Every third party that touches your data, named. It is a short list, and the messaging layer is not on it.
A sub-processor is any company Lumotis uses to process clinic data on your behalf. This page lists them, says what each does and where it runs, and explains how you are told before one is added.
- Updated monthly
- Change notice in advance
- Owned messaging layer
Under the DPDP Act the clinic stays responsible for what its processor's processors do. So you need to know who they are.
The DPDP Act 2023 makes the clinic, as data fiduciary, responsible for personal data even when it is processed by others on the clinic's behalf. Lumotis Digital Media is your data processor. Anyone Lumotis in turn relies on to store, transmit or analyse that data is a sub-processor, and the clinic is entitled to know who they are, what they do and where they are.
This page is that disclosure. It is kept current, reviewed monthly, and referenced from the data processing agreement so that the list you agreed to and the list in force are the same list. Where a value has not yet been confirmed for publication it appears as a token; those are filled in at signature and on this page at the same time.
One structural point matters more than any single name. WhatsApp messaging, which is where most patient contact happens, does not go through a third-party Business Solution Provider. SaroConnect is Lumotis's own WhatsApp Business Solution Provider infrastructure. Your patients' numbers and message content are not handed to another company for delivery. The only external party in that chain is Meta, which operates WhatsApp itself.
What we commit to before, during and after adding one.
Product means Lumotis does it. Clinic means it is your right to exercise. Both means we act and you decide.
- Saaro handles it
Vet before use
A sub-processor is assessed for security posture, data location, contractual commitments and the minimum data it needs. Nothing is added because it is convenient.
- Saaro handles it
Bind by contract
Each sub-processor is under written terms that require confidentiality, security measures at least as strong as ours, processing only on our instructions, and deletion on termination.
- Saaro handles it
Minimise what each one sees
Sub-processors receive only the data their function needs. The email provider sees an address and a login code, not a prescription. Analytics sees usage events, not patient data.
- Saaro handles it
Notify before adding or replacing
Clinic owners are told by email and WhatsApp at least subprocessor notice days before a new sub-processor begins processing data, with its name, function and location.
- Your clinic
Right to object
If a clinic reasonably objects to a new sub-processor on data protection grounds, it can raise the objection within the notice period. If we cannot address it, the clinic may terminate and take its data out without penalty, per the data processing agreement.
- Saaro handles it
Review monthly
The list is reviewed monthly and the page's modified date is updated whenever anything changes, even a location or a function description.
- Shared
Keep the list in the agreement
The data processing agreement references this page by URL so that the contractual list and the published list never diverge.
- Your clinic
Ask for more detail
A clinic can request the security summary or the contractual data-protection terms for any sub-processor on the list by writing to contact email.
The parts of the platform that are Lumotis's own, so they are not sub-processors at all.
SaroConnect messaging
Lumotis's own WhatsApp Business Solution Provider infrastructure. Templates, delivery logs and conversation state stay with us in India. No third-party BSP.
Learn morePatient records and clinical data
The application, database schema and record logic are Lumotis's. The cloud host provides the machines; it does not process the clinical content as a service.
Learn morePrescription structuring
Drug, dose and duration parsing runs within the platform. Dictation transcription is listed below where an external service is used.
Learn moreABDM integration
The connection to the ABDM gateway is Lumotis's own code. The gateway itself is government infrastructure, not a commercial sub-processor.
Learn moreAudit and access control
Role enforcement and the audit trail are part of the platform, not a bolt-on service, so no third party sees access logs.
Learn moreSupport
Support staff are Lumotis employees in India, bound by confidentiality, and access clinic data only with the clinic's permission and with every access logged.
Which sub-processor touched a given record, and when.
For a single patient record, the question 'who outside Lumotis has processed anything about this person' has a short answer, and the timeline shows it.
Storage and transmission entries name the category and the sub-processor from this list, so the disclosure on this page and the log on the record agree.
- Storage location on the record
- Message delivery through SaroConnect, then Meta
- Email entries carry no clinical content
- No analytics entries, because analytics never sees the record
- 10:20Record stored · subprocessor list cloud hosting, hosting regionStorage
- 10:31Rx sent via SaroConnect (Lumotis) to WhatsAppMessage
- 10:31Delivered over Meta WhatsApp networkTransit
- Tue 2 SepAnalytics access to recordNone
Current sub-processors.
Reviewed monthly. Last reviewed 2026-08-26. Tokens are replaced with confirmed names and locations at publication; the data processing agreement references this page.
| Function | Sub-processor | What it processes | Location |
|---|---|---|---|
| Cloud hosting | subprocessor list | Databases, file storage and backups for all clinic data, encrypted at rest | India, hosting region |
| Messaging | SaroConnect (Lumotis-owned, not a sub-processor) | WhatsApp templates, delivery logs, conversation state | India |
| Messaging network | Meta Platforms (WhatsApp) | Message content in transit between SaroConnect and the patient's phone | Global, per Meta's infrastructure |
| subprocessor list | Login codes, invoices to the clinic owner, service notices; no clinical content | subprocessor list | |
| Analytics | subprocessor list | Usage events on the website and product interface; no patient data | subprocessor list |
| Voice transcription | subprocessor list | Dictation audio, processed and discarded; no retention | voice processing region |
| ABDM gateway | National Health Authority (government, not commercial) | Consent artefacts and encrypted FHIR bundles under patient consent | India |
Swipe to see every tier
Your questions answered.
The things clinics ask first.
A company that Lumotis, as your data processor, uses to store, transmit or analyse clinic data on your behalf. Under the DPDP Act the clinic remains responsible for the data, so it is entitled to know who they are.
No. SaroConnect is Lumotis's own WhatsApp Business Solution Provider infrastructure. There is no third-party BSP. Once a message leaves SaroConnect it travels over Meta's WhatsApp network, which is inherent to WhatsApp and is disclosed above.
Yes. Owners are notified by email and WhatsApp at least {{SUBPROCESSOR_NOTICE_DAYS}} before a new sub-processor begins processing data, with its name, function and location. This page is updated at the same time.
Yes, within the notice period, on data protection grounds. If we cannot address the objection, the clinic may terminate and export its data without penalty, as set out in the data processing agreement.
No. Analytics collects usage events on the website and product interface, such as which screen was opened. Patient names, numbers and clinical content are not sent to it.
Monthly. The date at the top of the table shows the last review, and the page's modified date changes whenever any entry changes.
Keep reading.
- FeaturesWhatsApp automationSaaro runs on SaroConnect, Lumotis's own WhatsApp Business infrastructure. Reminders, prescriptions, reports and refills go out from your number, patient replies come back to the desk, and messaging is included in every plan.
- FeaturesPatient recordsA record built from every visit, not a spreadsheet row. Prescriptions, reports, notes and follow-ups sit in one timeline, linked to the patient's ABHA if they have one.
- FeaturesVoice prescriptionSpeak it in English, Hindi, or your mix of both. Saaro structures the drug, dose and duration, flags interactions, files it to the record and sends it from your clinic's number.
- TrustData residencySaaro Health is hosted in India, in hosting region. Databases, report files, backups and the WhatsApp messaging layer are all in-country. The one thing that crosses a border is the WhatsApp message itself, and we say so.
- TrustSecurityPatient data is encrypted in transit and at rest, seen only by the roles that need it, logged every time it is touched, and backed up so it can be restored. Here is the detail behind each of those claims.
- TrustDPDP complianceConsent, notice, retention, erasure, breach reporting and grievance handling are obligations on the clinic. Here is what each one means for an OPD, and which parts the product does for you.
Want the contractual terms behind the list?
Ask for the data processing agreement on the demo call. The list on this page is written into it.