Faces to Names Subprocessors
Last updated: October 7, 2026
Faces to Names ("FTN") defines customer data as all data provided to FTN through use of the FTN platform, including teacher account details, class and invitation metadata, and student research submissions. Some customer data is personal data under PIPEDA and under applicable provincial education-privacy legislation.
This Subprocessor List identifies the subprocessors authorised to process customer or personal data on behalf of FTN in order to provide the FTN platform. It supplements FTN's agreements with participating organisations.
FTN publishes the name of any new subprocessor at least 30 days before that subprocessor is authorized to perform services that may involve access to customer data or personal data. FTN notifies the designated contact at each participating school board by email when this list changes.
If you have questions about this list, contact us at .
Subprocessors
| Name of Subprocessor | Description of Processing | Location of Processing | Corporate Location |
|---|---|---|---|
| Environmental Systems Research Institute, Inc. (Esri) | Basemaps and historical-location searches; receives search text, map coordinates, and browser request data, including IP address | Global cloud infrastructure, including the United States | United States |
| Google LLC (Firebase Authentication) | User authentication and account identity | United States | United States |
| Google LLC (Firebase Cloud Storage) | Storage of files and photos uploaded by teachers and students | Canada (Google Cloud northamerica-northeast1, Montréal, Québec) | United States |
| Microsoft Corporation (Microsoft Entra ID) | School-board single sign-on, including authentication and the identity, tenant, and group or role claims supplied by a participating board | The geographic location assigned to the participating school board's Entra tenant; authentication may occur in the nearest datacenter in that Entra logical region | United States |
| Mistral AI (RCS Paris 952 418 325) | Optical character recognition of documents uploaded as research evidence | European Union, with onward transfers outside the EEA permitted under Standard Contractual Clauses | France |
| OpenAI, L.L.C. | Model inference for the research validation agent, which reads student worksheet answers and supporting documents. Reached through Vercel AI Gateway. | United States | United States |
| PlanetScale, Inc. | Hosting of the primary application database, which holds accounts, classes, invitations, projects, and worksheet content | Canada (GCP northamerica-northeast1, Montréal, Québec) | United States |
| PostHog, Inc. | Product analytics and usage measurement | United States | United States |
| Plus Five Five, Inc. (Resend) | Delivery of transactional email, including invitations and notifications | United States | United States |
| AlphaAI Technologies Inc. (dba Tavily) | Web search used by the research validation agent to locate candidate source pages | United States | United States (New York) |
| Vercel Inc. | Application hosting, edge network, and serverless compute for the FTN web application and API. Also runs the research validation agent and routes its model calls through Vercel AI Gateway. | United States (iad1, Washington DC) | United States |
Location of processing
FTN is a Canadian organization. Its primary application database and uploaded files are stored in Canada (Montréal). Other subprocessors process data outside Canada: in the United States, and in the European Union in the case of Mistral AI. Esri's mapping services use global cloud infrastructure, including the United States. The Location of Processing column above states the location for each subprocessor.
Each subprocessor processes personal data on FTN's behalf under a data processing agreement that restricts use of the data to the provision of that subprocessor's service. Data is encrypted in transit. FTN discloses these transfers in its Privacy Policy.
Subprocessors that process student-submitted content
The following providers process student-submitted content as described below:
- Esri — receives historical-location search text, which may come from worksheet fields, and map coordinates. Mapping requests go directly from the browser to Esri and include browser request data such as the IP address.
- PlanetScale, Inc. — stores worksheet text and structured answers.
- Google LLC (Firebase Cloud Storage) — stores the uploaded files.
- Vercel Inc. — processes the data in transit as the application host, runs the validation agent and holds its run state, and passes prompts through AI Gateway.
- Mistral AI — receives uploaded documents for text extraction.
- OpenAI, L.L.C. — receives worksheet answers and extracted document text for validation.
Microsoft Entra ID, PostHog, and Resend do not receive student-submitted content. Microsoft Entra ID receives identity and access data only for users who choose a participating school board's single sign-on.
Tavily receives the search queries the validation agent generates while researching a casualty record, and returns page titles and URLs. It does not receive worksheet documents or uploaded files.
Third-party services we link to but do not send data to
FTN embeds and links to public historical archives so that students can research within the platform. FTN proxies these requests, so the upstream site receives FTN's server address rather than the student's. These are not subprocessors and receive no personal data. The research map is not one of these: Esri is listed as a subprocessor above because the map is loaded directly by the browser.
- Veterans Affairs Canada — Canadian Virtual War Memorial (
veterans.gc.ca) - Commonwealth War Graves Commission (
cwgc.org) - Library and Archives Canada (
bac-lac.gc.ca)