Sub-processors
Last updated: 2 July 2026
This page lists every supplier (a "sub-processor" in UK GDPR Article 28 terms) that LESSO uses to deliver the service. We split the list in two: data sub-processors, which process customer or personal data, and platform utilities, which support the operation of the service but are not in the path of teacher prompts or generated content. This page is maintained in compliance with UK GDPR, the Data Protection Act 2018, and the Data (Use and Access) Act 2025.
Subscribe at the bottom of this page if you would like to be emailed before this list changes. Questions? support@lesso.co.uk
Data sub-processors
These suppliers process customer or personal data on LESSO's behalf. All are pinned to UK regions for the processing of LESSO customer and personal data.
| Supplier | Function | Location | Certifications | Privacy contact |
|---|---|---|---|---|
| Civo Ltd (including relax.ai) | UK-sovereign cloud infrastructure (LON1 region) hosting the LESSO application and customer data, plus primary AI inference via relax.ai. Models in use: Llama 4 Maverick 17B×128E (primary generation), DeepSeek-V4-Pro¹ and Kimi 2.6 (agentic tool-calling), Mistral-7B-Embedding (semantic search and curriculum retrieval), and Voxtral (voice transcription). relax.ai is a trademark of Civo Ltd — the same legal entity, the same DPO, the same DPA, the same UK jurisdiction. We list it once because it is one supplier. Any model hosted outside the Civo LON1 boundary triggers the 30-day change-notification process on this page. | United Kingdom (Civo LON1) | ISO 27001, Cyber Essentials Plus, G-Cloud listed | team@civo.com |
| Microsoft Azure OpenAI Service | Fallback AI inference, configuration-pinned to UK South region. Used only when the primary path is unavailable. | United Kingdom (Azure UK South) — see CLOUD Act note below | ISO 27001/27017/27018, SOC 1/2/3, EU Cloud CoC | aoaisupport@microsoft.com |
1 DeepSeek-V4-Pro naming note: "DeepSeek-V4-Pro" is relaxAI's internal identifier for their self-hosted deployment of DeepSeek's open-source v4 Pro frontier model (1M context window). This identifier was assigned by Civo / relax.ai and does not correspond to a version name released publicly by DeepSeek Ltd. The model weights are open-source and are hosted entirely within Civo LON1; LESSO does not call any API operated by DeepSeek Ltd.
Honest note on the US CLOUD Act
Microsoft is a US-headquartered processor. Even though Azure OpenAI is configured to the UK South region for LESSO, US authorities can in theory compel Microsoft to produce data via the CLOUD Act. We use Microsoft only as a fallback path; the primary AI inference for LESSO runs on Civo Ltd (LON1) — a UK-owned, UK-headquartered company whose data is subject only to UK law. We disclose this residual risk rather than hide it, and a school can request that the Azure fallback be disabled for their tenancy as part of the school agreement.
Platform utilities
These suppliers support the operation of the LESSO service (billing, transactional email) but are not in the path of teacher prompts or generated educational content.
| Supplier | Function | Location | Certifications | Privacy contact |
|---|---|---|---|---|
| Stripe Payments Europe Ltd | Subscription billing and payment processing. | Ireland (EU); card data tokenised, never touches LESSO infrastructure. | PCI-DSS Level 1, ISO 27001, SOC 1/2 | privacy@stripe.com |
| Resend | Transactional email delivery (account, billing, product notifications, this trust-hub change-notification list). | United States (mail in transit); sending domain authenticated with DKIM, SPF, DMARC. | SOC 2 Type II | privacy@resend.com |
End-to-end architecture
The diagram below shows the confirmed data path for every teacher request. All primary inference runs within the UK border (Civo LON1). The Azure UK South path is a fallback only and is clearly labelled.
Technical Architecture Q&A
Confirmed answers to the five questions most commonly raised by DPOs and procurement teams during AI supplier review. Last verified: 2 July 2026
Where are the AI models hosted?
All five models currently in use — Llama 4 Maverick, DeepSeek-V4-Pro, Kimi 2.6, Mistral-7B-Embedding, and Voxtral — are fully self-hosted within the Civo LON1 region on Civo-managed GPU infrastructure. No model is served from a cloud provider outside Civo LON1 on the primary path.
Does any data leave the UK during AI inference?
No. During inference on the primary path, no prompt, document, embedding, metadata, telemetry, tool call, or model output leaves the Civo LON1 boundary. This covers the full request lifecycle: routing, model invocation, and response delivery. The Azure UK South fallback is the only path that involves a US-headquartered company, and that path is used only when Civo LON1 is unavailable (the CLOUD Act risk on this fallback is disclosed honestly in the table above). Schools can request the Azure fallback be disabled for their tenancy.
Does LESSO call any third-party inference APIs (e.g. DeepSeek Ltd, Moonshot AI)?
No. relaxAI serves all models directly from Civo's own GPU infrastructure within LON1. LESSO does not call any external inference API provided by DeepSeek Ltd, Moonshot AI, Meta, Mistral AI, or any other third-party model vendor. The open-weight model weights are licensed under their respective open-source licences and deployed on Civo hardware.
Is relax.ai a separate sub-processor from Civo?
No. relax.ai is a trademark of Civo Ltd — the same legal entity, the same registered company, the same DPO, the same UK-sovereign infrastructure, and the same Article 28 DPA. There is one supplier (Civo Ltd) and one entry in the sub-processor table. We are not obscuring a supply-chain relationship: relax.ai is not a subsidiary, a partner, or an external service. It is a product name for the AI orchestration capability that Civo Ltd provides within its own infrastructure.
Does the 30-day change-notification commitment cover hosting location changes?
Yes, explicitly. Any change to the hosting location of any model or infrastructure component that takes it outside the Civo LON1 boundary triggers the 30-day change-notification commitment in the DPA. This means if Civo were ever to route inference to a non-LON1 location, LESSO would update this page with at least 30 days' notice and notify all subscribed DPOs automatically. Schools can object in writing within the notice window.
AI Model Governance
How LESSO selects, controls, and verifies the AI models it deploys.
Open-weight model provenance
All models currently deployed are open-weight (sometimes called open-source) foundation models: Llama 4 Maverick (Meta), DeepSeek-V4-Pro (DeepSeek open-source), Kimi 2.6 (Moonshot AI open-source), Mistral-7B-Embedding (Mistral AI), and Voxtral (Mistral AI). Each is served under its respective open-source or open-weight licence on Civo-managed GPU infrastructure within LON1. LESSO does not use any proprietary closed-model API as the primary inference path.
Model version control and updates
The specific model versions deployed are controlled by Civo Ltd within the LON1 environment. LESSO maintains the published sub-processor list to reflect the models in active use. Any update that changes the set of models — or their version identifiers — triggers an update to this page. Schools subscribed to change notifications receive an email whenever this page is updated.
No model training on school data
None of the models deployed — and no future model we deploy — is fine-tuned, adapted, or trained on prompts, conversations, documents, or generated content submitted by schools or teachers. This commitment is binding in the DPA (Article 28 UK GDPR). It applies equally to Civo Ltd / relax.ai and Microsoft Azure OpenAI Service.
Alignment between published list and active deployment
The models listed in the sub-processor table above match the models active in the production deployment at the time of the last-updated date on this page. LESSO's compliance lead verifies this alignment each time the page is updated.
How we add or change a sub-processor
Our Data Processing Agreement gives schools a contractual right to be told before a sub-processor changes. In practice that means:
- We update this page with the proposed change and the date it takes effect (minimum 30 days in advance for material changes).
- Anyone subscribed below is emailed automatically when this page is updated.
- School-controller customers can object in writing within the notice window; if we cannot accommodate the objection we honour the contract's exit and data-export terms.
Subscribe to change notifications
Be told before a LESSO sub-processor changes. Confirmation by double opt-in. Unsubscribe at any time from the link in every email.
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Questions about this page?
Privacy and data-protection matters are handled by Luke, our co-founder. support@lesso.co.uk
We aim to respond to DPO and procurement queries within two working days.
This page is part of the LESSO Trust Hub. See also our DPA, DPIA, security overview, and Privacy Policy.
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