_Last reviewed: 2026-08-23_

> **This page is not a Data Processing Agreement and cannot be signed or incorporated into a contract.**

## Current status

Lumail is an early-stage service operated by Codelynx, LLC. Lumail does **not currently provide a customer DPA that satisfies GDPR Article 28**.

At this time:

- There is no Lumail DPA available to download, accept, or countersign.
- Lumail's standard customer terms do not incorporate the European Commission's Standard Contractual Clauses (SCCs).
- Codelynx does not claim an active EU-U.S. Data Privacy Framework certification for Lumail.
- Lumail does not offer an EU-only data-residency commitment or a completed customer transfer impact assessment.
- DPAs or transfer safeguards offered by Lumail's infrastructure providers do not form a DPA between Codelynx and a Lumail customer.

If your organization acts as a controller or processor and requires an Article 28 DPA, SCCs, or another transfer mechanism, **do not use Lumail to process the affected EEA, UK, or Swiss personal data until the necessary terms have been issued and executed**.

## Why there is no signable DPA yet

The product and its infrastructure are still evolving. Publishing a template that says "DPA" before the processing instructions, audit terms, deletion commitments, breach process, subprocessor notice procedure, transfer modules, and technical measures are ready would create a misleading contract. This status page states the present limitation instead.

The [Privacy Policy](/legal/privacy) and [GDPR in Lumail](/docs/legal/gdpr-in-lumail) describe current practices for transparency, but neither document substitutes for an executed DPA.

## Planned package

Lumail intends to prepare:

- GDPR Article 28 controller-to-processor terms
- Appropriate SCC modules for transfers that require them
- A transfer and data-location annex
- A maintained subprocessor list and advance-change notice process
- Technical and organizational measures
- Retention, return, deletion, audit, and incident-notification terms

This is a roadmap, not a binding promise or release date. The final documents may change after legal and infrastructure review.

## Requests from prospective EU customers

If your legal or procurement team needs a DPA now, the accurate answer is that Lumail cannot currently provide one. You can contact [help@codelynx.dev](mailto:help@codelynx.dev) to register interest and describe your requirements, but contacting us does not authorize EEA processing or create contractual safeguards.

When a signable DPA becomes available, this page will be replaced or updated with the download or acceptance process and the effective version date.