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Legal

Sub-processor Disclosure

Last updated: June 2026 · Next review: June 2027 · Read time: 4 min · Version 1.0

TL;DR. Eight sub-processors. UK or EU resident for hosting, email, CRM, and payments — Stripe routes some fraud-prevention data through US infrastructure under a UK IDTA Addendum. We notify clients of new sub-processors at least 30 days before adding them, by email to the address on file. This is the canonical disclosure referenced by our DPA Article 28 §7 and the EU-sovereignty narrative on /compliance.

1. What this page is

Under UK GDPR Article 28(2), a processor that engages another processor (a "sub-processor") must do so only with the prior written authorisation of the controller. This page is that authorisation in published form — by entering or maintaining a subscription with UK Web Marketing, you authorise the sub-processors listed below. It is also the canonical reference that any signed DPA between us points to.

2. The list

Sub-processor Role Residency Data category Transfer safeguard
Vercel Inc. Static hosting + CDN + edge functions United Kingdom — London region lhr1 Page renders, server logs (IP, user-agent), first-party Analytics + Speed Insights telemetry DPA + UK IDTA Addendum (for any US support routing); ISO 27001 + SOC 2 Type II
Cloudflare, Inc. DNS + inbound email routing + CDN edges European Union + United Kingdom edge POPs DNS queries, inbound email forwarded to our mailbox DPA + UK IDTA Addendum; ISO 27001
Resend, Inc. Outbound transactional + newsletter email European Union (EU region) Recipient email, message content, send/open metadata DPA; EU-resident infrastructure by selection
Stripe Payments Europe Ltd. Subscription billing + fraud prevention Republic of Ireland Cardholder data (held by Stripe, not us), email, billing address DPA + UK IDTA Addendum (for global fraud network); PCI DSS Level 1
Capsule CRM (Zestia Ltd.) CRM (Growth Engine + Bespoke tiers only) United Kingdom (Manchester, UK-hosted) Client + lead contact records DPA; UK data controller
Plausible Analytics Analytics (only on client sites that opt in) European Union (Germany) Aggregated, anonymised visit counts — no personal data DPA; cookieless by design; not used on ukwebmarketing.com itself
Plain Helpdesk (Bespoke tier bolt-on) United Kingdom (London-based) Support tickets, message content, end-user email DPA; UK data controller
Proton Mail Real mailboxes (£15/inbox/mo bolt-on, any tier) Switzerland Email content for named mailboxes DPA; Swiss data-protection adequacy (UK and EU recognised)

3. International transfers

Our default architecture keeps personal data on UK or EU infrastructure. Three vendors routinely operate global networks: Cloudflare (DNS + edge), Stripe (fraud prevention), and Vercel (support routing). For each, transfers outside the UK and EEA are protected by the UK International Data Transfer Agreement / Addendum to the EU SCCs (or an equivalent safeguard — UK adequacy regulations where they exist).

Proton Mail is Swiss-resident. The UK recognises Switzerland under adequacy regulations — no IDTA needed.

4. Notification of changes

Before we add a new sub-processor that will process your personal data, we will give you at least 30 days' written notice by email to the address on file. The notice will include the sub-processor's name, role, residency, data category, and transfer safeguard. You may object on reasonable data-protection grounds within that window; if we can't accommodate your objection, you may terminate the subscription with a pro-rata refund of any prepaid Fees covering the period after termination.

To subscribe to sub-processor change notifications without being a current client, email hello@ukwebmarketing.com with the subject "Subscribe to sub-processor changes".

5. Audit + verification

Each sub-processor listed above has a Data Processing Agreement in place with us; we hold copies of their published security certifications (ISO 27001, SOC 2, PCI DSS) where applicable. Clients on Growth Engine and Bespoke tiers may request copies of the signed DPAs we hold — email hello@ukwebmarketing.com and we'll respond within 5 working days.

6. Related documents

Data Processing Agreement · Privacy Policy · Cookie Policy · EU-sovereign compliance posture · All legal documents

7. Changelog

  • v1.0 — 2026-06-03 — promoted from a section of /compliance to a standalone canonical disclosure, with transfer safeguards added per-vendor.
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