This Data Processing Agreement (DPA) is part of the terms of service. It applies when Lumina processes personal data for an agency ("you") that uses Lumina. Where it differs from the terms, this DPA wins for personal data.
1. Roles
You decide why and how personal data is used in your workspace, so you are the controller. Lumina processes it only to run the service for you, so Lumina is your processor. If you hold data for your own clients, you may be their processor, and Lumina is then your sub-processor.
2. What we process
- People: your team members, your clients' portal viewers, and the people you send reports or invitations to.
- Data: names, email addresses, roles, sign-in records, activity log entries, comments, and support messages.
- Ad data: performance numbers from the ad accounts you connect, such as spend, impressions and clicks, with campaign, ad set and ad names. Age, gender, country and placement splits arrive from the platforms as totals, not as individual people.
- How long: for as long as your workspace exists, then as described in section 8.
3. Your instructions
We process personal data only to provide Lumina as described in the terms, the privacy policy and this DPA, and as you set it up in the app. We tell you if we believe an instruction breaks data protection law.
4. Confidentiality and staff access
Only a small number of Lumina staff can reach customer data, and only to run, support or secure the service. They are bound to keep it confidential. Staff tools show workspace names and counts, not your reports.
5. Security
- Every workspace is kept apart by database rules, tested on every change.
- Platform access tokens are encrypted and never sent to the browser.
- All traffic uses HTTPS. Passwords are stored hashed, and known leaked passwords are refused.
- Owners and admins can see an activity log of important changes in their workspace.
- The database is backed up by our database provider.
6. Sub-processors
You agree that we use these services. We tell account owners before we add or replace one.
| Service | What for | Data | Where |
|---|---|---|---|
| Supabase | Database, sign-in and file storage (logos and ad thumbnails) | All workspace data | AWS Mumbai region, India |
| Netlify | Hosting the website and running the app's servers | Requests passing through the app; server logs | Global network; servers may run in the United States |
| Resend | Sending email (invitations, scheduled reports, alerts, support messages) | Recipient email addresses and email content | United States |
| Sentry | Error reports, so we can fix problems | Technical error details; personal data is removed before sending | United States or EU, depending on Sentry's hosting region |
| Anthropic | Writing report summaries, only when a team member asks for one | The report's numbers, date range and campaign names | United States |
The ad platforms you connect (such as Meta, Google, TikTok and Snapchat) are not our sub-processors. You connect them yourself, and their own terms apply to that data.
7. Transfers outside your country
Some sub-processors work outside your country, as shown above. Where the law requires it, transfers rely on recognized safeguards, such as the standard contractual clauses those providers offer.
8. When you leave
Owners can download all workspace data in Settings, Data, and can delete the workspace there. Deleting removes the data from the live database at once. Copies in our database provider's backups are removed when those backups expire.
9. Helping you
- Requests from people about their data: the export and delete tools in Settings cover most of them. We help with the rest when you ask.
- Data breaches: we tell the workspace owners without undue delay, and within 72 hours of finding out.
- Security reviews: we answer reasonable security questionnaires and share what we can about our controls.
10. Contact and signed copies
This DPA applies without signing. If your company needs a signed copy, or has questions, email support@luminadash.com.