Legal & compliance · Schedule v1.11 · Updated October 3, 2026
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.
This page is part of your agreement, and it cannot be changed quietly. DPA § 5.3 makes this published schedule part of the contract, and the tables printed inside your executed packet are this same schedule as of the version you signed (v3.9 — October 2026). Before any addition or replacement takes effect you get not less than 30 days’ advance written notice — to your authorized representative and your Data Protection Officer, published here at the same time — and a real opportunity to object; if we cannot accommodate your objection you may terminate without penalty. The published schedule governs only for changes that notice was actually given for. For anything else, the table printed in your executed copy controls.
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. From schedule v1.7, and only for a school that has elected the Voice Receptionist Add-On, also the inbound telephony and the live audio stream (Programmable Voice and Media Streams) between the caller and AskElira’s relay. Twilio call recording is not enabled for that service and no stored recording is created at Twilio | 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. For the Voice Receptionist Add-On: the caller’s telephone number, the call metadata, and the live call audio in transit | U.S. region selected; Twilio states that selecting a region does not guarantee every datum remains in it. Media Streams audio retention after transit is a written answer AskElira has requested from Twilio and does not yet hold |
| OpenAI, L.L.C. gpt-live-1, OpenAI Live API (direct developer API) AI model provider | AI model provider (DPA § 3.5), for the Voice Receptionist Add-On alone: performs the conversational speech processing of an inbound call and produces the spoken reply, answering from the school’s own approved facts supplied by AskElira’s code. OpenAI is also the developer of this model and receives content directly in that listed role — the express exception stated in DPA § 3.5. In force and not in use: no school’s call reaches OpenAI until that school has executed the amendment ordering the add-on and AskElira has enabled it. On training, AskElira relies on OpenAI’s own published statement and quotes it rather than paraphrasing it: "As of March 1, 2023, data sent to the OpenAI API is not used to train or improve OpenAI models (unless you explicitly opt in to share data with us)." (OpenAI’s published statement, https://developers.openai.com/api/docs/guides/your-data, retrieved 2026-09-15.) AskElira has not opted in. That is a quotation of OpenAI’s term, not an AskElira warranty, and AskElira does not represent that it holds a negotiated commitment beyond it. The same OpenAI voice model also generates fixed opening audio in the configured assistant voice from the School name and script only; if unavailable, the carrier speaks the same text by text-to-speech. | Fixed opening text and School name for OpenAI’s voice model, with no caller audio or Student Data in that request; live call audio; the Call Transcript; the assistant’s response text and audio; the school’s name and its approved admissions facts; whatever the caller chooses to say. No enrollment or attendance record is attached to the request, and no email address is collected by telephone | NOT a US Processing Endpoint. Reached on OpenAI’s direct developer API, for which AskElira holds no executed United States data-residency commitment. On retention and on Zero Data Retention, OpenAI’s published statement, quoted: "By default, abuse monitoring logs are generated for all API feature usage and retained for up to 30 days, unless longer retention is required by law, or is reasonably necessary to protect our services or any third party from harm." and "Eligible customers may have their customer content excluded from these abuse monitoring logs, subject to the limitations below, by getting approved for the Zero Data Retention or Modified Abuse Monitoring controls." (OpenAI’s published statement, https://developers.openai.com/api/docs/guides/your-data, retrieved 2026-09-15.) AskElira requested Zero Data Retention on 2026-09-15; it is NOT granted, so the 30-day default above is what applies to this account, and those logs are reviewable by authorized OpenAI personnel |
| Railway Corp. | Hosting for the relay server of the Voice Receptionist Add-On: it streams call audio between Twilio and OpenAI, runs AskElira’s own answer code, and assembles the Call Transcript. In force and not in use: no school’s call reaches Railway until that school has executed the amendment ordering the add-on and AskElira has enabled it | The same call audio in transit, the Call Transcript, and the call metadata; plus the school’s approved facts used to answer | United States (Railway, region to be confirmed). The specific region, and Railway’s log and backup retention, will be stated here once confirmed in writing |
| 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, and the family Q&A assistant only when Google Cloud Vertex AI is unavailable or throttled and has not answered; Google Cloud answers the family Q&A assistant first and serves the other two functions. Two models are served here, and the § 3.5 distinction between a model’s DEVELOPER and its PROVIDER is the whole of this row’s design: DeepSeek V3.2 (the review, and the family Q&A backup on text message and WhatsApp) was developed by DeepSeek, and gpt-oss-120b (the family Q&A backup on the website chat widget) was developed by OpenAI and released as an open-weight model, but both run entirely inside AWS’s United States infrastructure, operated by AWS under AWS’s terms — neither DeepSeek nor OpenAI operates any part of this path, holds an account with us for it, or receives Content from it (OpenAI’s own row, below, is the Voice Receptionist Add-On and nothing else). Content is not used to train or improve any AWS model, any third-party model served through Bedrock, or those model developers’ 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. Neither developer receives 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 each model is answered by AWS itself: each model card’s "End User License Agreements and Terms of Use" points at the model’s open-source licence — MIT for DeepSeek V3.2, Apache 2.0 for gpt-oss-120b, whose accompanying usage policy asks only that users "comply with all applicable law" — and neither carries an acceptable-use restriction beyond the law, a data claim, or a 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 | Two inputs, one per function. For the send/hold review: Staff Enrollment Notes — 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. For the family Q&A backup, and only when Google Cloud Vertex AI has not answered: the guardian’s question text as written, together with your school’s own published content used to ground the answer — the same content the Google Cloud row describes, sent here instead of there. A guardian may type a student’s name or other details in that text. 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 these models 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 neither DeepSeek V3.2 nor gpt-oss-120b is among the models Bedrock’s published abuse-detection documentation excepts from that default (that list names OpenAI’s GPT-5.x and GPT-6 models and Anthropic’s Claude Fable models; gpt-oss-120b is an open-weight model outside it, and this schedule routes to none of the models listed). Separately, AWS Service Terms § 50.12.2 permits AWS to review classifier-flagged inputs and outputs; with nothing retained for these models 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 |
| Google LLC Google Calendar API | Only where the school connects a calendar, in either edition: writes each booking a family makes to the one Google Calendar the school shares with AskElira’s service-account address with permission to make changes to events, and removes it if the booking is cancelled. Private-school edition: each tour, open house or admissions interview a family books, and any move of it; AskElira reads nothing from that calendar. Charter-school edition: each tour or appointment a family books through the website chat widget; to offer only open times, AskElira also reads that calendar’s free and busy times, and never reads an event’s title, details or attendees. AskElira adds no attendee (so Google sends the family nothing) and changes only the events it wrote. The school revokes access at any time by removing that address from the calendar’s sharing in Google. An event already on the school’s calendar is the school’s own record: AskElira removes it when the booking is cancelled while the calendar is still shared, but deleting a family’s data does not reach it | Private-school edition: guardian name, email address and mobile number; the child’s first name and the grade applied for; the visit’s type and time, and how it was booked. Charter-school edition: the name and email address the family gave when booking, any note the family typed with the booking, the booking’s service, date and time, and AskElira’s booking reference; the family’s telephone number is not sent | The school’s own Google Calendar, held by Google under the school’s own agreement with Google and in the locations that agreement permits; AskElira gives no residency commitment for this row — see DPA § 3.7(b) |
| 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 |
| PowerSchool | School-authorized SIS integration (read-only): enrollment fields and Attendance Data, under field-by-field view-only grants the School configures in its own PowerSchool. AskElira writes nothing back and requests no write access; the School revokes by disabling the plugin. In force and not in use: no School’s PowerSchool is read unless that School has elected the integration in writing under DPA § 3.3 | Guardian phone/email; student first name; grade; seat status; campus; enrollment year; SIS record identifiers; attendance category per school day | United States (PowerSchool-hosted or School-hosted instance; the School’s own contract with PowerSchool governs where its PowerSchool runs). AskElira passes on no residency or security warranty on PowerSchool’s behalf |
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.
Reviewing this before you sign?
The full Data Processing Agreement, the NY §2-d Addendum and the Parents’ Bill of Rights supplement — which names these same providers for families — are all published in full.