teurons

Data Processing Agreement

Last updated 20 October 2026

When you use a Teurons product to handle personal data about your own users, we process that data on your behalf. This agreement sets out the terms on which we do that. It applies automatically. There is nothing to sign. If your legal team needs a countersigned copy, email hello@teurons.com and we will arrange it.

Scope and roles

This agreement applies whenever Teurons, Inc., a Delaware corporation ("Teurons", "we", "us"), processes personal data on your behalf through any Teurons product. It forms part of the terms that govern your use of that product and takes effect automatically when you use it.

You are the controller of the personal data your end users generate through the product. We are your processor for that data.

We are a separate, independent controller of your own account data: your name, email address and organisation details, including what we hold to run the shared sign-in at accounts.teurons.com. That is governed by our Privacy Policy, not by this agreement.

Product-specific details of what is processed and where are in the schedule for each product below. Lumio is the only product with a schedule today. A product that processes end-user personal data on a customer's behalf gets its own schedule before it is offered under this agreement.

Our instructions

We process end-user personal data only on your documented instructions. Configuring a product, calling its APIs and using its dashboard constitute those instructions. We will not use that data for our own purposes, will not sell it, and will never use one customer's data to serve another.

If we believe an instruction breaks data protection law, we will tell you and may pause that processing rather than carry it out. If the law compels us to process data beyond your instructions, we will notify you first unless legally barred.

Confidentiality

Access to end-user data is limited to people who need it to operate or support the service. Everyone with access is under a duty of confidentiality that survives the end of their engagement.

Security measures

We maintain appropriate technical and organisational measures, described in full on our Security page. In summary:

  • encryption in transit (TLS with HSTS) and of stored credentials at rest (AES-GCM)
  • API tokens stored only as SHA-256 hashes, shown once at creation
  • every query scoped by organisation, so one customer's data cannot be reached from another's session
  • end-user identity verified by an HMAC signature generated on your server, so it cannot be forged from a browser
  • an origin allowlist controlling where each widget may load
  • least-privilege access to production, and secrets held outside the codebase

The measures above are those confirmed for Lumio today. The Security page labels which controls apply to which product.

Sub-processors

You authorise the sub-processors listed at /legal/subprocessors. Each is bound by equivalent data protection obligations.

We will give you at least 30 days' notice before adding or replacing a sub-processor that handles end-user data. If you reasonably object on data protection grounds, tell us within that period and we will work with you on an alternative. If none exists, you may terminate the affected part of the service.

Assisting with data subject requests

If an end user contacts us directly, we will not respond on your behalf. We will pass the request to you. Taking into account the nature of the processing, we will help you meet your obligations to access, correct, delete, restrict or export their data, using the tools in the product dashboard and, where those are not sufficient, by direct assistance.

Personal data breach

If we become aware of a breach affecting end-user data we process for you, we will notify you without undue delay and in any case within 72 hours. The notice will describe what happened, the categories and approximate number of records affected, the likely consequences, and what we are doing about it. We will not wait until the picture is complete before telling you.

Deletion and return

You can export or delete data at any time from the product dashboard. On termination we delete end-user data within 30 days, except where the law requires us to retain it. Backups are overwritten on their normal cycle. On request before deletion, we will provide a copy in a commonly used machine-readable format.

Audits and information

We will make available the information reasonably necessary to demonstrate compliance with this agreement. In practice that means answering a security questionnaire and pointing you at our Security page, which states plainly what we do and do not yet have. Where that is genuinely insufficient for your regulator, we will agree a proportionate audit, at your cost, on reasonable notice, and without disrupting other customers.

International transfers

Teurons, Inc. is incorporated in the United States, so data may be processed outside your country. Where personal data protected by UK or EU law is transferred out of those regions, the European Commission's standard contractual clauses (and the UK Addendum where applicable) are incorporated into this agreement by reference, with Teurons, Inc. as data importer and you as data exporter. Where each product is hosted is stated in its schedule below.

Schedule 1: Lumio

This schedule applies to Lumio (lumio.teurons.com), the Notion-powered widget you embed in your own product.

Subject matterProviding the Lumio widget (product updates, docs, announcements and their analytics) inside your product.
DurationFor as long as your account is active, plus the 30-day deletion window described under Deletion and return.
Nature and purposeStoring and serving content, tracking read state, targeting announcements you configured, and producing your analytics. Automated. No human review of end-user data in the ordinary course.
Data subjectsEnd users of your product who load the widget.
Categories of dataAn anonymous browser identifier; the user identifier and any properties you choose to send; usage events with the page URL, page title and origin; read state; and, where you enable the AI Assistant, the questions asked and the conversation history.
Special categoriesNone requested and none required. You control what you send, so do not send special-category data. The service is not designed for it.
Where it is processedLumio runs on Cloudflare's global network, so data may be processed wherever that network routes it. There is no data residency guarantee.

Contact

Questions, sub-processor objections and breach correspondence: hello@teurons.com. See also the Privacy Policy and Terms of Service.