- Home
- Legal
- Sub-processors
Sub-processors
This page lists the parties Sales-Surge B.V. engages to deliver Lumo. For each one you can read what we use it for, where the data is processed, which safeguard a transfer relies on and where that party's data processing agreement is published. Last updated: 11 November 2026.
How this list works
For data a customer puts in its workspace, Sales Surge is the processor and the parties below are sub-processors. That is arranged in the data processing agreement. For the site, the form and user accounts, Sales Surge is the controller itself. That is described in the privacy statement.
For each party we state whether its data processing agreement is already part of its terms. That is the case for every party in the first two tables: the agreement applies as soon as we use the service, without a separate signature.
Some parties only receive data when something is switched on, such as the AI features. Connections a customer or user switches on with their own account at another service are listed separately. There the customer or user has its own agreement with that service.
Sales Surge informs customers of any intended change to this list. A customer can object within 14 days on reasonable, documented grounds, as Article 9.3 of the General Terms and Conditions of Sales-Surge B.V. describes.
Always in use
These parties are needed for Lumo to work.
| Topic | Purpose | Location, safeguard and data processing agreement |
|---|---|---|
| Supabase Inc. | The app's database and file storage, with the daily backup. | London, United Kingdom (AWS region eu-west-2). Data is stored and primarily processed in that region. The United Kingdom has an adequacy decision. Transfers outside it rely on the standard contractual clauses (modules 2 and 3) and the UK addendum in the Supabase DPA. That DPA is part of the Supabase terms. Supabase sub-processors. |
| Netlify Inc. | Hosting of the app (crm.sales-surge.io) and the website, the serverless functions and delivery of static files. | Serverless functions in London (Netlify region lhr). Static files through Netlify's global network (CDN). Netlify is certified under the EU-US Data Privacy Framework with the UK extension, with the standard contractual clauses (modules 2 and 3) as a fallback. The Netlify DPA is part of the Netlify terms. Netlify sub-processors. |
| Mailgun (Sinch) | Sending mail from the app: sign-in, invitations, tickets, campaigns and the customer portal. | Mailgun EU region. In production the app always uses the EU region. According to Mailgun, messages, event logs and suppression lists stay in that region; account data such as users and domain names is global. Safeguard: standard contractual clauses and the UK addendum, and the EU-US Data Privacy Framework. The Sinch DPA is part of the terms. Note: for email, Sinch describes itself in that DPA as an independent controller. Sinch sub-processors. |
Only when an AI feature is on
Lumo's code only allows these two AI providers, and Gemini only as a paid service. The app refuses any other provider, a custom address or a free key: the AI feature then stays off.
| Topic | Purpose and when | Location, safeguard and data processing agreement |
|---|---|---|
| Anthropic PBC (Claude API) | "Report from a sentence": the sentence the user types and the list of fields of the workspace, no records. And the AI assistant, if Sales Surge chooses Claude as the assistant's model. The assistant is off by default per workspace; an admin switches it on. | United States. The Claude API processes requests globally by default (data residency). Anthropic does not train models on customer content (Commercial Terms) and deletes API inputs and outputs within 30 days, except for misuse investigations or a legal obligation (retention). Safeguard: standard contractual clauses (modules 2 and 3) and the UK addendum. The Anthropic DPA is part of the Commercial Terms. Anthropic sub-processors. |
| Google LLC (Gemini API, paid service) | The AI assistant, if Sales Surge chooses Gemini as the assistant's model: the question and the data the assistant looks up for it. The assistant is off by default per workspace; an admin switches it on. | Google chooses the location; data may be held in any country where Google has facilities. On the paid service Google does not use prompts and responses to improve its products, and keeps them for a limited time to detect misuse (Gemini API Additional Terms). The app refuses a free key. Safeguard: the EU-US Data Privacy Framework and standard contractual clauses from Google's processor terms, which apply to the paid service. |
Connections with the customer's own account
These services only receive or supply data once the customer or a user connects their own account. The customer or user then has its own agreement with that service. Sales Surge does not engage them as sub-processors.
| Topic | What happens | Location and terms |
|---|---|---|
| Google (Gmail and Google Calendar) | A user connects their own mailbox or calendar. Lumo fetches mail involving known contacts and events, and sends mail or events the user creates. | The data is held at Google under the user's own account. Lumo's access is governed by Google's rules for apps, the API Services User Data Policy, including the Limited Use requirements. Google LLC is certified under the EU-US Data Privacy Framework. |
| Microsoft (Outlook and Microsoft 365 calendar) | A user connects their own mailbox and calendar. Lumo fetches mail with known contacts and events, and sends mail or events the user creates. Microsoft is the source of this data and not a sub-processor of Sales Surge. | The data stays at Microsoft under the user's own account, or that of their organization. Lumo's access is governed by the Microsoft APIs Terms of Use. What Lumo does with the data is on the Microsoft 365 integration page. |
| Pipedrive | Import and sync with the customer's own Pipedrive account. | According to Pipedrive, EU accounts are placed in the EU by default (Pipedrive sub-processors). Terms: the Pipedrive DPA with the customer's account. |
| Meta (Facebook and Instagram) | Lead forms from the customer's ads. Lumo fetches a lead with the access the customer grants. Lumo places no Meta pixel, not on lumoheaven.com and not in the app. | Lead forms are governed by Meta's Lead Ad Terms between Meta and the customer. Under those terms the customer is responsible for consent and for informing the people who fill in the form. |
| Apollo.io | Enriching people and organisations with the customer's own API key. Lumo then sends, for example, a name, email address or domain to Apollo. | Hosted in the United States. Safeguard: the EU-US Data Privacy Framework with standard contractual clauses as a fallback, under the Apollo DPA, which is part of the Apollo terms. |
| ProspectPro (Bedrijfsdata.nl B.V.) | Recognising companies that visit the customer's website, with the customer's own key. When the customer enters a ProspectPro site id in Lumo's website tracking, Lumo's script also loads the ProspectPro script on the customer's site, except under Do Not Track or Global Privacy Control. | Bedrijfsdata.nl B.V. is a Dutch company. ProspectPro does not publish a data processing agreement for customers or the location of processing (privacy policy). The customer arranges this with ProspectPro itself. |
Video in guidance, only after a click
A workspace can put a Loom, YouTube or Vimeo video in a tour or guidance content. The app only loads that video once the viewer clicks "Load video". Before that, no request goes to that party.
| Topic | What happens | Terms |
|---|---|---|
| Loom, YouTube and Vimeo | After the click, the viewer's browser loads the video from that party, which then receives the viewer's IP address. YouTube plays through youtube-nocookie.com. | The party processes that data under its own terms. See the cookie statement. |
For our own processing
Leads from the form on lumoheaven.com arrive in Lumo and, through a Sales Surge connection of our own, in Pipedrive, Sales Surge's own CRM. For that data Sales Surge is the controller and Pipedrive is our own service provider, under the Pipedrive DPA. The website itself runs on Netlify. More in the privacy statement.
Lumo loads no third-party fonts. The Satoshi typeface is on our own servers, on the site and in the app. So no request goes to Fontshare or Google Fonts.
The available connections are described under integrations. Which cookies the app uses is in the cookie statement. Questions about this list go to info@sales-surge.nl.