lumi — Sub-processor List
Version 1.0 · current as of 3 September 2026
This page lists the sub-processors lumi engages to deliver the service.
How to read this list
A sub-processor is a third party that processes data on lumi's behalf (for example, hosting, email delivery, or AI-generated analysis). lumi remains accountable for any sub-processor's handling of data under the Data Sharing Agreement (DPA).
Current sub-processors
| Purpose | Sub-processor | Location & transfer | Safeguards |
|---|---|---|---|
| AI-generated analytical summaries (AI Insights) | Anthropic PBC | United States — UK GDPR transfer safeguards (SCCs / UK Addendum) | Data-processing agreement; processes only aggregated/derived figures (no individual salaries); no training on inputs; zero/limited retention under commercial API terms |
| Application hosting | Amazon Web Services (AWS) | United Kingdom / EEA region | Data-processing agreement (AWS DPA) |
| Transactional email | Postmark (Wildbit LLC, an ActiveCampaign company) | United States — UK GDPR transfer safeguards (SCCs / UK Addendum) | Data-processing agreement (Postmark DPA) |
Changes
Members who have accepted the DPA will be notified of additions to this list in line with the DPA's change-notification terms.