Document ID (BRA-LEGAL-### or BRA-PRICING-###) and are published at https://burdenoff.com/contracts. Each such referenced document is incorporated into this document by reference. The version of a referenced document that applies is the version published at https://burdenoff.com/contracts as at the Effective Date of the applicable Order Form (or, where no Order Form exists, the version current at the date of acceptance), unless an executed Order Form specifies a frozen version.