Sub-processors
The following sub-processors process personal data on behalf of Booki7 to deliver the service. Except where the table says otherwise, each is bound by a written agreement imposing GDPR Art. 28 obligations equivalent to those Booki7 owes its customers, plus Standard Contractual Clauses where the recipient is outside the EU/EEA.
| Sub-processor | Purpose | Region | Transfer mechanism |
|---|---|---|---|
| Hetzner Online GmbH | Hosting the application server, database, backups | Falkenstein, Germany (EU) | EU — no transfer. Art. 28 data processing agreement in place since 17 August 2026, and Hetzner's technical and organisational measures are audited annually against Art. 32 by TÜV Rheinland |
| Anthropic, PBC | Claude AI — conversation inference, and drafting messages a business sends its own clients | USA | SCCs (Module 2) + Anthropic's commercial terms; data not used for training |
| OpenAI, L.L.C. | Voice-tier text-to-speech, and an optional alternative LLM, where the Voice call tier is enabled | USA | SCCs + OpenAI DPA terms; API data not used for training. Only activated when the Controller enables the Voice call tier |
| Stripe Payments Europe Ltd. | Payment processing for subscriptions | Ireland (EU); some processing transferred to Stripe Inc. (US) | SCCs + Stripe DPA |
| Twilio Ireland Ltd. | WhatsApp + voice telephony when those features are enabled | Ireland (EU); transferred to Twilio Inc. (US) | SCCs + Twilio DPA |
| Sendinblue SAS (trading as Brevo) 17 rue Salneuve, 75017 Paris, France |
Outbound email — booking confirmations, reminders, sign-in and verification codes, aftercare and last-minute availability offers | France (EU) | EU processing — Data Processing Agreement incorporated into the Brevo Terms of Service (Art. 28) |
| Cloudflare, Inc. | Email forwarding (admin@booki7.com) | USA / global edge | SCCs + Cloudflare DPA |
| Meta Platforms Ireland Ltd. | Facebook Messenger inbound/outbound, when Messenger is enabled | Ireland (EU); processing also occurs at Meta Platforms Inc. (US) | SCCs + Meta Business DPA — Controller-side: visitor messages enter via the Controller's Facebook page, which the Controller manages directly |
| Telegram Messenger Inc. group companies: Telegram Group Inc. (British Virgin Islands), Telegram FZ-LLC (Dubai) |
Notifying a business owner that something has happened (a booking, an order, a contact request, or someone waiting to speak to a person), where that owner has linked their own Telegram account. The alert names the type of event and links to the dashboard. It carries no client name, contact details, service or appointment time | Data of EEA and UK users is held in data centres in the Netherlands (EU); group companies in the British Virgin Islands and Dubai | No Art. 28 agreement is available: Telegram offers none to operators of its Bot API. No client personal data is sent over this channel, so none is exposed to that gap. Activated only when the Controller links their own Telegram account, and never otherwise. See the note below |
| Deepgram, Inc. | Speech-to-text (Voice tier only — currently not GA) | USA | SCCs + Deepgram DPA — only activated when the Controller enables Voice |
| Google Ireland Ltd. | Google Calendar integration when the Controller enables it | Ireland (EU); transferred to Google LLC (US) | SCCs + Google Cloud DPA |
Notes
- Voice notes dictated onto a client record are transcribed by speech-to-text software self-hosted on Booki7's own EU server (Falkenstein, Germany): the audio is processed in memory, never leaves the EU, and is not sent to any third-party sub-processor. OpenAI is only an active sub-processor where the separate Voice call tier (OpenAI text-to-speech, with Deepgram) is enabled per-tenant, and only once the Controller turns it on.
- Telegram, listed here on 12 August 2026, and changed on the same day. This corrects an omission rather than announcing a new sub-processor. The Telegram alert channel shipped on 4 June 2026, two days after this page was first published, and the page was not updated at the time. Reviewing it brought a second problem to light: Telegram publishes no Art. 28 data processing agreement for operators of its Bot API, and states that bots are "completely independent from Telegram", so the contractual guarantees Booki7 gives for every other entry in this table were not available here. Until 12 August 2026 these alerts contained the client's name, email address, phone number and any note they left. They no longer contain any of it. The alert now says only what happened, for example "New booking", and links to the dashboard, where the details are reached over an authenticated session as they always were. Nothing about a client is sent to Telegram: not their name, not their contact details, not the service or the time. What remains is the business owner's own Telegram chat identifier, which is the owner's account data rather than their clients', and the fact that an alert was sent. Telegram's Art. 27 representative in the EU is the European Data Protection Office (EDPO), and Telegram states that it relies on European Commission standard contractual clauses for transfers to its group companies. A business that would rather use no third-party messenger at all can simply leave the channel unlinked, or disconnect it in Settings: email and the dashboard carry the same alerts.
- On 10 August 2026 outbound email moved from Amazon SES (AWS Europe, Ireland) to Sendinblue SAS, trading as Brevo, in France. Amazon Web Services EMEA SARL no longer processes any personal data for Booki7 and has been removed from this list. Both are EU processing, so the data-protection position is unchanged; the move was made because Brevo's terms cover the full range of messages Booki7 sends. Sendinblue SAS remains the legal entity — "Brevo" is a trading name adopted in 2023, not a change of company. Notified here per our 30-day notice commitment.
- On 6 July 2026 transactional email moved from SendGrid (Twilio, USA) to Amazon SES in the AWS Europe (Ireland) region. SendGrid no longer processes any personal data for Booki7 and has been removed from this list. This replacement improved the data-protection position (US sub-processor → EU processing), notified here per our 30-day notice commitment.
- For the legal text of the European Commission Standard Contractual Clauses (Decision 2021/914), see eur-lex.europa.eu/eli/dec_impl/2021/914.
How to object to a new sub-processor
If you object to a planned change on reasonable data-protection grounds, email admin@booki7.com within 30 days of the notification. We will work with you to find an alternative; if we can't, you may terminate the affected service without penalty for the remainder of your billing period.