Subprocessor List
Version 1.0 · Effective May 6, 2026 · Last Updated November 1, 2026
ABOUT THIS LIST
NurseKind AI, LLC ("NurseKind") acts as a Business Associate, not a Covered Entity, and uses the subprocessors below to deliver its clinical communication platform. This list covers every entity that may process personal data, FERPA-covered education records, or Protected Health Information ("PHI") on NurseKind's behalf. Regulatory basis: GDPR Art. 28(2); FERPA; HIPAA transparency best practices.
Institutional customers that have executed a Business Associate Agreement ("BAA") with NurseKind may request the full vendor-facing BAA register and copies of executed BAAs or DPAs by contacting hi@nursekindai.com.
SUBPROCESSORS
| Subprocessor | Service Provided | Data Types Processed | Country | HIPAA BAA | GDPR DPA / SCCs |
|---|---|---|---|---|---|
| Google Cloud Platform (Firebase Cloud Functions, Cloud SQL PostgreSQL 17, Vertex AI, Cloud Memorystore, Cloud Logging, Cloud Storage, Secret Manager, Cloud KMS) |
Core infrastructure, AI inference, audit logging, encryption key management | PHI (encrypted at rest); FERPA education records; operational logs; faculty-uploaded encounter video and, for assignments that ask for it, a student's own video (faces and the unredacted audio track), analyzed by Vertex AI Gemini and deleted when the analysis finishes; questions typed into the faculty help chat (free text, cleaned of email addresses, links and long numbers before use), which Vertex AI Gemini reads only to choose one prewritten answer | United States (us-central1; Vertex AI Gemini runs in the Google Cloud US multi-region, processing stays within the United States) | BAA executed | Google DPA / SCCs in place |
| Firebase Authentication (Google Identity Platform) |
User authentication and identity management | Authentication PII (email address, Firebase UID) | Google-managed, multi-region — not pinned to us-central1 like the rest of the GCP footprint | BAA executed (same Google Cloud BAA) |
Google DPA / SCCs in place |
| AssemblyAI | Audio transcription of clinical assessment recordings | PHI — audio recordings and transcripts from the Clinical Recording & Assessment feature | United States | BAA executed | Standard Contractual Clauses available |
| OpenAI (Realtime API) | Voice simulation interactions (AI Patient Practice Sessions, synthetic scenarios only) | The student's voice audio and the spoken conversation (transcript) during a practice session, plus the fictional scenario. Practice is designed for fictional scenarios only; students are instructed not to say or type real patient information, and OpenAI is not used for Clinical Recording & Assessment | United States | None. Not used for PHI; Practice is for fictional patients only | OpenAI DPA executed |
| Canvas LMS / Instructure | FERPA roster import via the Canvas API (the LTI 1.3 launch is a separate connection between your Institution's LMS and NurseKind) | FERPA education records (student roster, course enrollment) — no PHI | United States | No BAA required (FERPA scope only) | Instructure DPA |
| Brightspace / D2L | Read-only course, class list and assignment import through the Brightspace (Valence) API, using the faculty member's own sign-in consent; LTI 1.3 launch, grade return and class-list reads between your Institution's Brightspace and NurseKind | FERPA education records (course, class list names and emails, assignment data, scores returned to the gradebook) — no PHI | The region of your Institution's own Brightspace | No BAA required (FERPA scope only) | Your Institution's own D2L agreement |
| Hostinger | Transactional email for FERPA-scope notifications, and new-ticket notices from the faculty help chat to NurseKind's own support inbox | FERPA-scope contact email — no PHI. Help-chat ticket notices carry only a ticket number, category, school name, role and page, plus the sender's address as the reply-to header; never the message | European Union (Lithuania) | No BAA required (no PHI hosted or processed) | Hostinger DPA / GDPR-compliant |
| Cloudflare | Static website hosting (nursekindai.com), CDN, DDoS protection, TLS termination | Static web assets only — no PHI cached or processed at the CDN/hosting layer | United States / Global edge | No BAA required (no PHI in CDN/hosting layer) | Cloudflare DPA |
| Telegram | Operational alerting (uptime notifications, system alerts) | Operational metadata only — no PHI included in alert payloads. Help-chat ticket alerts carry a ticket number, category, school name, role and page; never the message, a person's name or an email address | International | No BAA required (no PHI transmitted) | N/A |
NOTES ON PHI SCOPE
- Google Cloud Platform is the primary infrastructure provider, covered by an executed Google Cloud HIPAA BAA. All PHI stored in Cloud SQL is encrypted at the column level using AES-256-GCM. Cloud Logging receives only redacted logs after PHI-sanitization middleware is applied.
- Firebase Authentication is a Google-managed service covered by the same executed Google Cloud BAA and Google DPA/SCCs as the rest of the GCP footprint, but unlike Cloud SQL and Cloud Functions it is not pinned to a single region — authentication PII (email address, Firebase UID) is not controlled to us-central1.
- AssemblyAI processes audio that may contain PHI as part of the Clinical Recording & Assessment feature. An AssemblyAI BAA is in effect. Audio is deleted by AssemblyAI after transcription per BAA terms.
- OpenAI Realtime API is restricted to synthetic AI Patient Practice Sessions scenarios. NurseKind's operational policy prohibits entering real patient data (ePHI) into it. The Platform blocks any scenario not flagged as fictional and educational from starting a session, and students are told not to say or type real patient information, but it does not inspect what is said aloud. OpenAI is not covered by a Business Associate Agreement and is not used for Clinical Recording & Assessment.
- Canvas LMS / Instructure integration is FERPA-scoped only. No PHI flows through the Canvas or LTI integrations. The Canvas integration imports course rosters for access provisioning; the LTI launch carries LMS identifiers and, if your Institution later enables grade passback, would send scores to that LMS.
- Brightspace / D2L integration is FERPA-scoped only. No PHI flows through it. It is off for every Institution until NurseKind turns it on at the Institution's request. The Brightspace import reads course, class list and assignment data with the signing-in faculty member's own consent; that sign-in token is stored encrypted and is short-lived. Brightspace launch and grade return use the same LTI 1.3 connection and consent checks as Canvas.
- Moodle, Schoology and Blackboard connect to NurseKind through LTI 1.3 only: a connection between your Institution's own LMS and NurseKind, carrying LMS identifiers, names, roles, class lists and scores. They are not NurseKind subprocessors, the integration is FERPA-scoped, and no PHI flows through it. Your Institution configures it with NurseKind and can turn it off at any time.
- Hostinger provides transactional email only. NurseKind does not route PHI-bearing traffic through Hostinger. Email is limited to FERPA-scope notifications, plus content-free ticket notices to NurseKind's own support inbox (the message a faculty member types into the help chat stays in the database and is read only in the staff dashboard). A software gate blocks any PHI-bearing email until an appropriate BAA is in place. Assessment PDFs are delivered in-app only.
- Cloudflare hosts the static website (nursekindai.com) in addition to providing CDN, DDoS protection, and TLS termination. NurseKind does not route PHI-bearing traffic through Cloudflare; the static site serves only public marketing and unauthenticated content.
- The faculty help chat stores the questions and tickets that faculty and faculty admin accounts type, for twelve months, in Cloud SQL under the Google Cloud BAA. We tell people not to include student or patient names, but free text can contain them, so it is handled as education-record data: access is limited to the person who wrote it and NurseKind support staff, staff reads are logged, and the text is deleted with the account or the school. The model that picks an answer (Vertex AI Gemini) sees the cleaned question only and cannot write anything the person sees.
UPDATE NOTIFICATION POLICY
NurseKind AI will provide 30 days' advance notice before adding any new subprocessor that will materially change the processing of PHI or FERPA-covered education records. Notice will be provided to institutional customers via:
- Email notification to the institution's designated privacy contact
- An update to this public disclosure page
Institutions that object to a proposed new subprocessor should contact NurseKind AI at hi@nursekindai.com within 14 days of receiving notice.
REQUESTING ADDITIONAL INFORMATION
Institutional customers may request:
- The full vendor-facing BAA register (internal, non-public)
- Copies of executed BAAs or DPAs for any listed subprocessor
- Data flow diagrams specific to their institution's deployment
Contact: hi@nursekindai.com.