Sub-processors
Summary
This summary is a plain-language guide to the main points of this document. It does not form part of the document’s binding terms and does not change their meaning. The numbered clauses govern.
- These are the companies Lucrii engages to help provide the Service, and which may process your organisation’s data for us.
- Your organisation’s data is hosted in Australia. The providers marked United States process some data there, and requests to Cohere’s embedding models may be processed in AWS regions outside Australia.
- Lucrii gives at least 30 days’ notice by email to each organisation’s Owners before a new sub-processor starts processing your data. Anyone else can ask to receive that notice by emailing support@lucrii.io.
- You can object to a new sub-processor. If Lucrii cannot resolve the objection, you can cancel or end the agreement and get a refund of fees paid in advance for the rest of the period.
1. About this page
1.1 This page lists the Sub-processors that Lucrii Pty Ltd (ABN 46 694 710 211, ACN 694 710 211) (Lucrii) engages to process Customer Data, or the Personal Information of Users, in providing the Service, as described in clause 7 of the Data Processing Addendum (DPA). It forms Annex III of the DPA, which forms part of the Terms of Service (Terms).
1.2 This page adopts the definitions in clause 2.1 of the Terms, including Customer, Customer Data, Service, Hermes, Hermes Content and Sub-processor, and the definitions in clause 2.1 of the DPA, including Customer Personal Data.
1.3 Lucrii binds each Sub-processor to written data protection obligations that meet the requirements of clause 7.2 of the DPA, and remains responsible to the Customer for each Sub-processor’s performance.
2. Current Sub-processors
To be told about changes to this list, email support@lucrii.io with the subject “Sub-processor updates”. Owners receive these notices without asking.
| Vendor | Purpose | Location |
|---|---|---|
| Amazon Web Services, including Amazon Bedrock and Amazon SES | Hosting, storage, AI processing and email delivery | Australia; embedding requests through Amazon Bedrock may be processed in other AWS regions |
| Anthropic (models through Amazon Bedrock) | AI models that generate Hermes’ responses, run inside Amazon Web Services | Australia, through Amazon Web Services |
| Cohere (embeddings through Amazon Bedrock) | AI models that index records and memories for Hermes, run inside Amazon Web Services | Australia and other AWS regions, through Amazon Bedrock cross-region inference |
| PostHog | Product analytics, session replay with inputs masked, error reports and application logs, and measuring and improving Hermes (Hermes Content) | United States |
| Stripe | Subscription billing and payments | United States and Australia |
| Klaviyo | Product and marketing email to Users, using their contact and account details and information about how they use Lucrii | United States |
| Workspace (support email and documents), sign-in with Google, and address search | United States and other countries where Google processes data |
2.1 Amazon Web Services hosts Customer Data in Sydney. Amazon Bedrock runs Hermes’ language models in Sydney and Melbourne. Users reach the Service through Amazon CloudFront, whose edge locations nearest each User carry the traffic to Sydney.
2.2 Anthropic and Cohere make the AI models that Hermes uses, and Amazon Web Services runs them on Amazon Bedrock. Anthropic’s models run on Amazon Bedrock in Australia. Cohere’s embedding models run through Amazon Bedrock’s cross-region inference, so Customer Data sent to them may be processed in AWS regions outside Australia. Lucrii does not train AI models, and its AI providers do not train on Customer Data.
2.3 PostHog receives Hermes Content so that Lucrii can measure and improve Hermes. Lucrii does not use that content to train AI models.
2.4 Klaviyo receives Users’ contact and account details, business details about their Organisation, and information about how each User uses Lucrii, including their activity in the Service, so that Lucrii can send Users its own product and marketing email. Klaviyo does not receive the content of Hermes interactions.
3. Notice of changes and objections
3.1 Lucrii gives at least 30 days’ notice before a new Sub-processor begins processing Customer Data, by updating this page and by email to the Owners of each Organisation and to everyone who has asked to receive these notices, as clause 7.3 of the DPA provides.
3.2 To receive these notices, email support@lucrii.io from the address that should receive them, as clause 2 describes. To stop receiving them, email the same address.
3.3 The Customer may object to a new Sub-processor, as clause 7.4 of the DPA describes.
4. Integrations the Customer chooses
4.1 Xero, Stripe Connect, Apps from the Lucrii App Store, and MCP Clients such as Claude and ChatGPT are not Lucrii’s Sub-processors. Lucrii does not engage them. The Customer chooses whether to connect them, Lucrii sends them the data the connection needs at the Customer’s direction, and their own terms and privacy policies govern what they do with it.
5. Contact
5.1 Questions about this page or about Lucrii’s Sub-processors can be sent to support@lucrii.io or to Lucrii Pty Ltd, PO Box 784, New Farm QLD 4005, Australia.