International data transfers
- Last update
- 7 October 2026
- Watch from
- 1 December 2026
- Version
- 2.0
- To whom it applies
- Customers and data subjects whose data is processed outside Chile
In summary
- The platform is not hosted in Chile: the main server is in France, in the European Union. All platform data is therefore transferred outside the country.
- Cloudflare, in the United States and across its global network, processes traffic and stores encrypted backups that it cannot read.
- When Michiva uses a language model, the question and masked facts are processed in the United States.
- Each transfer is covered by the provider's processing agreement and contractual clauses.
This summary guides the reading and does not replace the text of the document.
01Where the data is
Drometra is a Chilean company, but the platform data —positions, deliveries, drivers, recipients, evidence— is stored and processed on a server of Contabo GmbH located in France. The European Union applies the General Data Protection Regulation, a regime at least as demanding as Law 21,719, and Contabo is subject to it.
A previous version of this document stated that fleet data was stored in Chile. That was not correct, and we corrected it in version 2.0.
02What comes out, where and with what mechanism
| Data category | Destination | Reasons | Mechanism | State |
|---|---|---|---|---|
| All platform data | France (European Union) | Server hosting | Contabo data processing agreement under the General Data Protection Regulation | Active |
| Database backups, encrypted by us | Cloudflare network, no fixed region | Disaster recovery | Cloudflare data processing agreement and contractual clauses; Cloudflare cannot decrypt them | Active |
| IP addresses and connection metadata | United States and global points of presence | Delivery network, tunnel, and attack protection | Cloudflare data processing agreement and contractual clauses | Active |
| Questions to Michiva and masked facts | United States | Answer with OpenAI or Anthropic language models, directly or via OpenRouter | Provider's API terms, with no training and zero retention where the model offers it | Conditional |
| Mail and content of notifications | United States | Transactional email delivery with Resend | Provider's data processing agreement | Ready, not active |
| User IP and the map area viewed | United States | Esri satellite imagery | Provider's terms | Conditional |
| Drometra Vision video | Vehicle device; lab copy in Cloudflare R2 for 24 hours | Beta testing | Beta participation agreement | Lab beta |
03The mechanisms that the law allows
Ley 21.719 · Articles 27 and 28
The international transfer takes place where the country of destination has an adequate level of protection declared by the Agency; where the person responsible adopts contractual clauses, binding corporate rules or other instruments that ensure compliance; or when he / she averages a certified compliance model; there are also limited exceptions, such as the express consent of the holder or the performance of a contract in his / her interest.
Official text of the ruleThe Personal Data Protection Agency has not yet declared which countries have an adequate level of protection. Until it does, we rely on each provider's data processing agreements and contractual clauses. When that declaration exists, we will review this document and publish what changed.
04Additional guarantees
- Transit numbering: all connections, including internal ones to the database, use TLS.
- Backups encrypted at source: are encrypted on our server before leaving it, so the storage provider holds content it cannot read.
- Prior minimization: only the necessary facts reach the language models, with license plates and names replaced by placeholders.
- Country of destination assessment: before we hire we review whether their legislation allows government access incompatible with the guarantees committed.
The database volume on the server is not encrypted at the disk level; this is under evaluation.
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.
Related documents
- UnderloadedThe third parties that process data on behalf of Drometra: what function they perform, what data they reach, where they operate, and whether they are active.
- Privacy policyWhat personal data we process, in which products, where it is stored, how long we keep it, how we use artificial intelligence models, and how you exercise your rights.
- Platform privacyHow we process the fleet, route, delivery, driver, recipient, and video data generated by a customer's operations, in the console, Michiva, Dromivia, Drometra Vision, and Drometra Spaces.
- Michiva and AIWhat Michiva does today, what it will be able to do and under which rules, which third-party models it can use, what data reaches them, how long it is kept and what it never does.
