Sub-Processors
Every company that may touch the personal data in your account, what it does, and where it processes it. No exceptions and no small print.
What This Page Is
When you use the NotLuck CRM platform, you are the data controller and we are your data processor. To deliver the service we rely on other companies, and under UK GDPR those are your sub-processors too. This page names them.
It is referenced by our Data Processing Agreement, which sets out what we owe you and what happens when this list changes.
Not every client uses every service below. A company only processes your data if you use the feature it powers. If you never send an SMS, Twilio never sees anything of yours.
These companies have been part of the Platform since our Terms took effect on 31 July 2025. This page was first published on 12 August 2026 to set the list out in one place, and we date every change to it from here on.
1. Platform and Hosting
These underpin the CRM itself, so they apply to every client.
- HighLevel, Inc.
- CRM platform provider. United States.
- LeadConnector LLC
- Communication services and support, affiliate of HighLevel. United States.
- HighLevel India
- Platform services and support. India.
- Google Cloud Platform
- Data storage and hosting. United States.
- Amazon Web Services
- Data storage and hosting. United States.
2. Communications
Used when you send messages from your account.
- Twilio
- SMS and voice. United States.
- Mailgun
- Email delivery. United States.
- Meta Platforms
- WhatsApp messaging. United States.
3. Payments
- Stripe
- Payment processing. United States.
- Chargebacks911
- Payment dispute handling. United States.
4. AI Features
These process data only if you switch on and use an AI feature.
- OpenAI
- AI provider. United States.
- BotPress
- AI provider. United States.
- RetellAI
- Voice AI provider. United States.
- Synthflow
- Voice AI provider. United States.
On AI and Your Data
- We do not use your data to train AI models, and we do not permit our suppliers to do so on our instruction
- AI features are opt-in. Nothing is processed by an AI provider unless you have turned that feature on
- If you process health data or other special category data, speak to us before enabling AI features so we can configure them properly
5. Supporting Services
Used by the platform provider for support, analytics and account security.
- Freshworks
- Customer support and communication. United States.
- Zapier
- Workflow automation, where you connect it. United States.
- Pendo
- Product analytics. United States.
- ChartMogul
- Subscription analytics. United States.
- Mozart Data
- Data analytics. United States.
- People Data Labs
- Analytics. United States.
- Persona Identities
- Identity verification. United States.
The platform provider maintains its own current list at gohighlevel.com/sub-processors, and you can subscribe there to be notified when it changes.
6. NotLuck's Own Suppliers
These handle data we hold about you as our client, such as our website, our billing and our correspondence with you. They are covered by our Privacy Policy rather than by the Data Processing Agreement.
- Netlify
- Website hosting. United States.
- Stripe
- Our subscription billing. United States.
- Google Workspace
- Our email and documents. United States and European Union.
7. Where Data Is Processed
The CRM platform processes and stores data in the United States. There is no UK or EU hosting option. We would rather tell you that plainly than let you assume otherwise.
Transfers outside the UK are covered by the Standard Contractual Clauses together with the UK International Data Transfer Addendum, and by the UK Extension to the EU-US Data Privacy Framework where the recipient is certified under it. The Information Commissioner's Office is the competent supervisory authority. Full detail is in section 8 of the Data Processing Agreement.
8. Changes and Objections
We will give you at least 30 days' notice by email before we add or replace a sub-processor that handles your data.
If you object on reasonable data protection grounds, email hello@notluck.co.uk within that period. We will work with you to find a solution, and if there is not one, you may end the affected part of the service without penalty and get back any fees paid in advance for the unused period.
This page is the current list. We date every change at the top.