BulkGate SMS by VoxFlow

Privacy Policy
Effective date: 10 October 2026 | Last updated: 10 October 2026

1. Introduction

BulkGate SMS by VoxFlow (the "Service") is a HighLevel Marketplace application that connects a HighLevel sub-account to the subscriber's own BulkGate account for sending and receiving SMS. This Privacy Policy explains what personal data the Service handles, in which role, for how long, and what rights people have. It is written to comply with the UK GDPR and the EU GDPR (2016/679).

2. Who We Are

Company nameMindful Momentum Ltd, trading as VoxFlow
Registered addressHova House, 1 Hova Villas, Brighton & Hove, BN3 3DH, United Kingdom
Company number14864005
Contact emailbulkgate@voxflow.hu
Trading nameVoxFlow (voxflow.hu)
Product nameBulkGate SMS by VoxFlow

3. Our Two Roles

Processor. The business that installs the Service (the "Subscriber", usually an agency or its client) decides whom it messages and why. For the phone numbers, messages and opt-out status of the people it messages, the Subscriber is the data controller and we act as its data processor, under our Data Processing Addendum. If you received an SMS through the Service and want to exercise your rights, please contact the business that messaged you; we will help them respond.

Controller. For the Subscriber's own account data (which sub-account installed the Service, its access tokens and BulkGate API credentials) and for our technical logs, Mindful Momentum Ltd is the data controller.

4. What Data the Service Handles

DataWhat we keepHow long
Message content (text of outbound and inbound SMS) Passed through between HighLevel and BulkGate. Not stored by the Service. —
Message references HighLevel and BulkGate message IDs and delivery status, used to report delivery back. No phone number, no text. 400 days
Opt-out list A keyed cryptographic hash (HMAC) of the phone number of each person who replied STOP (or an equivalent keyword), per sub-account, so that they are not messaged again. The number itself is not stored in this list. Also added when the Subscriber turns on SMS do-not-disturb for a contact; removed when the person replies START or the Subscriber turns do-not-disturb off. Until the opt-out is lifted, or the Service is uninstalled from that sub-account
Opt-out history When an opt-out or opt-in happened and through which channel (SMS keyword or the Subscriber's do-not-disturb setting), with the same hashed number. Kept so the Subscriber can show when consent was withdrawn. Until the Service is uninstalled from that sub-account
Duplicate-protection keys One-way hashes of incoming events, so a retried webhook is not processed twice. 30 days
Pending delivery reports A delivery report that arrived before its message reference; message ID and status only. 7 days
Subscriber account data HighLevel location and company IDs; OAuth tokens and the BulkGate Application ID and token, all encrypted at rest (Fernet). Until uninstall
Technical logs Request and error logs. Phone numbers are masked and access tokens removed before logging. Kept by our hosting provider for a limited period, currently up to 30 days
Backups A daily encrypted copy of the database above, for disaster recovery. Each copy is deleted after 30 days

Contact names and conversation history stay in the Subscriber's HighLevel account; the Service does not copy them.

5. Purposes and Legal Basis

PurposeLegal basis
Sending and receiving SMS, reporting delivery status (as processor)On the Subscriber's documented instructions — GDPR Art. 28; the Subscriber determines its own legal basis
Honouring opt-outs (STOP) and opt-ins (START), and mirroring them to the contact's SMS do-not-disturb setting (as processor)On the Subscriber's instructions, enabling it to meet its legal obligations to stop messaging people who object
Managing the installation and the Subscriber's credentials (as controller)Performance of a contract — Art. 6(1)(b)
Security, abuse prevention, debugging, backups (as controller)Legitimate interest — Art. 6(1)(f)

6. Uninstalling and Deletion

When the Service is uninstalled from a sub-account, HighLevel notifies us and we immediately and permanently delete that sub-account's installation, encrypted credentials, message references and opt-out list. The agency-level access token is deleted once no sub-account of that agency has the Service installed. Backup copies containing the deleted data expire within 30 days.

Opt-outs are also recorded as SMS do-not-disturb on the contact in HighLevel and on the Subscriber's BulkGate blacklist; those records remain in the Subscriber's own accounts after uninstall.

7. Sub-processors and International Transfers

Sub-processorPurposeData location
Railway Corp.Application hosting and databaseEU (Netherlands data centre); US company
Cloudflare, Inc. (R2)Daily database backupEU (EU-jurisdiction storage); US company

The following platforms are chosen and contracted by the Subscriber, not by us. The Service only connects them, using the Subscriber's own accounts:

PlatformRoleLocation
HighLevel Inc.The Subscriber's CRM and conversations inbox, where messages are written and readUSA
TOPefekt s.r.o. (BulkGate)SMS delivery through the Subscriber's own BulkGate accountEU (Czech Republic)

Our database and backups are stored in the EU. Railway and Cloudflare are US companies; any access from the USA is covered by the EU Standard Contractual Clauses (with the UK Addendum) and/or the EU–US Data Privacy Framework, as applicable to each provider. Data received from EU Subscribers by Mindful Momentum Ltd in the UK relies on the EU adequacy decision for the United Kingdom.

8. Security

If a personal data breach affects data we process for a Subscriber, we notify that Subscriber without undue delay. For data we control, we notify the competent supervisory authority within 72 hours where required.

9. Your Rights

Under the UK GDPR and the EU GDPR you have the right to access, rectify, erase, restrict, port and object to the processing of your personal data. If you received a message through the Service, the quickest way to stop further messages is to reply STOP. For other requests, contact the business that messaged you (the controller); you may also write to bulkgate@voxflow.hu and we will forward your request to it and assist. For data we control, we respond within one month.

10. Cookies

The Service itself sets no cookies. Its setup page runs inside HighLevel, which applies its own cookie policy.

11. Children

The Service is a business tool and is not directed at individuals under 16.

12. Supervisory Authority

You may lodge a complaint with the UK Information Commissioner's Office (ico.org.uk) or with the data protection authority of the EU country where you live or work.

13. Changes to This Policy

We will announce material changes on this page at least 15 days before they take effect. The "Last updated" date above shows the current version.