Sub-processors
Last updated [effective date]
This is a draft pending legal review. It was written to describe how Chumbaq works today and has not yet been checked by a lawyer.
A sub-processor is a company Chumbaq uses to process personal data while running our cloud service. Under our data processing agreement, each one is bound by a written contract with data protection duties, and we stay responsible to you for their work.
Self-hosted installations of Chumbaq use none of these.
1. Current sub-processors
| Provider | What we use it for | What data it gets | Where |
|---|---|---|---|
| [hosting provider] | Servers, database, queues and backups for the cloud service | All data in the service: your account data and your app users' data | [hosting region] |
| Brevo | Chumbaq's own account email to you: email verification, password reset and security notices. Not your campaigns. | Your name and email address, and the content of the email | [Brevo data location] |
| Stadia Maps | Map images on the dashboard's analytics page | The IP address of the person viewing the dashboard, sent by their browser when the map loads. No app user data. | [Stadia Maps data location] |
| [payment processor] | Card payments and invoices | Billing contact and payment details | [payment processor region] |
2. Providers you connect with your own account
Chumbaq does not send your messages from accounts of its own. To send push, email, SMS or WhatsApp messages, or to import Mixpanel cohorts, you connect your own account with that provider in your project's settings. The credentials belong to your project, are stored encrypted, and are used only for that project.
These providers are not Chumbaq's sub-processors. You choose them, you have the contract with them, and they act for you. When you send a message, we pass them what that message needs, such as a push token, an email address or a phone number, and the message itself. Their own terms and privacy commitments apply. If you never connect one, it receives nothing through Chumbaq.
| Channel | Providers you can connect |
|---|---|
| Push notifications | Firebase Cloud Messaging (Google), Apple Push Notification service, Xiaomi Mi Push |
| Amazon SES, Resend, Brevo | |
| SMS | Twilio |
| Meta WhatsApp Cloud API, Twilio, Gupshup, Interakt | |
| Analytics cohorts | Mixpanel (we import cohort members from your Mixpanel project) |
Webhooks work the same way: if you add a webhook, we send event data to the address you choose, which is yours to control.
3. How we tell you about changes
We will email the owner of every account at least [number of days] days before we add or replace a sub-processor, and update this page and its date at the same time.
You can object within that period, on reasonable data protection grounds, by emailing [contact email for objections]. The DPA explains what happens next.
Who we are
Chumbaq is built and operated by Qleverlabs Technologies Inc (USA) and Qleverlabs Technologies Pvt Ltd (India). Registered addresses: [registered address of Qleverlabs Technologies Pvt Ltd] and [registered address of Qleverlabs Technologies Inc].