Sub-processors
List of processors under Art. 28 GDPR engaged to deliver the Service. Changes are communicated to Customers in advance per the customer DPA.
EW-Flow sub-processors (engaged directly by Everywhere S.r.l.)
| Vendor | Purpose | Processing location | Safeguards |
|---|---|---|---|
| Microsoft Corp. (Microsoft Ireland Operations Ltd) | Hosting (Azure App Service), database (Azure Database for MySQL), storage (Azure Blob), authentication (Azure AD B2C), telemetry (Application Insights), Service Bus, Redis, Key Vault, Grafana | EU (Italy North); some global metadata | Microsoft Online Services DPA, EU Data Boundary, SCCs, DPF |
| Microsoft Azure Communication Services | Transactional platform emails (notifications, invoices, invitations) | EU | Covered by the Microsoft Online Services DPA |
| Stripe Payments Europe Ltd | Payment processing, billing | EU (Ireland) primary; some US processing | Stripe DPA, SCCs, DPF |
| GitHub Inc. | Source code hosting, CI/CD (GitHub Actions) | US | GitHub DPA, SCCs, DPF |
| OpenAI, L.L.C. | Language models for the AI Agent: response generation for the in-portal AI assistant | US | OpenAI DPA and Standard Contractual Clauses; data sent through the API is not used to train models |
| Anthropic, PBC | Language models for the AI Agent: response generation for the in-portal AI assistant | US | Anthropic DPA and Standard Contractual Clauses; data sent through the API is not used to train models |
There may be more than one language model provider and they may change over time. The list in force is the one on this page, and every change is recorded in the change history.
Customer-configured integrations
The following services are not our sub-processors: the Customer configures them with their own credentials and contracts directly with the vendor. Data flows through EW-Flow but no contractual relationship exists between Everywhere S.r.l. and these vendors.
| Service | Type | Vendor privacy |
|---|---|---|
| Twilio Inc. | SMS, voice, WhatsApp | privacy |
| Aculab plc | Telephony | privacy |
| Slack Technologies | Messaging | privacy |
| OpenAI L.L.C. | OpenAI module (LLM) | privacy |
| Microsoft Azure Communication Services | SMS, voice, email, chat (ACS module) | (covered by Customer's Microsoft Online Services DPA where configured by the Customer) |
Change notifications
Changes to the sub-processor list are published on this page and communicated to Customers at least 30 days in advance, except for security or legal urgencies. Customers may object to a change as set out in the customer DPA.
Change history
| Date | Change |
|---|---|
| 2026-09-16 | AI Agent language model providers named: OpenAI and Anthropic; added Microsoft Azure Communication Services as a platform service for transactional emails. Legal review completed |
| 2026-05-07 | Initial publication |