Subprocessors
Effective date: September 1, 2026 · Version 2026-09-01
PALDAM LLC uses the providers below to operate CivicRecordsOnline. A "subprocessor" is a provider that may process Agency Data on PALDAM's behalf. The table is a transparency notice, not a promise that every provider processes every category for every agency. Provider locations describe the principal service configuration known to PALDAM; network routing, support, security, and provider operations may involve other locations under applicable contracts.
| Provider | Purpose | Information involved | Processing location |
|---|---|---|---|
| Microsoft Azure | Application hosting, Azure SQL, blob storage, secrets, logs, monitoring, backups, and related cloud infrastructure. | Agency and staff account data; requester and request data; documents and images; release copies; audit and application logs. | United States configuration; limited support or network processing may occur elsewhere under Microsoft's terms. |
| Twilio SendGrid | Transactional email delivery and delivery-event webhooks. | Sender and recipient addresses; message content and metadata; delivery, bounce, and complaint events. | United States service configuration; provider operations may be global. |
| Stripe | CivicRecordsOnline subscription checkout, invoices, billing portal, and payment-status events. | Agency billing contact; subscription, invoice, and payment-status metadata; provider customer identifiers. PALDAM does not store full card numbers. | United States; provider operations may be global. |
| Cloudflare | DNS, edge routing, availability and security controls for public domains and tenant portals. | IP address, hostname, request metadata, timestamps, routing data, security events, and Service traffic handled in transit. Agency Records remain stored in Azure and are not intentionally cached at the edge. | Global network; account and log handling under Cloudflare's terms and PALDAM's configuration. |
| Google Analytics 4 / Google Ads | Analytics and advertising conversion measurement on the public marketing website and on the account sign-up and setup pages. | Marketing-site and sign-up-page usage, browser/device data, referral and campaign data, approximate IP-derived location, and advertising click identifiers. Never Agency Records; never requester portals or pages that display Agency Records. | United States and other locations under Google's terms. |
| Google Workspace | Business email and mailbox hosting for messages sent to PALDAM addresses, including legal, privacy, accessibility, security, and support correspondence. | Sender and recipient details, message content, attachments, and mailbox metadata supplied through email. | United States and other locations under Google's terms. |
Scope and provider responsibility
PALDAM requires providers to process information only for contracted services and to maintain protections appropriate to their role. Each provider operates its own service and remains responsible for its infrastructure and legal obligations. PALDAM's use of a provider does not make PALDAM responsible for matters outside PALDAM's reasonable control, subject to applicable law and the Terms of Service.
Changes and objections
PALDAM may add, replace, or remove providers as the Service changes. We will update this page before a new provider begins materially different processing of Agency Data when reasonably practicable. An Agency with a documented legal objection may email legal@civicrecordsonline.com within 15 days after notice. The parties will discuss reasonable alternatives, but PALDAM is not required to operate the Service without a provider necessary for security, reliability, or core functionality. If no reasonable alternative is available, the Agency may cancel before the provider's materially different processing begins; that cancellation is the Agency's exclusive remedy for the change, except where applicable law requires otherwise.
Questions
Security and procurement questions: security@civicrecordsonline.com. Privacy questions: privacy@civicrecordsonline.com.