Subprocessors Page

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These are the subprocessors Luminance currently uses to provide the Product (including any additional features) and Support. This page is referenced by the Data Processing Addendum (“DPA”); if we add or replace a subprocessor we follow the notice and objection process in the DPA.

Sub-processor

Nature and purpose of processing

Categories of personal data

Location of processing

PRODUCT & CUSTOMER DATA HOSTING

AWS

Cloud hosting of the Product and Customer Data.

Determined by the Customer. Any personal data contained in the Customer Data (documents) uploaded to the Product. For example, names, contact details, and any personal data within the Customer’s documents.

As set out in the Product Order Form, and in accordance with the locations at aws.amazon.com/compliance/sub-processors.

INFRASTRUCTURE PROVIDERS Customer Data is not sent to an external model provider.

AWS

In-cloud Additional Generative Model processing.

Determined by the Customer. Any personal data contained in the inputs submitted to the feature utilising Additional Generative Models.

As set out in the Product Order Form, and in accordance with the locations at aws.amazon.com/compliance/sub-processors.

Microsoft Azure

In-cloud Additional Generative Model processing.

Determined by the Customer. Any personal data contained in the inputs submitted to the feature utilising Additional Generative Models.

Follows the hosting region set out in the Product Order Form: EU/UK if the Product is hosted in the EU/UK; otherwise an international location.

Google Cloud EMEA Limited

In-cloud Additional Generative Model processing.

Determined by the Customer. Any personal data contained in the inputs submitted to the feature utilising Additional Generative Models.

Follows the hosting region set out in the Product Order Form: EU/UK if the Product is hosted in the EU/UK; otherwise an international location.

GENERATIVE MODEL PROVIDERS Customer inputs are sent to the provider.

OpenAI, L.L.C

Additional Generative Model processing, accessed via the provider’s API.

Determined by the Customer. Any personal data contained in the inputs submitted to the feature utilising Additional Generative Models.

United States

SUPPORT & OPERATIONS

Luminance, Inc

24/7 support services.

Authorised users’ contact and account data (e.g. name, email), and any personal data the Customer includes in a support request.

United States

Luminance Technologies Australia Pty Limited

24/7 support services.

Authorised users’ contact and account data (e.g. name, email), and any personal data the Customer includes in a support request.

Australia

Intercom R&D Unlimited Company

Customer support tooling and communications.

Authorised users’ contact and account data (e.g. name, email), and any personal data the Customer includes in a support request.

European Union and/or United States (United States on request)

Mango Technologies, Inc. (ClickUp)

Support and operations tooling (ticketing and workflow).

Authorised users’ contact and account data (e.g. name, email), and any personal data the Customer includes in a support request.

European Union

OpenAI, L.L.C

Agentic workflows (Codex) used in the support of the Product

Authorised users’ contact and account data (e.g. name, email), and any personal data the Customer includes in a support request.

European Union

Categories of personal data. Because the Product processes documents and inputs supplied by the Customer, the Customer determines the categories of personal data processed. These may include special categories of personal data (Article 9 UK/EU GDPR) and personal data relating to criminal convictions and offences (Article 10). The Customer is responsible for establishing a lawful basis, and any additional conditions, for such processing.

International transfers. For any transfer of personal data outside the UK/EEA (including to the United States), Luminance relies on the transfer safeguards set out in the DPA (Standard Contractual Clauses and/or the EU-U.S., UK and Swiss Data Privacy Framework).