Sub-Processors
The named sub-processors we engage to deliver the SignalLine AI service. Last reviewed 29 September 2026.
This page lists the sub-processors Sparkline Consulting Ltd(“we”, “us”) engages to deliver the SignalLine AI services. We notify customers at least 30 days before adding or replacing a sub-processor in a way that affects their data, in line with UK GDPR Article 28(2) and our customer Data Processing Agreement.
This page is incorporated by reference into our customer Data Processing Agreement (Schedule B) as the current sub-processor list. Where a customer’s signed agreement points to “the current list at 11-sub-processors.md”, this page is that list’s public mirror and is kept in step with it.
Telephony
| Sub-processor | Service | Country | Transfer mechanism | DPA |
|---|---|---|---|---|
| Telnyx LLC | SIP trunking that places and receives calls, phone-number provisioning, and call-detail-record export. | United States | UK Addendum to the EU Standard Contractual Clauses | Telnyx DPA |
AI / NLP
| Sub-processor | Service | Country | Transfer mechanism | DPA |
|---|---|---|---|---|
| Deepgram, Inc. | Speech-to-text and voice-agent orchestration during calls; text-to-speech for English and Spanish. | EU endpoint for the AI receptionist and portal voice agents; United States endpoint for survey calls using our classic transcription path. | None currently in place | No published DPARequested; not yet in place. |
| Anthropic, PBC | The language model behind the AI receptionist during calls, post-call summarisation of call transcripts, and the chat widget on this website. | United States | UK Addendum to the EU Standard Contractual Clauses | Anthropic DPA |
| OpenAI, LLC | Speech-to-text (the default transcription provider for survey calls) and text embeddings for knowledge-base search. | United States | UK Addendum to the EU Standard Contractual Clauses | OpenAI DPA |
| Groq, Inc. | A low-latency language model available as an alternative survey-call brain. | United States | EU Standard Contractual Clauses / UK GDPR terms in the Groq DPA | Groq DPA |
| Gladia SAS | A speech-to-text option for survey calls, selectable per campaign. | France (EU) | Within the UK adequacy area for the EU | Gladia DPARequires separate acceptance; acceptance not yet verified. |
| ElevenLabs, Inc. | Text-to-speech for 13 of the 15 languages offered on the AI receptionist. | United States | UK Addendum to the EU Standard Contractual Clauses | ElevenLabs DPA |
| Cartesia, Inc. | Text-to-speech for outbound survey campaigns. | United States | UK Addendum to the EU Standard Contractual Clauses | Cartesia DPA |
Hosting & infrastructure
| Sub-processor | Service | Country | Transfer mechanism | DPA |
|---|---|---|---|---|
| DigitalOcean, LLC | Cloud hosting for our databases and application servers. Also stores survey-campaign call recordings, for the period a customer has recording enabled, encrypted at rest. | EU region (chosen) | Within the UK adequacy area for the EU; UK Addendum to the EU SCCs for any US fall-back | DigitalOcean DPA |
Billing
| Sub-processor | Service | Country | Transfer mechanism | DPA |
|---|---|---|---|---|
| Stripe Payments Europe, Ltd. / Stripe Payments UK, Ltd. | Subscription billing and metered per-minute usage for portal customers — account owner's email, billing details, and call-minute counts. Card details go to Stripe directly and are never held by us. | Ireland / United Kingdom | Within the UK adequacy area for the EU; UK Addendum to the EU SCCs for onward US transfers | Stripe DPAStripe acts as an independent controller for payment processing and as our processor for the billing data we send it. |
Domain & operational tooling
| Sub-processor | Service | Country | Transfer mechanism | DPA |
|---|---|---|---|---|
| Zoho Corporation B.V. | Mailbox hosting and mail routing for signalline.io. | Netherlands (EU) | Within the UK adequacy area for the EU | Zoho GDPR termsIn-account DPA signature pending. |
| Resend Group, Inc. | Transactional email — contact-form lead notifications and operational call-summary notifications. | United States | UK Addendum to the EU Standard Contractual Clauses | Resend DPA |
| Plausible Insights OÜ | Privacy-focused website analytics for signalline.io — no cookies, no cross-site tracking. | Estonia (EU) | Within the UK adequacy area for the EU | Plausible DPA |
| Telegram FZ-LLC / Telegram Group Inc. | An operational notification channel that receives a caller's phone number and a one-sentence call summary. We are removing this channel — see the note below. | United Arab Emirates / British Virgin Islands | None available | No DPA exists for the Telegram Bot API |
Telegram is being removed, not disclosed indefinitely. Telegram offers no data processing agreement and no transfer mechanism for its Bot API, so we are removing it as a notification channel rather than continuing to send caller-derived data to it. The same notification is already delivered by email through Resend. Until the removal ships, it is listed here rather than hidden.
Not sub-processors
For completeness, because they are sometimes assumed to be:
- Porkbun, LLC — our domain registrar. It handles Sparkline Consulting Ltd’s own registrant details under ICANN obligations, as a controller in its own right. It never receives caller or customer personal data.
- X (formerly Twitter) — we post to our own company account from our own marketing tooling. X is an independent controller for its own platform data. No caller or customer personal data is sent to it.
Notification policy
When we plan to:
- Add a new sub-processor that will process customer personal data, or
- Replace an existing sub-processor with one that materially changes the data flow (jurisdiction, data category, retention),
we will notify customers at least 30 days before the change takes effect, by email to the customer’s named contact and by updating this page.
Customers may object to the change in writing within the notification window. If we cannot offer an alternative that meets the customer’s reasonable objection, the customer may terminate the affected services without penalty, as set out in their Data Processing Agreement.
How to verify a transfer mechanism
For each sub-processor in the United States, we rely on the UK Addendum to the EU Standard Contractual Clauses (Module Two — Controller to Processor) issued by the ICO, as incorporated into that sub-processor’s data processing agreement. A transfer impact assessment (TIA) accompanies each. We are happy to share a redacted copy of any TIA on request to dmitri.dolgorukov@signalline.io.
Changes to this page
We may update this page from time to time as our sub-processors change. The date at the top reflects the most recent review. See our Privacy Policy for how we handle personal data more broadly.