Sub-processors
The third parties ShareTree engages to deliver Proactive EAP, what each of them handles, and where. This page is Schedule 2, section 1 of the Proactive EAP Service Agreement.
Last updated: 9 September 2026
Proactive EAP is delivered with the help of the providers below. This list forms part of the Proactive EAP Service Agreement as Schedule 2, section 1. Employees receiving check-in calls can read the plain-English version in the Employee Privacy Notice.
ShareTree’s system of record is hosted by Xano in Sydney, Australia. All client data, transcripts, findings, reports and acceptance records are stored there. Some processing happens overseas, which is disclosed under Australian Privacy Principle 8 in clause 9.6 of the agreement.
How this list changes
Under clause 9.7 of the agreement, ShareTree may add or change a sub-processor by updating this page and notifying each client’s nominated administrator, giving at least 30 days’ notice before the change takes effect. A client may object on reasonable grounds within that period. If the objection cannot be resolved, either party may terminate the affected order without penalty and ShareTree refunds fees paid for the unexpired part of the current cadence block.
Current sub-processors
| Sub-processor | Function | Location of processing | Personal information processed | Controls | In schedule since |
|---|---|---|---|---|---|
| ElevenLabs, Inc. | Conversational AI voice agent for AI Mode calls (speech recognition, dialogue, speech synthesis). | United States | Live call audio and dialogue during the call; Enrolled Employee first name and Client name passed as call variables. | Zero Retention Mode enabled on the production agent: no recording, transcript or call metadata retained after the call. Transcript delivered to ShareTree by signed webhook and stored only in Sydney. Audio webhook disabled. Contractual prohibition on training on customer content. | 9 September 2026 |
| Twilio Inc. | Telephony: placing outbound calls to Enrolled Employee mobiles; SMS. | United States (call routing and metadata); carriage within Australia | Mobile number; call timing, duration and outcome metadata. No call content stored. | No recording enabled. Data processing addendum in place. | 9 September 2026 |
| Anthropic, PBC | AI analysis of Transcripts to produce Findings against the Taxonomy. | United States | Transcript text (identifying details minimised before submission where practicable). | API terms prohibit training on customer inputs; zero data retention where available on plan. Outputs stored only in Sydney. | 9 September 2026 |
| Cal.com, Inc. | Booking of Support Sessions; calendar invitations and SMS reminders. | United States / EU | Enrolled Employee name, email, mobile number; session time. | Limited to booking data. No call content. | 9 September 2026 |
| Twilio SendGrid | Transactional email (pre-call notice, booking confirmations, administrator notices). | United States | Name; email address; email content (no call content). | Transactional only. | 9 September 2026 |
| Stripe, Inc. | Payment processing for the Client. | United States / Australia | Client billing contact and payment details. | PCI-DSS Level 1. ShareTree does not store card numbers. | 9 September 2026 |
| Xano, Inc. | Backend and database hosting (system of record). | Sydney, Australia | All data categories above. | Encryption at rest and in transit; server-side access control; append-only audit tables. | 9 September 2026 |
Change history
- 9 September 2026 — Schedule first published with the Proactive EAP Service Agreement. Initial sub-processors: ElevenLabs, Twilio, Anthropic, Cal.com, Twilio SendGrid, Stripe and Xano.
Questions
Email support@sharetree.org.