Sub-processor List
Effective date: 2026-06-01 · Last updated: 2026-10-02
Schedule to the Data Processing Agreement
This Sub-processor List forms a schedule to the Data Processing Agreement ("DPA") between Tourbox Systems Limited (company number 15613075), registered at 125 Freshfield Road, Brighton, England, BN2 0BR ("Tourbox", "we", "us") and the Customer ("you", "Controller").
Capitalised terms not defined here have the meanings given in the DPA.
AI assistants that an operator connects to Tourbox themselves (for example over MCP) act as that operator's own processor and are not Tourbox sub-processors.
Current Sub-processors
The following sub-processors are authorised to process personal data on behalf of Tourbox in connection with the provision of the platform:
Core Platform Infrastructure
| Sub-processor | Purpose | Data Processed | Location |
|---|---|---|---|
| Hanko (Hanko GmbH) | Passwordless authentication | Email addresses, user identity, WebAuthn credentials | 🇪🇺 EU |
| Northflank (Northflank Ltd) | Infrastructure hosting (API, workers, database, Redis, monitoring) | All platform data | 🇬🇧 UK |
| OVHcloud (OVH Groupe SAS) | Object storage (uploaded media, generated PDFs, attachments) | Traveller media, documents, passport images, attachments | 🇬🇧 UK (London) |
| Scaleway (Scaleway SAS) | Encrypted off-site backups | Client-side encrypted backup ciphertext only | 🇫🇷 EU (France) |
| Cloudflare (Cloudflare, Inc.) | CDN, Pages hosting, DNS, Turnstile bot protection, map tiles (transit and edge caching, no processing) | Static assets, cached media renders and video, map tiles, IP addresses, form metadata | 🌍 Global |
| Paddle (Paddle.com Market Ltd) | Subscription billing, invoicing, tax compliance (Merchant of Record) | Billing data, organisation details, payment information | 🇬🇧/🇺🇸 UK/US |
Platform data is hosted in the United Kingdom, and uploaded files are stored in OVHcloud's UK region, in London. OVH Groupe SAS is incorporated in France, which is where the contract sits, but the files themselves stay in the United Kingdom. For customers in the EEA, transfers to the UK are covered by the European Commission's UK adequacy decisions, so no standard contractual clauses are needed.
Error monitoring is performed by a self-hosted error-tracking service running on Tourbox's own Northflank (UK) infrastructure; it is not a separate third-party sub-processor, and personal data in error reports is disabled by default.
Email and SMS Delivery
| Sub-processor | Purpose | Data Processed | Location |
|---|---|---|---|
| Sinch (incl. Mailgun) | Outbound email delivery; SMS sending and receiving | Email addresses, email content, phone numbers, text message content | 🇪🇺 EU (api.eu.mailgun.net, eu.sms.api.sinch.com) |
Where a member of an organisation connects their own Gmail or Microsoft mailbox, email they compose is sent through that provider instead (see Operator-Initiated Integrations). SMS is sent and received from a dedicated number Tourbox itself rents on its own Sinch account for the organisation; the organisation does not hold or configure any Sinch credentials.
AI Providers
| Sub-processor | Purpose | Data Processed | Location |
|---|---|---|---|
| Mistral AI (Mistral AI SAS) | Text generation, document OCR, classification, voice dictation transcription (default) | Document content, itinerary/booking text, dictation audio | 🇪🇺 EU |
| Jina AI / Elastic | Text and image (multimodal) embeddings | Text and image content submitted for search | 🇪🇺 EU |
Tourbox processes UK/EU customer personal data only through EU-based AI sub-processors (Mistral AI and Jina AI). Web-search tooling used by the AI assistant receives only generic, non-identifying queries (no customer names, emails, booking references, or other personal data) and therefore does not process personal data on the Customer's behalf.
Media Processing
| Sub-processor | Purpose | Data Processed | Location |
|---|---|---|---|
| fal.ai (FAL AI, Inc.) | AI image editing | Image media | 🇺🇸 US |
| RunPod (RunPod, Inc.) | GPU vision (object detection, captioning, alt-text) and image upscaling, EU data centres only | Image media | 🇺🇸 US |
| Black Forest Labs (Black Forest Labs GmbH) | AI image editing (EU endpoint only; being introduced) | Image media | 🇪🇺 EU |
These media sub-processors process uploaded photos (which may contain images of identifiable individuals). US vendors are engaged under a Data Processing Agreement with appropriate transfer safeguards (UK IDTA / EU SCCs). Image upscaling runs on RunPod's EU data centres; we are moving AI image editing to Black Forest Labs, with EU-only processing. fal.ai remains engaged until that migration completes. Video files are processed on our own UK infrastructure.
Maps & Geocoding
| Sub-processor | Purpose | Data Processed | Location |
|---|---|---|---|
| MapTiler (MapTiler AG) | Maps, geocoding | Location queries, coordinates | 🇨🇭 EU-adequate (CH) |
Web Analytics
| Sub-processor | Purpose | Data Processed | Location |
|---|---|---|---|
| Umami (Umami Software, Inc.) | Privacy-first usage analytics on public traveller pages | Page URL, referrer, browser and device type, derived country. No cookies; IP addresses are hashed and not retained | 🇪🇺 EU (Germany) |
Umami sets no cookies and does not identify individual visitors, so no consent banner is shown. It is used only to understand how our public pages are used, never for advertising.
Operator-Initiated Integrations
These sub-processors are only engaged when an authorised operator within the Customer's organisation explicitly connects the relevant integration:
| Sub-processor | Purpose | Data Processed | Location |
|---|---|---|---|
| Vamoos (Vamoos Ltd) | Sync itineraries / travel documents to the Vamoos traveller app | Traveller itineraries and documents | 🇬🇧 UK |
| Xero (Xero Limited) | Accounting sync (supplier invoices, payments) | Supplier and financial transaction data | 🇦🇺 AU/Global |
| Slack (Salesforce, Inc.) | Notifications posted to the operator's workspace | Notification / event-summary content | 🇺🇸 US |
| Google Ads (Google LLC) | Offline conversion upload | Advertising click identifiers, conversions | 🇺🇸 US |
| Microsoft Ads (Microsoft Corporation) | Offline conversion upload | Advertising click identifiers, conversions | 🇺🇸 US |
| Meta Ads (Meta Platforms, Inc.) | Offline conversion upload; WhatsApp Business Platform message delivery (operators who connect WhatsApp) | Advertising click identifiers, conversions; traveller phone numbers, names and message content (stored in the local storage region the operator's number was registered with, ordinarily the EU (Germany); numbers already registered before connecting keep their existing region) | 🇺🇸 US |
| Felloh (Felloh Ltd) | Payment processing (card / open banking) and reconciliation | Customer name, email, travel dates, booking reference, payment amounts | 🇬🇧 UK |
| HubSpot (HubSpot, Inc.) | CRM synchronisation (contact and deal sync) | CRM contact records once sync is enabled; connection credentials only until then | 🇺🇸 US |
| Duffel (Duffel Technology Ltd) | Flight availability search via the operator's own Duffel account | Routes, travel dates, passenger counts and ages (no names or contact details) | 🇬🇧 UK |
Connected Accounts (User-Initiated)
These sub-processors are engaged only when an individual user connects their own account via OAuth:
| Sub-processor | Purpose | Data Processed | Location |
|---|---|---|---|
| Google (Google LLC) | Gmail synchronisation | User mailbox content, identity | 🇺🇸 US |
| Microsoft (Microsoft Corporation) | Outlook / Microsoft Graph mail sync | User mailbox content, identity | 🇺🇸 US |
| Zoom (Zoom Video Communications, Inc.) | Meeting / call data | Meeting data, participant information | 🇺🇸 US |
The Customer (or the relevant user) may disconnect any operator-initiated integration or connected account at any time, at which point data sharing with that sub-processor ceases. No personal data is shared with these sub-processors unless and until the integration is actively enabled.
Some optional integrations do not transmit personal data: stock-image search (Unsplash, Pexels) sends only non-identifying search terms, and the WordPress plugin operates on the operator's own self-hosted site. These are therefore not personal-data sub-processors.
The Felloh Data Processing Agreement is to be confirmed and signed out of band before the payments feature goes live; the entry above is recorded here so the sub-processor list stays complete. The HubSpot integration currently establishes the connection only; no CRM records are exchanged until contact and deal sync is enabled, and the entry above is likewise recorded for completeness.
AI Provider Selection
All AI processing of UK/EU customer personal data is performed by EU-based sub-processors. Text generation, OCR and classification use Mistral AI (France); embeddings use Jina AI (Germany / Elastic). US-based AI providers are not used for customer personal data.
Change Log
- 2026-09-12: corrected the locations given for OVHcloud object storage and Northflank hosting. This page previously said OVHcloud was in France and Northflank in the EU; both have always been in the United Kingdom. Nothing about the hosting or the storage changed, and no sub-processor was added or replaced: only the locations shown here were wrong.
- 2026-09-10: clarified that AI assistants an operator connects to Tourbox themselves (for example over MCP) are the operator's own processor, not a Tourbox sub-processor. No new sub-processor: Tourbox does not select, engage, or pay for the operator's AI vendor, and processes no data through it on the operator's behalf.
- 2026-08-29: widened the Sinch entry (previously "Mailgun (Sinch)", Email Delivery) to cover SMS sending and receiving alongside outbound email. No new sub-processor, since Sinch already processed email on Tourbox's behalf.
Notification of Changes
In accordance with the DPA, Tourbox will provide the Customer with at least 14 days' prior written notice of any intended changes to this Sub-processor List, including the addition or replacement of sub-processors. The Customer may object to such changes as set out in the DPA.
Contact
If you have any questions about this Sub-processor List or our use of sub-processors, please contact us at [email protected].
This Sub-processor List was last updated on the date shown in the page metadata above. See also our Data Processing Agreement.