LumiLumi

Sub-Processors

Last updated 29 July 2026

This page lists the third-party services that process personal information on Lumi's behalf to run the Lumi Reading Diary, and — in a second table — the other third parties involved in delivering Lumi that handle information for their own purposes. It accompanies our Privacy Policy and is provided so a school can see who touches its data, what they touch, why, and where it is processed.

Every service listed here is in active use. Our cloud environment also contains services that are provisioned but technically blocked from receiving any personal information — they are not listed here because we do not use them, and we will add a service to this page, and update our Privacy Policy where the change affects what we disclose or where it is processed, before it begins handling any personal information.

The services in the first table are ones we use to run Lumi on our own and the school's instructions, under contracts that require them to protect personal information and to use it only for us. They are not independent recipients using data for their own purposes — we do not do that, and we do not sell personal information. Using these providers does not reduce our own responsibility to you under the Australian Privacy Principles.

Lumi is operated by Lumi Education Pty Ltd (ABN 45 700 349 015). Questions: support@lumi-reading.com.

Where your data primarily lives

Our main database, uploaded files and application processing are in Australia — Google Cloud's Sydney australia-southeast1 region. The first table below identifies the supporting services that operate elsewhere.

Sub-processors — services that handle personal information on our instructions

Provider Personal information it touches Purpose How we authorise it Processing / storage countries
Google Cloud Firestorecloud.google.com School, child, adult, roster, reading and messaging records Primary application database Service operation, under the Google Cloud DPA Australia (australia-southeast1, Sydney)
Google Cloud Storagecloud.google.com Optional comprehension audio, school logos, book covers Storage for uploaded media and assets Service operation, under the Google Cloud DPA Australia (australia-southeast1)
Google Cloud Functions / Cloud Run / Eventarc / Schedulercloud.google.com All record types, transiently, while server logic runs Server-side authorisation, aggregation, notifications, deletion, media validation Service operation, under the Google Cloud DPA Australia (australia-southeast1)
Google Cloud Loggingcloud.google.com Application and security events. Account, school, child and record identifiers are prohibited in our log payloads; an administrator identity can appear in Google's required audit logs Operational and security logging Service operation, under the Google Cloud DPA Ordinary logs Australia; Google's required audit logs are global
Google Cloud Secret Managercloud.google.com Application credentials only — no child or school content Secure storage of service credentials Service operation, under the Google Cloud DPA Australia (australia-southeast1)
Google Cloud Vertex AIcloud.google.com A teacher-taken photograph of a book cover, sent to read the title and author. No student, school or account information accompanies the image. Book-catalogue metadata (AI text recognition) Service operation, under the Google Cloud terms Australia (australia-southeast1)
Firebase Authenticationfirebase.google.com Adult account id, email or phone number, multi-factor settings, sign-in and recovery metadata Account sign-in, MFA and recovery for parents/carers and staff Service operation, under the Firebase Data Processing & Security Terms United States — Google documents this as a US-only service
Firebase Cloud Messagingfirebase.google.com Device push token; adult-facing notification text, which can reveal limited reading context Delivering reminders, achievement and comment notifications, school announcements Service operation, under the Firebase terms Global platform service
Apple Push Notification servicedeveloper.apple.com Device push token; adult-facing notification text Push delivery to Apple devices Platform provider, under Apple's developer terms Global platform service
Firebase App Checkfirebase.google.com App and device attestation tokens — no content data Anti-abuse / verifying requests come from a genuine app Service operation, under the Firebase terms Google service; global support may apply
Firebase Analyticsfirebase.google.com Pseudonymous usage events — no child or account identifiers, no reading detail Product-usage insight to improve the app Your opt-in consent — off by default, withdrawable May be processed outside Australia
Firebase Crashlyticsfirebase.google.com Crash stack traces and app/device diagnostics — no account identifier; child content prohibited Diagnosing and fixing crashes Your opt-in consent — off by default, withdrawable May be processed outside Australia
Twilio SendGridtwilio.com Parent onboarding and account emails carrying the recipient's details and, for parent onboarding, the child's first name and an enrolment link code (QR image) Onboarding, service and operational email Service operation, under the Twilio DPA (which names the Australian Privacy Act 1988) Infrastructure in North America and the European Union; Twilio Inc. may process in the United States
Google Workspaceworkspace.google.com Whatever a sender includes in an email to our support address Receiving and actioning privacy and support requests Service operation, under the Google Workspace Data Processing Amendment Global (Google-managed regions)
Cloudflarecloudflare.com Network metadata inherent in delivering a request, including IP address and user-agent. We do not send Lumi account, school or student records to Cloudflare, and we do not link this metadata to Lumi records. Serving the in-app status notice, fronting our public sites, and answering a lightweight connectivity check the app makes (an HTTP HEAD request) when it starts, when connectivity changes and periodically while it is open Service operation, under the Cloudflare DPA Global edge network
Firebase Hostingfirebase.google.com Public website and portal delivery; standard web request logs Serving lumi-reading.com and our web portals Service operation, under the Firebase terms Google global edge, with content stored in Australia
Google Fontsfonts.google.com Ordinary network information (IP address, user agent) when the app, our websites or our emails load fonts from Google. No Lumi account or student information. Displaying text Service operation, under Google's terms Global

Other third parties involved in delivering Lumi

These are not sub-processors: they do not handle personal information on our instructions, and we do not control what they do with it. We list them so the picture is complete.

Party What it involves Whose terms apply
Apple App Store If you install the app from the App Store, Apple handles your store account, purchase and device diagnostic information for its own purposes. Apple's privacy policy
Google Play If you install the app from Google Play, Google handles your store account, purchase and device diagnostic information for its own purposes. Google's privacy policy
Google Books API We send an ISBN or title to look up public book details and covers. No personal information is sent, and the request is not linked to a child's record. Google public API terms
Open Library / Internet Archive We send an ISBN, title or work id to look up public book details and covers. No personal information is sent. Open Library terms

Changes to this list

We keep this page current. Before a new sub-processor begins handling personal information, we will update this page and, where the change affects what we disclose or the countries where information is processed, our Privacy Policy. We will give schools at least 30 days' notice by email to their nominated contact before a new sub-processor starts, and a school may raise a reasonable objection during that period; if we cannot resolve it, the school may end its arrangement with us without penalty for the remainder of the term. Schools can also ask to be added to, or removed from, this notification list by emailing support@lumi-reading.com.