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HighLevel is an all in one US based marketing and CRM platform used by agencies for funnels, email, SMS, calendars, AI agents and white label SaaS. It sets first party cookies on client funnels, captures form and attribution data, and processes personal data in the United States, which triggers GDPR consent and transfer requirements.
HighLevel, also marketed as GoHighLevel, is an all in one marketing and CRM platform built primarily for agencies and resellers. It bundles funnels, websites, email and SMS automation, calendars, pipelines, reputation management, AI assistants and a white label SaaS layer that agencies can resell to their own clients. Because HighLevel sits at the center of lead capture, advertising attribution and customer messaging, it processes a large amount of personal data including names, emails, phone numbers, IP addresses, behavioral events and conversation history.
On funnels, forms and websites built with HighLevel, the platform typically sets first party visitor and session cookies, attribution identifiers, CSRF tokens and form session cookies. Additional pixels can be injected by the agency, such as Meta, Google Ads or TikTok pixels, that fall under the consent regime. Server side webhooks and the HighLevel Conversations module also persist message logs, call recordings and lead data inside the CRM. All of these technologies must be evaluated together when building your consent strategy.
HighLevel LLC is headquartered in the United States and processes personal data on US infrastructure, including AWS and Cloudflare. For European controllers, this triggers Chapter V of the GDPR. Transfers must be covered by Standard Contractual Clauses, and where the relevant sub processor is certified, by the EU US Data Privacy Framework. Controllers should perform a Transfer Impact Assessment, document supplementary measures and update their Records of Processing Activities accordingly.
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The legal basis depends on the use case. Pure CRM functionality requested by the end user, such as booking a calendar slot, creating an account or receiving an order confirmation, can rely on Article 6(1)(b) GDPR contract. Marketing automation, lead scoring, advertising pixels and behavioral analytics rely on Article 6(1)(a) GDPR consent, combined with Article 5(3) of the ePrivacy Directive for any storage or access to information on the user device. Consent must be prior, specific, informed and freely given.
The overall risk level for HighLevel is medium to high. The platform combines identifiers, behavioral data, communication content and AI processing, which can amount to large scale profiling. A Data Protection Impact Assessment is strongly recommended when HighLevel is used to score leads, automate outbound SMS and email, train AI agents on customer conversations, or to centralize data from multiple advertising sources. Document data retention, access controls and sub processor changes.
Sign a Data Processing Agreement with HighLevel, integrate it with a Consent Management Platform that blocks non essential cookies and pixels until consent is granted, configure server side events to respect the consent signal, document retention periods, restrict admin and agency seats, audit white label sub clients, and update your privacy notice and cookie policy to mention HighLevel, the United States as a recipient country and the relevant transfer mechanism.
Websites using HighLevel must obtain user consent under GDPR regulations.
DPIA considerations
A DPIA is recommended when HighLevel is used for large scale marketing automation, behavioral profiling, lead scoring, SMS and email outreach, or when sensitive categories of data may be collected through funnels and forms. Key risks: US data transfers, cross channel profiling, retention of CRM records, sub processor chain, and combining first party CRM data with advertising identifiers. Document the transfer mechanism (SCCs, DPF), perform a Transfer Impact Assessment, configure data retention, restrict admin access, and ensure consent is captured before non essential cookies fire.
Sample consent text
We use HighLevel to operate our funnels, forms, calendars and CRM. With your consent, HighLevel may set cookies and identifiers to measure funnel performance, attribute conversions and personalize follow up messages. You can accept, refuse or change your choice at any time from our cookie banner.
Third-party domains contacted
gohighlevel.comapp.gohighlevel.commsgsndr.comleadconnectorhq.comcdn.msgsndr.comservices.leadconnectorhq.comCookies placed
| Name | Type | Duration | Purpose |
|---|---|---|---|
| ghl_visitor_id | first_party | 1 year | Persistent visitor identifier used by HighLevel to track returning visitors across funnels and forms for attribution and lead matching. |
| ghl_session | first_party | Session | Session cookie used to maintain the funnel and form state across page navigation within a single browsing session. |
| _gh_uniq | first_party | 30 days | Attribution cookie that stores UTM parameters, referrer and first touch source to attribute leads to the correct marketing campaign. |
| ghl_form_session | first_party | Session | Form session cookie used to preserve form inputs, multi step state and CSRF protection during the form completion flow. |
| ghl_csrf | first_party | Session | CSRF protection token used to secure form submissions and API requests against cross site request forgery. |
HighLevel places tracking cookies for advertising — comply with GDPR using FlowConsent.
HighLevel typically sets first party cookies on funnels, forms and websites, including a visitor identifier, a session cookie, a form session cookie, attribution and UTM identifiers and a CSRF token. Agencies often add third party advertising pixels such as Meta, Google Ads and TikTok, which are subject to consent. The exact set depends on the modules enabled, the domain configuration and the integrations added by the agency.
Yes, when HighLevel is used for marketing automation, advertising pixels, behavioral analytics or remarketing identifiers, prior consent is required under Article 5(3) of the ePrivacy Directive and Article 6(1)(a) GDPR. Strict CRM functionality requested by the end user, such as a calendar booking or an order confirmation, can rely on Article 6(1)(b) contract without consent.
The legal basis is split. Operational CRM workflows requested by the user rely on Article 6(1)(b) GDPR contract. Marketing automation, lead scoring, retargeting and advertising pixels rely on Article 6(1)(a) GDPR consent, combined with the ePrivacy Directive for any storage or access to information on the user device. Document both bases in your Records of Processing Activities.
Yes. HighLevel LLC is a US company and processes personal data on US infrastructure, including AWS and Cloudflare. Transfers must be covered by Standard Contractual Clauses, and where applicable by the EU US Data Privacy Framework for certified sub processors. A Transfer Impact Assessment and a description of supplementary measures are recommended.
A DPIA is strongly recommended when HighLevel is used for large scale marketing automation, behavioral profiling, lead scoring, AI driven conversations or when data from multiple sources is centralized into one CRM. The combination of identifiers, communication content and AI processing typically meets at least two of the EDPB criteria that trigger a mandatory DPIA.
Sign a Data Processing Agreement, integrate HighLevel with a Consent Management Platform, block non essential cookies and pixels until consent is granted, configure server side events to respect the consent signal, define retention periods, restrict admin and agency seats, audit white label sub clients, and update your privacy notice and cookie policy to mention HighLevel, the United States and the relevant transfer mechanism.
European or EU hosted alternatives that can cover parts of the HighLevel feature set include HubSpot with EU hosting, Brevo, ActiveCampaign with EU options, Plezi, Webmecanik, Pipedrive and Salesforce with EU residency. None of these covers the exact agency white label scope, so a migration analysis should compare funnels, CRM, messaging and white label SaaS features against your actual usage.
List the HighLevel cookies and identifiers used on your funnels and forms, describe their purpose and duration, indicate HighLevel LLC as recipient, mention the United States as the destination country, name the transfer mechanism (SCCs and DPF where applicable), and link to a way for users to withdraw or change consent at any time.