Legal
Sub-Processors
Version 0.2 · Last Updated: 17 July 2026
1. Overview
This page lists the third parties that process personal data on behalf of FiqhEngine Ltd in the course of providing the Service. It is published in support of our obligations under GDPR Articles 13 and 28 and is referenced from our Privacy Policy.
Each sub-processor below has a written Data Processing Agreement in place, covers personal data only to the extent needed to deliver the function described, and is reviewed at least annually.
2. Infrastructure & Hosting
Railway Corp. (Application Hosting & Managed PostgreSQL)
- Purpose:
- Serves the FiqhEngine web application and API, and hosts the primary application database. The frontend is served by our application server on Railway; there is no separate CDN sub-processor.
- Data processed:
- All application data (engagements, documents, fatwas, user accounts, encrypted OAuth tokens) plus IP addresses and standard HTTP request metadata — encrypted at rest.
- Location:
- United States — US East (Virginia) region.
- Safeguards:
- SOC 2 Type II / ISO 27001 certified infrastructure; TLS 1.2 minimum (TLS 1.3 supported) in transit; AES-256-GCM at the application layer for sensitive fields; point-in-time recovery backups retained for approximately four weeks; Standard Contractual Clauses and UK IDTA.
- More info:
- railway.com/legal/privacy
3. Email Delivery
Twilio SendGrid (Transactional & Notification Email)
- Purpose:
- Delivers transactional and notification email (account, security, and workflow messages) on our behalf.
- Data processed:
- Recipient email address, sender name, subject and body of the message, basic delivery metadata (opens, bounces).
- Location:
- United States.
- Safeguards:
- SOC 2 Type II; ISO 27001; TLS in transit; Standard Contractual Clauses and UK IDTA under the Twilio DPA.
- More info:
- twilio.com/legal/privacy
SendGrid is the only email provider in production. Alternative providers (Gmail API, Amazon SES, generic SMTP) are configurable in the codebase but are not currently active.
4. Optional Calendar & Contact Integrations
These integrations are only activated when an individual user explicitly connects the relevant account from within their profile. They can be disconnected at any time from the Calendar widget's Settings, which immediately revokes our access and deletes the stored tokens.
Google LLC (Google Calendar, Google People, OpenID)
- Purpose:
- Two-way sync of meetings, audits, and SSB sessions with the user's Google Calendar; optional read-only access to contacts for attendee suggestions; OpenID sign-in.
- Data processed:
- OAuth access and refresh tokens (encrypted), calendar events created or modified by the user within FiqhEngine, contact name and email when the user invites an attendee.
- Location:
- United States and other regions operated by Google.
- Safeguards:
- Our use of data received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements (no advertising use, no training of generalised AI models, no transfer to third parties beyond what is necessary to deliver the feature).
- More info:
- policies.google.com/privacy
Microsoft Corporation (Microsoft Graph — Calendar & Contacts)
- Purpose:
- Two-way sync of meetings with the user's Outlook / Microsoft 365 calendar; optional read-only access to contacts for attendee suggestions.
- Data processed:
- OAuth access and refresh tokens (encrypted), calendar events created or modified by the user within FiqhEngine, contact name and email when the user invites an attendee.
- Location:
- Determined by the user's Microsoft 365 tenant region.
- Safeguards:
- TLS in transit; Microsoft Online Services DPA; tokens stored encrypted (AES-256-GCM) in our database; user-initiated revocation at any time.
- More info:
- privacy.microsoft.com/privacystatement
5. Meeting & Conferencing (Optional, Per-Tenant)
Where a tenant enables meeting scheduling, join links are minted through the provider selected for that deployment. These are configured per tenant and are not active by default.
Zoom Video Communications, Inc.
- Purpose:
- Create Zoom meeting links when a host schedules a meeting from within FiqhEngine (via Server-to-Server OAuth on the tenant's own Zoom account).
- Data processed:
- Meeting topic, start time, duration, and host email address. Recording behaviour defers entirely to the tenant's own Zoom account configuration.
- Location:
- United States and other regions operated by Zoom.
- Safeguards:
- TLS in transit; Zoom DPA; meetings are created on the customer's own Zoom account under their controls.
- More info:
- zoom.us/privacy
Microsoft Corporation (Microsoft Teams)
- Purpose:
- Mint Microsoft Teams join links via Microsoft Graph when a host schedules a Teams meeting from within FiqhEngine.
- Data processed:
- Meeting subject, start time, duration, and organiser identity.
- Location:
- Determined by the tenant's Microsoft 365 region.
- Safeguards:
- TLS in transit; Microsoft Online Services DPA.
- More info:
- privacy.microsoft.com/privacystatement
Google Meet links are minted through the Google Calendar integration listed in section 4 and require a connected Google account.
6. Electronic Signature (Optional, Per-Tenant)
Where e-signature is enabled, documents are sent for signature through SignWell. If e-signature is not configured, the platform falls back to manual signed-PDF upload and no signature sub-processor is used.
SignWell, Inc.
- Purpose:
- Send documents for electronic signature and return the executed document and audit trail.
- Data processed:
- Document to be signed, signer name and email address, and signature/audit metadata.
- Location:
- United States.
- Safeguards:
- TLS in transit; webhook signature verification; SignWell DPA.
- More info:
- signwell.com/legal/privacy
7. AI Processing
Google LLC (Google Gemini API)
- Purpose:
- Generate Shariah advisory suggestions and analyse uploaded documents. FiqhEngine does not use this to train its own models.
- Data processed:
- Advisory titles/descriptions, relevant knowledge-base context, and the content of documents submitted for analysis.
- Location:
- United States and other regions operated by Google.
- Safeguards:
- TLS in transit; Google AI API terms; Google does not use data submitted through the paid Gemini API to train or improve its models.
- More info:
- ai.google.dev/gemini-api/terms
8. Team Notifications (Optional, Per-Tenant)
Slack Technologies, LLC
- Purpose:
- Deliver workflow notifications to a customer's Slack workspace where the customer enables the Slack integration.
- Data processed:
- Notification content and the destination channel/workspace identifiers configured by the customer.
- Location:
- United States and other regions operated by Salesforce/Slack.
- Safeguards:
- TLS in transit; Slack DPA; integration is off unless the customer enables it.
- More info:
- slack.com/trust/privacy
9. Authentication & Security
Two-factor authentication is implemented in-process using the open-source speakeasy (TOTP generation) and qrcode libraries. Neither transmits data to any external service. 2FA secrets are stored encrypted in our database and never leave our infrastructure.
10. Analytics & Tracking
Google LLC (Google Analytics 4 — marketing website only)
- Purpose:
- Aggregate visitor analytics on our public marketing website. Not used inside the authenticated application. Loaded only after a visitor grants Analytics-cookie consent.
- Data processed:
- Pseudonymous usage events and device/browser metadata, with IP anonymisation enabled. No application database content.
- Location:
- United States and other regions operated by Google.
- Safeguards:
- IP anonymisation; consent-gated loading; Google Ads Data Processing Terms; Standard Contractual Clauses.
- More info:
- policies.google.com/privacy
We do not use Mixpanel, advertising networks, social-media tracking pixels, or any third-party profiling service. Product usage telemetry inside the application is stored in our own database and used solely to operate and improve the Service.
11. Development & Operations
GitHub, Inc.
- Purpose:
- Source-code repository and CI/CD for the FiqhEngine application.
- Data processed:
- Source code and commit history. No customer data, production secrets, or personal data is stored in the repository.
- Location:
- United States.
- Safeguards:
- SOC 2 Type II; ISO 27001; access restricted to the development team via SSO and 2FA.
- More info:
- github.com/site-policy
12. International Data Transfers
Where personal data is transferred outside the United Kingdom or the European Economic Area, we rely on Standard Contractual Clauses (SCCs) approved by the EU Commission and the UK International Data Transfer Addendum, supplemented by encryption in transit (TLS 1.2 minimum, TLS 1.3 supported) and at rest (AES-256-GCM).
| Sub-Processor | Destination | Transfer Mechanism |
|---|---|---|
| Railway | USA (US East, Virginia) | SCCs + UK IDTA |
| SendGrid (Twilio) | USA | SCCs + UK IDTA |
| Google — Calendar / Gemini / Analytics | USA / Global | SCCs (Google DPA) |
| Microsoft (optional) | Tenant-dependent | Microsoft Online Services DPA |
| Zoom (optional) | USA / Global | SCCs (Zoom DPA) |
| SignWell (optional) | USA | SCCs + provider DPA |
| Slack (optional) | USA / Global | SCCs (Slack DPA) |
| GitHub | USA | SCCs + UK IDTA |
13. Changes to This List
We will update this page whenever we add, remove, or change a sub-processor. For material changes affecting how Customer Data is processed, we will provide reasonable advance notice by email to account administrators.
14. Contact
Questions about our sub-processors or DPA requests should be directed to privacy@fiqhengine.com.
FiqhEngine Ltd
128 City Road
London EC1V 2XN
United Kingdom