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I think your understanding of 'proactively' might just be different from parent's (and mine).

I'd agree that entities that provide their users' data upon a simple request, and a carveout in regulations that allows (not forces) them to do so, fits the definition of proactive.

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Let's not get all Humpty Dumpty here. "Upon request" is reactive by definition. "Proactive" sharing would quite literally mean sharing on one's own initiative.

It's proactive in the sense that it's shared before a valid warrant is issued for the information, and before they have any reason to do so. But is reactive to any request at all, sure.

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