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Sub-processors

The companies Elara One uses to host and run the service, what each one does, the data it handles and where.

Last updated

Draft — under legal review. This is a working draft. It may change before it takes effect, and the values marked in brackets are still to be confirmed.

In short

These are the companies that help us run Elara One and may handle personal data from your store.

Your store runs in London, on UK servers. Encrypted backups are kept in the EU, and Cloudflare, which stores them, cannot read them.

We give notice before adding a new one. Email [email protected] to be told.

About this list

Elara One is a trading name of Elara Labs Ltd, a company registered in England and Wales with company number 17541993, whose registered office is at 128 City Road, London, United Kingdom, EC1V 2NX.

A sub-processor is a company we engage to process personal data on behalf of our customers. Each is bound by a written contract that limits what it may do and requires it to keep data secure, as our data processing agreement requires. We use the same companies for our own business data, as our privacy notice explains.

Where your data lives

Your store's application, database, search index and cache run in London, on UK servers hosted by Vultr. Nightly backups are encrypted on our servers before they leave them and kept for 14 days in Cloudflare R2 storage with EU jurisdiction; Cloudflare stores them but does not have the key. A separate encrypted copy for recovery to a point in time is kept in UK storage.

In use today

Sub-processors in use today

Sub-processor
Vultr
What they do
Hosts the application, the store databases, search and cache.
Data
Everything the service holds for a store.
Location
London, United Kingdom
Sub-processor
Cloudflare
What they do
Network protection, DNS and the content delivery network. Stores public catalogue images (no personal data) and the nightly encrypted database backups. Runs the Turnstile spam check on our own forms.
Data
Encrypted backups, which Cloudflare cannot read; technical request data.
Location
Backups: EU. Network: global
Sub-processor
Stripe
What they do
Card payments on each store's own Stripe account, and the billing of our own subscriptions.
Data
Payment details, order amounts and status; for billing, our customers' billing contacts.
Location
United States and EU
Sub-processor
PayPal
What they do
Storefront payments, when a store offers PayPal.
Data
Payment details, order amounts and status.
Location
Outside the UK
Sub-processor
Mailgun
What they do
Platform emails (invitations, password resets, billing and usage notices), and store emails until a store's own sending domain is set up.
Data
Recipient email addresses and message content.
Location
EU
Sub-processor
Twilio
What they do
Text messages for the inbox.
Data
Phone numbers and message text.
Location
Outside the UK
Sub-processor
HubSpot
What they do
Syncing leads and customers, only when a store connects its HubSpot account.
Data
Contact details and contact properties.
Location
The region of the store's HubSpot account

Planned, not in use yet

These are ready for features that are not live. None of them processes customer data today. We will give notice, as described below, before any of them starts.

Planned sub-processors

Sub-processor
Amazon Web Services EMEA SARL (Amazon SES, SNS and EventBridge)
What they will do
Sending a store's email from its own domain, and reporting delivery, bounces and complaints. Coming soon.
Data
Recipient email addresses, message content and delivery events.
Location
London, United Kingdom
Sub-processor
Vapi
What they will do
AI voice calls for lead follow-up. Coming soon.
Data
Phone numbers, call transcripts and call records.
Location
Outside the UK
Sub-processor
Backblaze (B2)
What they will do
A nightly copy of encrypted private files, once file uploads launch. Planned.
Data
Encrypted files only, which Backblaze cannot read.
Location
EU (Central)

Services a store chooses itself

A store can connect services under its own accounts and terms. Those companies work for the store, not for us, so they are not our sub-processors. The store should name them in its own privacy notice. They include:

  • Google Analytics 4, Google Ads, Meta and Microsoft Advertising, when the store connects its own accounts. Anything sent to them waits for the shopper's consent.
  • Google (Gmail and Google Calendar) and Microsoft (Outlook and Microsoft 365), when a member of staff connects their own or a shared mailbox. How we use that data is in our privacy notice.
  • A store's own Mailgun account, if it chooses to send its email that way.
  • Cloudflare Turnstile on a store's own forms, using the store's own keys.
  • The browser's own speech recognition, if a store switches on voice search.

Transfers outside the UK

Where a sub-processor handles personal data outside the UK and the EU, we rely on appropriate safeguards such as the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or the UK–US data bridge where the company is certified.

Changes and notice

We update this page before a new sub-processor starts handling customer data, and change the date at the top. Customers who ask to be told get an email at least [30 days] before the change. To be added, email [email protected] with the subject "Sub-processor updates".

If you object to a new sub-processor on reasonable data protection grounds, tell us within the notice period. The data processing agreement explains what happens next.