Lumina Dental Limited engages the following sub-processors to deliver the Lumina platform and associated services.
All sub-processors are contractually bound by data protection obligations consistent with UK GDPR. This schedule is maintained as part of the Data Processing Agreement between Lumina and the Customer.
Infrastructure and Hosting
| Sub-processor | Purpose | Data Location |
|---|---|---|
| Amazon Web Services (AWS) | Secure application hosting, data storage, communications services, and optional AI processing (model inference and speech transcription) | United Kingdom (AWS London region) |
All primary application and patient data is hosted within the United Kingdom, in the AWS London region.
AI model inference runs under approved European geographic inference profiles. Verified in August 2026, a request under those profiles may additionally be served in AWS regions within the United Kingdom and the European Economic Area, being: London (United Kingdom), Dublin (Ireland), Paris (France), Frankfurt (Germany), Stockholm (Sweden), Milan (Italy) and Zaragoza (Spain). Speech transcription for live dictation is served in the AWS London region only.
The providers of the underlying foundation models do not receive, and do not have access to, request or response content under the Amazon Bedrock arrangements set out in the Data Processing Agreement. They are not sub-processors. If that position changes for any model, the change process below applies before the processing begins.
Payment Processing
| Sub-processor | Purpose | Data Location |
|---|---|---|
| Stripe Payments Europe Ltd / Stripe, Inc. | Subscription billing and payment processing | EU and/or United States (as required by Stripe infrastructure) |
Lumina does not store full payment card details. Card data is processed directly by Stripe.
Categories of Data Processed
Sub-processors may process personal data strictly as necessary to provide the Services, including:
- Patient identifiers
- Special category health data
- Clinical records and images
- Practice account data
- Billing information
International Transfers
Lumina hosts primary application data within the United Kingdom.
AI model inference may be served in AWS regions within the United Kingdom and the European Economic Area, as listed above. European Economic Area states are covered by UK adequacy regulations, so no separate Article 46 safeguard is required for that processing.
Where payment processing requires data transfer outside the UK, appropriate safeguards are relied upon.
Changes to Sub-processors
Lumina will update this page when sub-processors are added, removed, or changed. The following process applies:
- Customers will receive at least 30 days' advance written notice via email before any change takes effect
- Customers may object to a new or changed sub-processor in writing within 14 days of receiving notice
- Lumina will work in good faith with the Customer to address any reasonable objection
- If a reasonable objection cannot be resolved, the Customer may terminate the agreement in accordance with the Terms of Service
Contact
If you have questions about this schedule or our use of sub-processors:
Lumina Dental Limited, registered in England and Wales (company number 16067035)
Email: privacy@luminadental.co.uk
This schedule was last updated in August 2026. Previous versions are available upon request.