Generative AI chatbots

Lumo

Proton’s AI assistant with encrypted saved conversations

SwitzerlandEFTAFree plan Ownership reviewed, controller unresolvedHigh non-EU dependency

Scope verdict

Ownership reviewed, controller unresolved

Proton AG is CHE-354.686.492. Proton calls Fondation Proton its primary shareholder and says a change of control needs Foundation consent. Official Foundation statutes show that the board appoints its successors and decides by majority. Proton AG’s April 2026 articles distinguish ordinary, voting-privileged and non-voting instruments, but do not identify their current holders. The Foundation’s exact voting stake and the full control arrangement remain unresolved.

How we classify services

Operational dependency warning

Relies heavily on non-European providers

Current public evidence shows 5 non-European infrastructure or email dependencies across 5 providers: Atlassian Pty Ltd, Chargebee Inc, PayPal group, Stripe Inc, Zendesk Inc. The reviewed operational path is therefore not entirely European.

Review dependencies ↓

Lumo is a hosted AI assistant operated by Proton AG in Switzerland. It supports writing, questions, files, images and projects, with guest access and Free, Plus and business plans. Proton says inference runs on infrastructure it controls in Europe.

Saved conversations use zero-access encryption, but the inference server must decrypt prompts to generate answers. Closing a normal saved conversation is not the same as deleting it; Ghost mode is a separate option. The mobile clients have GPLv3 licences, which does not establish a self-hostable version of the complete service.

Pricing

Checked 18 September 2026 in EUR: Free has limits; Plus is €12.99 monthly or €119.88 billed annually (€9.99/month equivalent). Professional is €14.99/user monthly or €143.88/user annually; business taxes may apply. Consumer tax treatment was not itemized on the price page. Subscriptions renew automatically and paid use is subject to fair use. The terms limit initial refunds to unused days within 30 days, with payment-method exceptions.

Data and operations

Infrastructure and email path

Verified operational dependencies, shown separately from ownership and from the service's core data hosting.

Core service hosting

Proton-controlled infrastructure

Provider control not verified
Location
Europe, according to Proton; exact Lumo GPU countries not established
Observed
Proton states that Lumo inference runs on servers it controls in Europe. Prompts are decrypted at the inference server; saved history uses zero-access encryption. The operator is Swiss, but its ultimate voting control remains unresolved in this review.

Public website

Proton network

Provider control not verified
Location
Not established by DNS
Observed
lumo.proton.me A 185.70.42.51; no AAAA answer at review. The public endpoint does not locate all inference, storage or backup systems.

Incoming business email

Proton Mail

European provider
Observed
MX 10 mail.protonmail.ch · 20 mailsec.protonmail.ch

Authorised outbound email

Proton SPF authorization

Provider control not verified
Location
Not established by SPF
Observed
lumo.proton.me and proton.me include _spf.protonmail.ch, which also includes _spf2.protonmail.ch. Both were expanded. These permitted senders do not establish the location or ownership of every mail-delivery workload.

Search result source

Selected partner APIs, not named in the Lumo policy

Provider control not verified
Location
Not specified
Observed
Optional web search sends a simplified request to partner APIs; Proton says the full query is not shared. A complete partner identity/location list was not established.

Supporting services

Zendesk Inc

Non-European provider
Location
United States
Observed
Customer-support data, with transfer safeguards stated. This is not a disclosed model inference provider.

Why this matters

The published disclosure lists Zendesk Inc for supporting services. Depending on the function, account or customer data may reach this non-European provider. See the source for the documented scope.

Supporting services

Atlassian Pty Ltd

Non-European provider
Location
European Union, United States and United Kingdom
Observed
Customer-support storage, according to the Lumo-specific policy.

Why this matters

The published disclosure lists Atlassian Pty Ltd for supporting services. Depending on the function, account or customer data may reach this non-European provider. See the source for the documented scope.

Payment processing

Stripe Inc

Non-European provider
Location
United States
Observed
Payment processing for paid use, with contractual transfer safeguards. This does not mean payment providers receive ordinary chat contents.

Why this matters

When this payment method is used, Stripe Inc processes payment and billing data. This role alone does not establish access to the service's other customer content.

Payment processing

PayPal group

Non-European provider
Location
United States and Singapore
Observed
Payment processing for paid use, with contractual transfer safeguards. This does not mean payment providers receive ordinary chat contents.

Why this matters

When this payment method is used, PayPal group processes payment and billing data. This role alone does not establish access to the service's other customer content.

Payment processing

Chargebee Inc

Non-European provider
Location
United States
Observed
Payment processing for paid use, with contractual transfer safeguards. This does not mean payment providers receive ordinary chat contents.

Why this matters

When this payment method is used, Chargebee Inc processes payment and billing data. This role alone does not establish access to the service's other customer content.

Supporting services

Proton-operated Sentry and mobile app stores

Provider control not verified
Location
Self-hosted Sentry; app-store processing locations not specified here
Observed
Native-app crash information may be sent to Proton. Store-level aggregate statistics follow the respective app-store policies; a no-chat-log claim does not remove all account or telemetry data.

Supporting services

ETH Zurich and EPFL, optional Apertus feedback

European provider
Location
Switzerland; complete processing-location schedule not supplied
Observed
Only when the user submits feedback for Apertus, anonymized prompt, response and feedback may be shared for evaluation, safety improvement and model training.

Public DNS records identify visible providers and routes, not every backend location or private data-region setting.

Infrastructure checked:

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