Bulkgate Integration

Privacy Policy
Effective date: 3 July 2026 | Last updated: 3 July 2026

1. Introduction

Welcome to Bulkgate Integration (the "Service"), a GoHighLevel Marketplace application. We are committed to protecting your personal data in compliance with the UK GDPR, the EU GDPR (2016/679), and applicable data-protection legislation. This Privacy Policy explains what data we collect, why we collect it, how we protect it, and what rights you have.

2. Data Controller

Company name	Mindful Momentum Ltd
Registered address	Hova House, 1 Hova Villas, Brighton & Hove, BN3 3DH, United Kingdom
Company number	14864005
UTR	61309 15915
Support email	ghladmins@gmail.com
Hungarian business address	Weiner Leó utca 4., 1066 Budapest, Hungary
Hungarian phone	+36 20 515 1514

3. What is Bulkgate Integration?

Bulkgate Integration is a GoHighLevel Marketplace application that acts as an SMS Conversation Provider: it delivers outbound SMS messages sent from a subscriber's GoHighLevel (GHL) sub-account through the subscriber's own Bulkgate account, and returns inbound SMS replies and delivery status reports back into the GHL Unified Inbox. Each subscriber connects and pays for their own Bulkgate account directly (pay-as-you-go); the Service does not process or resell SMS credit.

4. Data Processors

Processor	Role	Location
HighLevel Inc. (GoHighLevel)	CRM, Conversations/Unified Inbox	USA
TOPefekt s.r.o. (Bulkgate)	SMS delivery, using the subscriber's own Bulkgate account	EU
Railway Corp.	Application hosting	USA

All sub-processors are bound by GDPR-compatible Data Processing Agreements. Transfers to the USA are covered by Standard Contractual Clauses (SCCs) and/or the EU–US Data Privacy Framework.

5. Personal Data We Process

SMS message data: recipient/sender phone numbers, message text content, delivery timestamps and status — passed through between GHL and Bulkgate.
GoHighLevel contact data: contact name, phone number, and conversation history relevant to the SMS thread, as stored in the subscriber's GHL sub-account.
Subscriber account data: GHL location ID, OAuth access/refresh tokens (Fernet-encrypted at rest), Bulkgate Application ID and token (Fernet-encrypted at rest, provided by the subscriber).
Technical data: IP addresses, API request logs, error logs — retained for security and debugging.

6. Legal Basis and Purpose

Purpose	Legal basis (GDPR Art. 6)
Delivering SMS via the subscriber's Bulkgate account	Contract performance — Art. 6(1)(b)
OAuth authentication and token management	Contract performance — Art. 6(1)(b)
Security, fraud prevention, debugging	Legitimate interest — Art. 6(1)(f)
Legal and regulatory compliance	Legal obligation — Art. 6(1)(c)

7. Retention Periods

Active installation: data is retained for the duration of the active GHL installation.
Post-uninstall: account data and encrypted credentials are deleted within 90 days of uninstall.
Security / audit logs: up to 12 months.
OAuth & Bulkgate tokens: deleted immediately upon uninstall or revocation.

8. Your Rights

Under the UK GDPR and EU GDPR you have the right to access, rectify, erase, restrict, port, and object to the processing of your data, and to withdraw consent where processing is based on consent. To exercise any of these rights, contact us at ghladmins@gmail.com. We will respond within 30 days.

9. Cookies

The Bulkgate Integration web application uses strictly necessary session cookies for OAuth state verification only. No marketing or analytics cookies are set by the Service itself.

10. Security

TLS encryption on all data in transit.
OAuth and Bulkgate API tokens encrypted at rest using Fernet symmetric encryption.
Access controls: only authorised personnel and automated systems access production data.
Data breach notification within 72 hours of discovery where required by law.

11. Children's Privacy

The Service is not directed at individuals under the age of 16. We do not knowingly collect personal data from children.

12. Supervisory Authority

If you believe our data processing violates applicable law, you may lodge a complaint with the UK Information Commissioner's Office (ico.org.uk), the Hungarian NAIH (naih.hu), or your local Data Protection Authority.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via a notice on this page at least 15 days before taking effect.

14. Contact

Mindful Momentum Ltd
Email: ghladmins@gmail.com
Hungarian phone: +36 20 515 1514
Address: Hova House, 1 Hova Villas, Brighton & Hove, BN3 3DH, United Kingdom