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The subprocessors

Schedule B of the Subscriber Agreement names nine — Microsoft Azure (hosting, Canada Central), Microsoft Azure AI Speech (scribe speech-to-text, Canada Central), Cloudflare (network security, global edge), Stripe (payments, Canada/US), Twilio (SMS, US), Twilio SendGrid (email, US), Anthropic (AI, US), Daily.co (telehealth media, US/global edge) and MaxMind (IP geolocation, a local lookup with no data sent) — each with its processing location and the data it touches, and adding one that handles health information takes 30 days' notice with a right to object.

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Schedule B, as published

ProviderRoleLocationData touched
Microsoft AzureCloud hosting, storage, backupsCanada (Canada Central)All Customer Data incl. health information, encrypted at rest
Microsoft Azure AI SpeechReal-time speech-to-text for the Ambient ScribeCanada (Canada Central)Encounter audio, processed in real time to text; configured not to retain audio, never stored by Arxeon
CloudflareNetwork security, DDoS protection, content deliveryGlobal network (encrypted transit)Traffic metadata; encrypted content in transit
StripePayment processing and tax calculationCanada / United StatesBilling contact, address, payment details — no health information
TwilioSMS delivery and phone-number verificationUnited States / carrier networksPhone numbers and SMS content
Twilio SendGridEmail deliveryUnited StatesEmail addresses and message content
AnthropicAI processing for AI-assisted featuresUnited StatesContent submitted to AI features only when used — no model training, minimized retention under a data processing agreement
Daily.coLive video and audio transport for telehealthUnited States / global media edgeReal-time call media, encrypted in transit; no health information stored, calls not recorded
MaxMindIP geolocation for security featuresLocal database lookup (no data sent)IP addresses only

Alberta Health also receives claim data — surname, first name, date of birth, sex, ULI, guardian ULI, address and diagnosis codes — on every claim the clinic approves; that is a disclosure the clinic authorizes, not a subprocessor.

Changes

Arxeon binds each subprocessor that handles health information to obligations materially as protective as the Information Manager Agreement, gives at least 30 days' notice (email or in-app) before a new one handles health information, and if the clinic reasonably objects on privacy grounds and no alternative can be offered, the clinic may terminate the affected services with a pro-rata refund of prepaid, unused fees. Arxeon remains responsible for its subprocessors.

This card reproduces Schedule B as published; the agreement and the Privacy Policy govern.

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