Data processing addendum
Last updated 7 October 2026
Draft — pending legal review
This addendum applies when Advert Lumen processes personal data on your behalf. Advert Lumen acts as your processor, and, for data obtained from Meta, as a technology provider that processes data only on behalf of each client and keeps each client's data separate.
Scope
Account users' contact details; ad performance reports, which contain aggregated metrics and no person-level data; and the drafts and creatives you provide.
Sub-processors
Fly.io, Neon, Upstash, Tigris Data, Meta (Model API), Resend, Stripe and Sentry, all in the United States.
International transfers
Customers in the EU: data is processed in the United States under the standard contractual clauses.
Optional contribution of calibration data
You may opt in to contribute statistics about our predictions for your campaigns to Advert Lumen's public accuracy page and to global calibration. Both are off by default, can be switched off at any time, and remain unavailable until our legal review confirms they are permitted under Meta's platform terms.
Deletion and assistance
Deletion follows the retention rules in the privacy policy. We help you answer data-subject requests by running the same deletion jobs, and we notify affected organisations of a security incident involving their data within 72 hours of becoming aware of it.