Security Measures
and Sub-Processors


As incorporated into LightWork’s Data Processing Agreement

Annex 1: Security measures

Technical and organisational
measures to ensure the
security of Personal Data

Technical measures

  • All workloads run on Google Cloud Platform (GCP), deployed strictly in UK and EU regions (London or other EU zones only).

  • MongoDB (UK region) is our primary database. Data is encrypted at rest with AES-256 and encrypted in transit (TLS).

  • We maintain periodic automated backups of all production databases with secure storage and controlled access.

  • Access to infrastructure is restricted via IAM, MFA-enforced accounts and least-privilege roles.

  • Services run in private networks with firewalls and VPC-level isolation.

  • Monitoring, alerting and log management are handled by Datadog, configured within EU regions.

  • We use Vanta to continuously monitor our security position and maintain compliance with ISO27001:2022 and SOC2 frameworks.

  • All software is kept up-to-date and security updates are installed as soon as reasonably possible.

Organisational measures

  • Operational practices include regular patching, vulnerability scanning, penetration testing and maintaining incident management and response processes.

  • Making all employees and third-party agents fully aware of their individual responsibilities under the UK GDPR.

Annex 2: Sub-processors


Current sub-processors

Name of Sub-processor

Location of Processing

Transfer mechanism

Google Cloud Platform (GCP): cloud infrastructure

UK and EEA (US access)

EU-US DPF (UK Extension) for US support/admin access; SCCs + UK Addendum fallback

MongoDB Atlas: primary database

UK (US access)

EU-US DPF (UK Extension)

Redis Cloud: caching

UK (US access)

SCCs + UK Addendum; TRA completed

Nylas: email and calendar integration

EEA (US access)

Adequacy (EEA); EU-US DPF (UK Extension) for US access

Anthropic (Claude): foundational model provider

US

SCCs + UK Addendum; TRA completed

SendGrid (Twilio): outbound transactional email

US

SCCs + UK Addendum + TRA completed

Resend: outbound transactional email

US

EU-US DPF (UK Extension)

Twilio: voice, SMS and WhatsApp communications

EEA / US

EU-US DPF (UK Extension)

ElevenLabs: text-to-speech / voice

US

EU-US DPF + SCCs (UK Addendum)

Google Maps Platform: travel-time and viewing logistics

US

EU-US DPF (UK Extension)

Datadog: monitoring, logging and observability

EEA (US access)

Adequacy (EEA); EU-US DPF (UK Extension) for US access

PostHog: product analytics

EEA (US access)

Adequacy (EEA); EU-US DPF (UK Extension) for US access

Pydantic Logfire: application and LLM observability

EEA (US access)

Adequacy (EEA); SCCs + UK Addendum for US access; TRA completed

Pylon: customer support desk

US

SCCs (Module 2) + UK Addendum; TRA completed

Vercel: application hosting for the Spark demo (select clients)

US

EU-US DPF (UK Extension); EU SCCs + UK Addendum (IDTA) fallback

Slack: internal comms; incidental customer data in QA/support

US

EU-US DPF (UK Extension) via Salesforce

Sub-processor change notification terms

We give customers 30 days' advance notice of a new or changed sub-processor, and 48 hours for an urgent replacement (e.g. a security issue).


Retained but not in live production

Name of Sub-processor

Location of Processing

Transfer mechanism

OpenAI: foundational model provider

US

SCCs + UK Addendum; TRA completed

Google (Gemini): foundational model provider

US

EU-US DPF (UK Extension)



Version

Date

Description

Author

Approved By

1.0

25 March 2026

Security Measures and Sub-Processors

James Wilson

Rameen Sorkhabi

1.1

25 June 2026

Updated sub-processor list and transfer mechanisms.

Freddie Poser

Freddie Poser

1.2

28 July 2026

Reconciled to internal register: removed Qdrant and LangSmith (decommissioned); moved OpenAI and Gemini to retained (not in live production); added Pylon, Vercel and Slack; GCP US-access leg annotated.

James Wilson

Freddie Poser

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© 2026 LightWork Holding Ltd. Company No. 15027977 · VAT: GB488579216

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Ready to let Felicity handle the admin?

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83 Victoria Street, London, SW1H 0HW

© 2026 LightWork Holding Ltd. Company No. 15027977 · VAT: GB488579216

propertymark industry supplier badge
SOC 2 badge
ISO/IEC 27001 certification badge
LightWork AI Cyber Essentials Plus certification badge

Ready to let Felicity handle the admin?

Book a walk-through to see exactly how Felicity can streamline your property operations

83 Victoria Street, London, SW1H 0HW

© 2026 LightWork Holding Ltd. Company No. 15027977 · VAT: GB488579216

propertymark industry supplier badge
SOC 2 badge
ISO/IEC 27001 certification badge
LightWork AI Cyber Essentials Plus certification badge