Last updated: 9 October 2026

This Data Processing Agreement (“DPA”) forms part of the Terms and Conditions between 77Labs (Tomasz Gorski, trading as 77Labs, “we”) and the business that subscribes to Autopilot (“you”). It applies whenever we process personal data on your behalf, and it is designed to meet Article 28 of the UK GDPR.

1. Roles

For personal data about your customers, leads, contacts and staff that you put into or collect through Autopilot (“Customer Personal Data”), you are the controller and we are your processor.

2. Details of the processing

3. Our obligations

We will:

4. Sub-processors

You give us general authorisation to use sub-processors. Our current sub-processors are:

Sub-processor Purpose Location
HighLevel Inc. (LeadConnector) Platform hosting, CRM, messaging, phone, AI features USA
Carriers and AI providers engaged by HighLevel Delivery of calls, SMS, and AI responses USA / various
Mailgun Technologies Email delivery USA / EU
Stripe Payments you take from your own customers through Autopilot (if enabled) USA / EU

We will give you at least 30 days’ notice by email before adding or replacing a sub-processor. If you object on reasonable data protection grounds and we cannot resolve it, you may cancel without penalty. We impose data protection obligations on each sub-processor that are no less protective than this DPA, and remain responsible for them.

5. International transfers

Customer Personal Data may be transferred to the USA and other countries where our sub-processors operate. Where this happens we rely on adequacy regulations (including the UK Extension to the EU-US Data Privacy Framework) or the UK International Data Transfer Addendum to the European Commission’s Standard Contractual Clauses.

6. Security

7. Personal data breaches

We will notify you without undue delay, and in any case within 48 hours, after becoming aware of a personal data breach affecting Customer Personal Data, and give you the information you reasonably need to meet your own obligation to report to the ICO within 72 hours.

8. Your obligations

You are responsible for having a lawful basis for the data you put into Autopilot and for the messages you send, for giving your customers the privacy information they need (including that calls may be recorded or answered by an AI assistant), and for complying with PECR when sending marketing.

9. Deletion and return

When your subscription ends you can export your data for 30 days. After that we will delete Customer Personal Data, unless the law requires us to keep it. Backups held by our sub-processors are deleted on their normal cycle.

10. General

If this DPA conflicts with the Terms and Conditions on a data protection matter, this DPA wins. It is governed by the law of England and Wales.