Subprocessor schedule
Every company that can reach your families’ or students’ information, what each one does with it, and where it processes. This is the schedule incorporated into the Data Processing Agreement at DPA § 5.3.
DPA § 5.3(a) — access to family and student data
Each is bound by written data-protection terms covering confidentiality, security, breach notification, and deletion on our instruction, and AskElira remains liable to your school for their acts and omissions. Where a provider publishes standard terms we cannot negotiate, we impose obligations no less protective than those we owe you, as 8 NYCRR § 121.9(b) requires, and select only providers whose published terms meet that standard. One exception, named rather than disclaimed: Meta Platforms. Meta gives no United States processing commitment and does not accept deletion instructions from us for message content crossing its network — which is why WhatsApp is off unless your school switches it on, and why leaving it off costs you nothing else in the service.
| Subprocessor | Role | Personal data accessed | Location |
|---|---|---|---|
| Twilio, Inc. | SMS delivery (A2P 10DLC registered); outbound keypad-IVR voice and plain-TTS attendance calls | Guardian phone number; student first name (spoken in both the enrollment and attendance call scripts); student full name (attendance text and email only); seat/attendance status; call outcome | U.S. region selected; Twilio states that selecting a region does not guarantee every datum remains in it |
| Meta Platforms, Inc. WhatsApp Business Platform | Carries family Q&A assistant messages over WhatsApp, where the school enables that channel. Twilio remains the provider of record — the channel is reached through Twilio’s WhatsApp Business API — but Meta operates the network and receives the message content in the clear on its own platform, so it is disclosed in its own right | Guardian WhatsApp telephone number and display name; the guardian’s question text as written; the assistant’s answer text. The enrollment and attendance records in DPA § 3.1(a) are not sent over this channel | Global. Meta gives AskElira no United States processing commitment of any kind, and AskElira passes on no residency warranty for this channel — see DPA § 3.7(a) |
| Google Cloud Vertex AI AI model provider | AI model provider (DPA § 3.5): family Q&A assistant, staff support assistant, and School Operational Document reading (event flyers and academic calendars your school uploads). The staff-note send/hold review moved to the Amazon Web Services row below on August 16, 2026 — a change of source inside the schedule, not a new function and not a new kind of data. Content is not used to train or improve Google’s models | The guardian’s question text as written — no student or guardian name is attached to a Q&A request, which carries the question and your school’s own published facts and nothing from the § 3.1(a) enrollment record. School Operational Documents your staff upload (a flyer, a calendar), which are the school’s own published material, never a guardian- or student-submitted file. SSN-shaped text in free-text inputs is redacted before storage and before transmission | US Processing Endpoint (recorded in the Order Form; us-central1 unless stated otherwise). Data at rest and ML processing in-region; abuse-monitoring retention up to 90 days, held in the selected region, not used for training |
| Amazon Web Services, Inc. Amazon Bedrock AI model provider | AI model provider (DPA § 3.5) — serves the staff-note send/hold review; Google Cloud serves the other three functions. The model served here is DeepSeek V3.2, and the § 3.5 distinction between a model’s DEVELOPER and its PROVIDER is the whole of this row’s design: the model was developed by DeepSeek, but it runs entirely inside AWS’s United States infrastructure, operated by AWS under AWS’s terms — DeepSeek the company operates no part of this path, holds no account with us, and receives no Content from it. Content is not used to train or improve any AWS model, any third-party model served through Bedrock, or that model developer’s own models: the AWS Data Processing Addendum § 3 commits that "AWS will not access or use, or disclose to any third party, any Customer Data, except … as necessary to maintain or provide the Services", and § 2 makes the agreement itself the only instructions AWS may process on — training a model is neither. AWS Service Terms § 50.3 says the same by exclusion, listing the services for which AWS may use content to develop and improve and stating that it "does not apply to … any AI Service that is not listed"; Bedrock is not on that list, and § 1.14.1 incorporates the Addendum. The developer receives no Content: § 50.12.5 permits AWS to share information about our use of a third-party model with that model’s provider only where the information "does not include Your Content". Which terms govern the model is answered by AWS itself: the model card’s "End User License Agreements and Terms of Use" points at the model’s open-source MIT license, which carries no acceptable-use restriction, no data claim, and no foreign governing-law clause — so no vendor licence sits between your school and us. The AWS Customer Agreement, the AWS Service Terms and the AWS Data Processing Addendum are the whole of it | One input: Staff Enrollment Notes, for the send/hold review — free text your staff wrote about a named applicant, so a student’s name is present whenever your staff wrote one, with SSN-shaped text redacted before storage and before transmission. The guardian question text the Google Cloud row describes is not sent here. No enrollment record, no attendance data, no document, and no file of any kind | Amazon Bedrock In-Region, United States only — us-east-1, us-east-2 or us-west-2. Two independent reasons it stays there: for this model the Geo and Global cross-Region inference profiles are not supported, so a request cannot leave the selected region even by misconfiguration; and AWS Data Processing Addendum § 12.1 commits that once the region is chosen, "AWS will not transfer Customer Data from Customer’s selected Region(s) except as necessary to provide the Services initiated by Customer, or as necessary to comply with the law". On retention, nothing is kept: AWS operates Bedrock on a zero-data-retention and zero-operator-access model, under which "no operators of the service can access model input or output", and DeepSeek V3.2 is not among the models Bedrock’s published abuse-detection documentation excepts from that default (that list names OpenAI and Anthropic models, and this schedule routes to neither). Separately, AWS Service Terms § 50.12.2 permits AWS to review classifier-flagged inputs and outputs; with nothing retained for this model there is nothing for that permission to reach, and we state the permission as well as the practice because a contract records what a party may do and published documentation records what it does — two different things for a school to weigh |
| Google LLC Sheets API | Enrollment tracker autofill, and a read of the school's own tracker to compare its registration statuses against the student information system (school-authorized, both directions). The comparison is a report: nothing read from a spreadsheet ever changes a record, moves a seat, or sends a message | Enrollment Data per DPA § 3.1(a). On the read side, deliberately narrower: the column headings, and then only the columns identified as student ID, student name, grade and registration status. Other columns of the school's spreadsheet are never requested and never received | United States |
| Turso (ChiselStrike) | Primary encrypted database hosting (provider-managed volume encryption at rest) | All persisted Personal Data in DPA § 3.1 | United States |
| Vercel, Inc. | Application hosting and the serverless runtime that processes Personal Data | All DPA § 3.1 Personal Data processed in-runtime | U.S. regions selected; Vercel states it may process data globally and replicates some backups globally |
| AgentMail (Amazon SES) | Transactional email delivery, inbound guardian-mail receipt and sender authentication | Guardian email; student first name; student full name (attendance emails only) | United States |
| Resend, Inc. | Standby outbound email delivery — used only where the primary email provider will not accept a message for transport (an outage, an authentication failure, throttling). A rejection that belongs to the recipient, such as a suppression or block-list entry, is never retried here. Inbound mail and its sender authentication stay with AgentMail | Guardian email; student first name; student full name (attendance emails only) | United States |
| SchoolMint | School-authorized SIS/enrollment integration | Guardian phone/email; student first name; grade; seat status; campus; enrollment year; SIS record identifiers | United States |
DPA § 5.3(b) — school staff and account data only
These support billing and contract execution. None of them receives student data, guardian data, or any Protected Data under NY Education Law § 2-d.
| Subprocessor | Role | Personal data accessed | Location |
|---|---|---|---|
| Stripe, Inc. | Subscription billing and payment processing | Billing contact name and email address; payment-method and subscription status. AskElira does not receive or store full payment-card numbers | United States |
| eSignatures.com | Electronic execution of the onboarding instruments | Signer name, email address, signature image, and execution audit trail | United States |
Not a subprocessor. Three vendors are named here rather than omitted, because each touches AskElira’s own engineering systems and none receives school, guardian, or student data. Anthropic PBC is used only as internal software-development tooling. Slack Technologies receives an internal operations channel: automated signals about AskElira’s own deployments, test suites and safety-switch settings, in which a school appears only as a pseudonym computed from a key held on AskElira’s own machine and resolvable nowhere else. DeepSeek receives short excerpts of AskElira’s own build output — test failures, file paths, stack traces and commit messages — to summarize them for that channel; it receives no Protected Data, no message content, and nothing from any school record, and it is not an AI model provider under DPA § 3.5 in that capacity. Separately, and the distinction matters: one of the models AskElira runs WAS DEVELOPED by DeepSeek — DeepSeek V3.2, which serves the staff-note review. That model is served entirely by Amazon Web Services on Amazon Bedrock, a subprocessor named in the schedule above; AWS operates it inside AWS’s United States infrastructure under AWS’s terms, and DeepSeek the company operates no part of that path and receives no Content from it either (AWS Service Terms § 50.12.5). A model’s developer and the provider that serves it are different parties — DPA § 3.5 draws exactly that line. Every payload to Slack or to DeepSeek is scanned before it is sent and is blocked outright, rather than trimmed and sent, if it matches a family or school identifier. The former conversational-voice path (VAPI, with OpenAI as its model provider) was retired on July 24, 2026 and processes no school data. A provider’s presence in the schedule above is independent of that retired path.