Last updated: 1 June 2026 Change notification: we will notify schools at least 30 days before adding or replacing a sub-processor that processes pupil personal data.
The following sub-processors are engaged to deliver the OMNIA Inclusion service. All are bound by a Data Processing Agreement equivalent to or stronger than the one we offer schools.
Infrastructure
| Sub-processor | Service | Data category | Location | Transfer basis |
|---|---|---|---|---|
| Supabase Inc. (via Lovable Cloud) | Database hosting, object storage, authentication | All School Data | EEA — AWS eu-west-1, Ireland | UK adequacy regulation for the EEA. No IDTA or SCCs required. |
| Lovable AB | Application hosting platform and development environment | All School Data (via Supabase) | EEA — AWS eu-west-1, Ireland | UK adequacy regulation for the EEA. Lovable Business plan DPA in place. |
| Cloudflare, Inc. | Edge compute (Workers), CDN, DDoS protection | Request bodies in-memory only; no persistence at the edge | Globally distributed; EU edge nodes preferred for EU visitors | UK IDTA / EU SCCs in Cloudflare DPA |
AI
| Sub-processor | Service | Data category | Location | Notes |
|---|---|---|---|---|
| Lovable AB (AI Gateway) | LLM request brokerage | Specialist report text, free-text fields — passed through a server-side PII scrubber before leaving our infrastructure | EU | Single chokepoint for all LLM traffic |
| Anthropic PBC | LLM inference — plan generation, SMART target drafting, contextual AI analysis, Specialist Support Prompts | Passed through OMNIA's mandatory server-side PII scrubber before every request — replaces names with role tokens and removes common identifiers (DOB, address, phone, NI) on a best-effort basis; the scrubber is defence-in-depth, not a guarantee against free-text leakage | US (via Lovable AI Gateway) | Anthropic DPA in place; no training on school data; no retention beyond request/response cycle |
| Google LLC (Gemini API) | LLM inference — natural language query parsing for the Insights pupil search feature only. Query strings only — no pupil data, no plan content, no assessment data transmitted to the model. Confirmed from Edge Function code review (index.ts). | Same as above, post-scrub | EU regions where available; subject to Google's data-residency controls | We do not opt in to model training |
| OpenAI, L.L.C. (GPT models) | LLM inference for select features | Same as above, post-scrub | EU regions where available | We do not opt in to model training |
| School-managed AI provider (BYOK, opt-in) | When a school activates Bring Your Own Key (available to every school), AI traffic for that school is routed to the school's own Anthropic or Azure OpenAI account instead of OMNIA's Lovable AI Gateway. The school is the controller of its provider relationship. | Same as above, post-scrub | The school's chosen Azure region (e.g. UAE North, UK South) for Azure OpenAI, or Anthropic's published regions | Per-school opt-in. API key is AES-256-GCM encrypted at rest. No auto-fallback to OMNIA's shared key — failures surface to the school's admin. |
| Sub-processor | Service | Data category | Location |
|---|---|---|---|
| Microsoft Corporation (Microsoft Graph) | Sending parent-voice and notification emails from the school's own M365 tenant where enabled | Recipient email + body | The school's M365 region |
| (Pending) Transactional email provider | Service emails sent from our domain (e.g. magic-link, beta access) | Recipient email + body | EU — provider to be confirmed before general availability |
School-controlled MIS integrations (opt-in, per school)
| Sub-processor | Service | Data category | Location | Notes |
|---|---|---|---|---|
| Go4Schools Ltd. | School MIS — source of UPN, name, DOB, year group, attainment grades, baseline grades and SEND attributes for pupils at the connecting school | Pupil identifiers and assessment data | UK | Read-only pull initiated by OMNIA using a per-school API key generated and revocable by the school's Go4Schools admin. Schools that do not connect Go4Schools send no data to this sub-processor. We do not write back to Go4Schools. |
Operational / support tools (no pupil data)
| Sub-processor | Service | Data category | Location |
|---|---|---|---|
| Stripe, Inc. | Billing (when we begin charging) | Billing contact + payment metadata only | Globally; UK/EU data centres for EU customers |
| Cloudflare Email Routing | Inbound email to *@omnia-inclusion.com | Email metadata + body | Globally distributed |
We do not engage any sub-processor in a country without adequacy or equivalent UK / EU Standard Contractual Clauses in place.
New data categories — June 2026
The following data categories were added in the June 2026 build sprint. They are processed by the sub-processors listed above within their existing scope.
Available Interventions Register: School-specific intervention programme data including staff names recorded as trained to deliver specific programmes. Stored in Supabase (Lovable Cloud). Programme names and delivery formats (not staff names) are included in AI plan generation context sent to Anthropic Claude.
Assessment platform import data: Scores and progress data imported from Lexia Core5, Nessy, Sparx Maths, DoodleLearning, TTRS, Emile, and other platforms. Stored in Supabase. Lexia Core5 exports which contain demographic fields (date of birth, gender, race) have those fields stripped server-side immediately on import — they are never stored or passed to any sub-processor.
Questions
Email privacy@omnia-inclusion.com.