Registration of sub-commissioned officers

Last update: 7 October 2026
Version: 2.0
To whom it applies: Drometra customers and anyone who wants to audit the treatment chain

In summary

We publish the full list, we do not deliver it "on request": a treatment chain that cannot be seen cannot be audited.
Today there are two active subprocessors with platform data: Contabo, which hosts the server in France, and Cloudflare, which provides the network, tunnel, and storage for encrypted backups.
The language model providers (OpenAI and Anthropic, directly or via OpenRouter) and the email provider (Resend) are conditional: they only receive data when the feature is enabled.
Identity, geocoding, route calculation, and monitoring run on our own servers and do not involve third parties.
We warn 30 days before we incorporate a new one, and the client can object to it with a foundation.

This summary guides the reading and does not replace the text of the document.

01Why is this list public?

The widespread practice in the industry is to state that a subprocessor list exists and provide it only to those who request it in writing. We consider that an inadequate response: anyone evaluating a purchase needs to know the chain before signing, and the data subject —a driver, a recipient— will never be in a position to request it.

Publishing it has a cost: it forces us to keep it up to date and it exposes our architectural decisions. We assume it because the alternative is to ask for confidence without giving the means to verify it.

02Infrastructure and operation of the platform

Supplier	Function	Data that it reaches	Processing location	State
Contabo GmbH (Germany)	Servers running the application, the database, user identity, and map services	The whole of the platform data	France (European Union)	Active
Cloudflare, Inc. (United States)	DNS, delivery network, attack protection, server access tunnel, and access control	IP addresses and connection metadata; traffic passes through its network	Global network, at the nearest point of presence	Active
Cloudflare, Inc. — R2	Storage of database backups and public base maps	Backups encrypted on our server before uploading; Cloudflare does not have the key. The maps contain no personal data	Cloudflare network; no fixed region	Active
OpenRouter, Inc. (United States)	Routing of language model calls for Michiva	Written question and facts with license plates and names masked	United States	Conditional: only with the Michiva model layer enabled
OpenAI, L.L.C. and Anthropic, PBC (United States)	Language models for Michiva, via API, directly or through OpenRouter	The same masked data; no training and zero retention when the model offers it	United States	Conditional: only with the Michiva model layer enabled
Meta Platforms — WhatsApp Business	Sending Michiva's messages to delivery recipients	Recipient's name and phone number, estimated arrival window and tracking link	United States and other regions	Planned, not active: only if the customer turns on WhatsApp messages, with 30 days' notice
Resend, Inc. (United States)	Transactional email: alerts and notifications	Email address and content	United States	Ready, not active in production
Esri, Inc. (United States)	High-resolution satellite imagery on the console map	The user's IP address and the map area they are viewing; the browser requests the images directly. It does not receive fleet data	United States	Conditional: only if the customer enables high-resolution imagery
Bsale (Chile)	Integration with the customer's management system	Customers, contacts, and documents that the customer itself syncs	Chile	Conditional: only if the customer connects their account

A «conditional» provider receives no data while the corresponding feature is disabled. Enabling it for your company is an express decision, and we inform you beforehand which provider and which model will be in use.

03Services we operate ourselves

These components process personal data, but they run on our own servers and are not subprocessors:

Identity and access: Keycloak, with the second authentication factor.
Geocoding: Nominatim, with OpenStreetMap data for Chile.
Route calculation: OSRM.
Database: PostgreSQL with PostGIS.
Technical monitoring: metrics and alerts on a second Contabo server, with no customer identifiers.

For source code we use GitHub, Inc. (United States). No customer data is stored there: development and testing work with synthetic data.

04Corporate systems

These suppliers do not access fleet data. They treat commercial contact and administration data, for which Drometra is responsible.

Supplier	Function	Data that it reaches	Country of treatment
Electronic billing provider	Issuance of tax documents	Social reason, Rut, amount, document detail	Chile
Accounting and legal advice	Accounting, taxation and legal defence	What is necessary for the commission, under professional secrecy	Chile

Today we do not use web analytics, CRM, or advertising tools, nor a payment processor. If we add any, it will appear in this register before receiving data.

05What do we demand of each

Contract or data processing agreement setting out the subject matter, duration, purpose, type of data, and categories of data subjects.
Prohibition of processing data for different purposes and of giving them away without authorization.
For model providers, a prohibition on training with the data and, where the model offers it, zero retention.
Security measures equivalent to ours, verifiable.
Notification of incidents within a time limit that allows us to meet our client.
Deletion or return of the data at the end of the order.

With large-scale infrastructure providers we do not negotiate custom contracts: we accept their standard data processing agreement. We review it before contracting and state it here so it is not read as a negotiated contract.

Ley 21.719 · Article 15a

The person responsible may not delegate the order unless the person responsible expressly and in writing has been authorised. If he / she delegates, he / she maintains joint responsibility for the treatment of the third party.

Official text of the rule

06Changes to the list

1.We publish the change on this page at least 30 days in advance and notify affected customers by email.
2.During that period, the client may object in writing, indicating the basis.
3.If the objection is reasonable, we seek a technical alternative; if there is no objection, the client can finish the affected service without penalty or cost of departure.
4.An emergency replacement for the fall of a supplier is communicated within 72 hours, with the same option of a posteriori objection.

Status of this document

Text prepared by Drometra and pending review by external legal advice before its final publication. Its structure and content were built on the current Chilean legislation and on Law 21.719, which has been in force since 1 December 2026. It does not constitute legal advice for third parties.