Who processes personal data for lamp
The third parties that handle personal data to run lamp's hosted service, what they handle and where.
DRAFT — prepared with AI assistance, not reviewed by a lawyer. Do not publish before legal review.
Version: draft 0.1, [DATE] Operated by: Agentic Genie LLP ("LAMP")
This list names the third parties that process personal data for LAMP's hosted service. It forms part of the LAMP Data Processing Addendum (data-processing-addendum.md). LAMP gives at least 30 days' notice before adding a Sub-processor or changing what one receives or where. To get notices by email, write to [PRIVACY CONTACT EMAIL] or turn on "Legal updates" in the Cockpit.
How to read the table
- Tenant Data: "Yes" means the provider processes personal data inside your business records or conversations, so it is a Sub-processor under the Addendum. "LAMP only" means it handles only LAMP's own data (sign-in or billing) and is listed for transparency.
- Country: where the provider processes the data. Where a provider uses several countries, the main ones are named.
- Entries marked [UNCONFIRMED] are planned by LAMP's architecture but not yet contracted, or their region or terms have not been checked. They must be confirmed before this list is published.
An on-premises or customer-cloud Cell uses only the providers its owner configures. This list applies to LAMP's hosted service.
1. Hosting and infrastructure
| Provider | Purpose | Personal data received | Country | Tenant Data | Notes |
|---|---|---|---|---|---|
| Amazon Web Services India Pvt. Ltd. (contracting entity [UNCONFIRMED]) | Hosts the Cell: application servers, database, file storage, back-ups, logs | All Tenant Data and LAMP Account Data, encrypted at rest | India ([AWS REGION, e.g. ap-south-1 Mumbai]; disaster-recovery region [UNCONFIRMED]) | Yes | Source: ADR-0008. Primary store for everything |
2. AI model providers
LAMP calls models through a LiteLLM gateway that runs inside the Cell (ADR-0009). The gateway sends each model only the slice of data a task needs, with identifiers and Sensitive Data Classes masked where the task allows. LAMP uses only terms under which providers do not train on the data.
| Provider | Purpose | Personal data received | Country | Tenant Data | Notes |
|---|---|---|---|---|---|
| Anthropic, PBC | Frontier model for hard reasoning: reading uploaded documents, Deviation write-ups, drafting Tree Changes | Prompt content: parts of records, messages and document images, which may contain names, contact details and amounts | United States | Yes | [UNCONFIRMED] contract route (direct API or via OpenRouter) and retention setting |
| OpenRouter, Inc. | Routes calls to small and open-weight models for routine tasks (extraction, classification, template filling, chat replies) | Prompt content as above | United States | Yes | [UNCONFIRMED] Must be configured to route only to providers that do not train on or retain prompts |
| Model hosts selected through OpenRouter | Run the model that answers a routed call | Prompt content as above | Varies: mainly United States and European Union [UNCONFIRMED] | Yes | [UNCONFIRMED] LAMP must either list each upstream host or pin routing to a named set. Listing only OpenRouter is probably not enough |
| OpenAI, L.L.C. | Alternative frontier or small model, used if a task class qualifies on it | Prompt content as above | United States | Yes | [UNCONFIRMED] Named in the legal research as a possible provider; not yet chosen |
| Google LLC (Gemini API) | Alternative model, used if a task class qualifies on it | Prompt content as above | United States | Yes | [UNCONFIRMED] Named in the legal research as a possible provider; not yet chosen |
3. Messaging Channels
| Provider | Purpose | Personal data received | Country | Tenant Data | Notes |
|---|---|---|---|---|---|
| Telegram (Telegram Messenger Inc. / Telegram FZ-LLC [UNCONFIRMED entity]) | Default Channel: carries messages between people and LAMP's bot; delivers sign-in codes | Message content, files and images, Telegram user ID, name and verified mobile number | Outside India; Telegram states it uses several data centres [UNCONFIRMED] | Yes | People use Telegram under Telegram's own terms. [UNCONFIRMED] whether Telegram is a Sub-processor or an independent service the user chooses |
| Meta Platforms, Inc. / Meta Platforms Ireland Ltd. (WhatsApp Cloud API) | WhatsApp Channel on the Tenant's own number; LAMP's separate sign-in number | Message content, files, WhatsApp phone numbers and profile names | United States and other Meta data centres [UNCONFIRMED] | Yes, once enabled | Source: ADR-0013. Not live until Meta approves LAMP as a Tech Provider. The Tenant accepts Meta's terms and pays Meta directly. [UNCONFIRMED] whether Meta is LAMP's Sub-processor or the Tenant's own processor. WhatsApp data never enters shared learning |
4. Email and SMS
| Provider | Purpose | Personal data received | Country | Tenant Data | Notes |
|---|---|---|---|---|---|
| Amazon Web Services (Amazon SES) | Sends email one-time codes, invites and account notices; sends Documents by email when the Tenant chooses | Recipient email address, message content and attachments | India ([AWS REGION]); delivered onward to the recipient's mail provider anywhere | Yes, when Documents are emailed | Source: ADR-0011. [UNCONFIRMED] SES region |
| SMS provider [TO BE CHOSEN] | SMS one-time codes, only if switched on | Mobile number, code | India [UNCONFIRMED] | LAMP only | Source: ADR-0011. Off until a provider is configured |
5. Payments and billing
| Provider | Purpose | Personal data received | Country | Tenant Data | Notes |
|---|---|---|---|---|---|
| Razorpay Software Pvt. Ltd. | Collects LAMP subscription fees from the Account Holder | Account Holder name, email, mobile, business name, GSTIN; payment details entered on Razorpay's own page | India | LAMP only | Source: pricing research. LAMP does not see full card or bank credentials |
6. Statutory integrations (only when the Tenant connects them)
| Provider | Purpose | Personal data received | Country | Tenant Data | Notes |
|---|---|---|---|---|---|
| GST Suvidha Provider [TO BE CHOSEN] | Generates e-way bills (and later e-invoices) on the government systems for the Tenant | Invoice and transport data: Counterparty names, GSTINs, addresses, vehicle numbers, the Tenant's API credentials | India | Yes, when connected | Source: ADR-0007. Without a connection, LAMP produces a portal upload file and the Tenant uploads it, so no GSP is involved |
Not Sub-processors
These receive data from LAMP only on a person's or the Tenant's own choice, under their own terms, and are not engaged by LAMP:
- External Assistants (such as Claude, ChatGPT or others) that a person connects to LAMP over MCP.
- Government portals (GSTN, the e-way bill system, the e-invoice registration portal) that receive filings made by or for the Tenant.
- Tally or other accounting software the Tenant imports from or exports to.
- Recipients of the Tenant's messages and Documents, such as its customers and suppliers.
LAMP runs its evaluation, logging and monitoring tools inside the Cell. If LAMP adds a hosted tool for error tracking, analytics, support tickets or model tracing that receives Tenant Data, it will be added here with notice first.
Change log
| Date | Change |
|---|---|
| [DATE] | First version |