Sub-processors

EverCFO is operated by Celeste Business Advisors LLP (“EverCFO”, “we”, “our”, or “us”). This page lists every third-party sub-processor we engage to operate the EverCFO service, what data each receives, where the data is stored, and the data processing agreement that governs each relationship. It is the canonical record cross-referenced by our Privacy Policy section 3 and (when published) our Data Processing Addendum.

1. What a sub-processor is and why this list matters

A sub-processor is any third party we use to process customer personal data on our behalf in the course of providing EverCFO. Under GDPR Article 28 (and equivalent regulation elsewhere), every sub-processor must be bound by a data processing agreement (DPA) that imposes the same data protection obligations on the sub-processor that you have with us, and we remain liable to you for the sub-processor’s acts and omissions.

The accounting and commerce platforms you connect (QuickBooks, Xero, Shopify) are data sources you authorize, not sub-processors.

We publish this list (a) so business customers can complete their own vendor risk reviews, (b) so we can give material-change notice before adding or replacing a sub-processor, and (c) so every contractual statement we make about who processes your data is traceable to a single source of truth.

The list below is generated directly from a single source-of-truth file in our codebase. Anything that ships into production is reconciled against it. We currently engage 16 sub-processors.

A further 2 providers are listed but not yet engaged — TypeSafe and Plaid. They appear in section 2.1 below, with the data they will receive, and process nothing today. We publish a row before the first data reaches a provider rather than after, so the material-change notice in section 4 runs in advance of the change rather than alongside it. Each row says in its own words what has to happen before it begins.

2. Current sub-processors

Every provider in this section is engaged today and processes customer data now. Providers we have disclosed ahead of first use are listed separately in section 2.1, and ones we have removed in section 2.2 — neither receives customer data.

Sub-processors are grouped by function. Within each group, entries are ordered as they appear in our source-of-truth file. The “Last reviewed” column is the date the row was last reviewed against the deployed system (data categories, storage location, DPA URL).

2.1 Planned sub-processors, not yet engaged

These providers are disclosed in advance of first use. They process no customer data today. The “Data it will receive” column describes what each would receive once the relevant feature is turned on, and each row states in its own words what has to happen first.

3. How we vet and manage sub-processors

Before a sub-processor goes into production behind customer data, we check each of the following:

• Data processing terms. We review each sub-processor’s published data processing terms before engaging it; where a provider publishes a DPA, it is linked in the table.
• Cross-border safeguards where required. Where the sub-processor processes EU or UK personal data outside the EEA / UK, the relevant Module Three Standard Contractual Clauses (or equivalent transfer mechanism) apply.
• Minimum-necessary data. Each sub-processor receives only the data categories listed in its row above. When we change what we send, we update this list and the privacy policy in the same release.
• Breach notification. We look for breach-notification commitments in each provider’s terms, so that EverCFO can in turn notify affected customers in accordance with section 8 of our Data Processing Addendum.
• Deletion on request. When a customer exercises a deletion or end-of-contract right, we propagate that instruction to sub-processors that hold copies of relevant data within the timelines stated in our Privacy Policy and Terms.

We review every sub-processor row in this list periodically and bump the “Last reviewed” date when the row is re-verified against the deployed system. A material change to a sub-processor (added role, expanded data categories, changed storage region, replacement provider) triggers a notification under section 4 below.

4. Notifications of material changes

Before adding a new sub-processor or making a material change to an existing one (for example, a change of storage region or expanded data categories), we will give business customers at least 30 days’ advance written notice. This commitment also appears in our Data Processing Addendum when published.

To receive material-change notifications, email privacy@evercfo.ai from the address associated with your EverCFO account and ask to be added to the sub-processor notification list. We do not yet offer an in-product subscription control; when we ship one, we will update this section.

You may object to a proposed new sub-processor for reasonable grounds related to data protection. If we cannot accommodate your objection within a reasonable period, you may terminate the affected portion of the service in accordance with our Terms of Service.

5. Contact

Questions about a specific sub-processor or about our sub-processor management program can be sent to our privacy contact at privacy@evercfo.ai. For the broader privacy program and full contact details, see Privacy Policy section 13.