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Sub-processors

Last updated: 28 July 2026

The third parties that may process personal data on our behalf, what they do, and where. This is the list referred to in our Data Processing Agreement.

We publish this in full rather than summarising it. A data protection officer reviewing us should be able to check this page against what they can observe, and find no surprises.

ProviderWhat it doesWhere
SupabaseDatabase and file storage (the CRM itself)EU — Paris, France
VercelApplication hosting and serverless computeEU — Paris (cdg1); company US-based
UpstashRate limiting (IP addresses only)EU
DeepSeek
Customers requiring EU-only processing can be moved to Mistral (France) on request.
Generates assistant replies. Receives the message content and the surrounding conversation.China
Outside the EEA — SCCs apply
Mistral AI
Used only when selected for the account.
EU alternative for generating assistant repliesEU — France
OpenAI
Used only when selected for the account.
Alternative model, and speech transcriptionUnited States
Outside the EEA — SCCs apply
Google (Gemini)
Used only when selected for the account.
Alternative model and image generationUnited States
Outside the EEA — SCCs apply
Anthropic
Used only when selected for the account.
Alternative modelUnited States
Outside the EEA — SCCs apply
Meta Platforms (Facebook, Instagram, WhatsApp)
Only when the customer connects those channels.
Delivers and receives messages and comments on the customer's own connected accountsUnited States / global
Outside the EEA — SCCs apply
Twilio
Only when the customer connects SMS/WhatsApp via Twilio.
WhatsApp and SMS deliveryUnited States / EU
Outside the EEA — SCCs apply
Telegram
Only when the customer connects Telegram.
Message delivery on TelegramOutside the EEA
Outside the EEA — SCCs apply
ResendTransactional email deliveryUnited States / EU
Outside the EEA — SCCs apply
Vapi
Only when voice calling is enabled.
AI voice calls — audio, recordings and transcriptsUnited States
Outside the EEA — SCCs apply
ElevenLabs
Only when voice replies are enabled.
Speech synthesis for voice repliesUnited States
Outside the EEA — SCCs apply
AssemblyAI / Groq
Only when voice notes are used.
Speech-to-text transcriptionUnited States
Outside the EEA — SCCs apply
CloudinaryImage and video hosting and transformationUnited States / EU
Outside the EEA — SCCs apply
Creatomate
Only when video generation is used.
Video renderingEU — Netherlands
fal.ai / Kling / Runway / HeyGen
Only when video generation is used. Listing media only — not lead data.
AI video generation from listing photosUnited States / global
Outside the EEA — SCCs apply
StripeSubscription billing (customer account holders only, not their leads)United States / EU
Outside the EEA — SCCs apply
Google (OAuth, Maps, Places/Reviews)Sign-in, map display, review syncUnited States
Outside the EEA — SCCs apply
TikTok / YouTube
Only when the customer connects those channels.
Publishing to the customer's own connected social accountsUnited States / global
Outside the EEA — SCCs apply
Orgo
Only for accounts with an automation VM.
Hosted automation workers for scraping and scheduled jobsUnited States
Outside the EEA — SCCs apply

EU-only processing

Several providers above operate outside the EEA, and the default AI model (DeepSeek) processes data in China. Customers who require personal data to stay within the EU can ask us to configure their account accordingly — principally by switching the AI model to Mistral AI (France) and leaving optional channels disconnected. Write to partners@my5thstar.com.

Changes to this list

We notify customers by email at least 30 days before adding a sub-processor that handles personal data, so there is time to object as set out in the Data Processing Agreement.