Privacy Policy

1. INTRODUCTION

2. WHAT PERSONAL DATA WE COLLECT

2.1 Data You Provide Directly

2.2 Data Collected Automatically

2.3 Data from Third Parties

3. LEGAL BASIS FOR PROCESSING

We process your personal data under the following GDPR legal bases:

3.1 Contract Performance (Article 6(1)(b))

• Providing the Service you've signed up for
• Delivering trial access
• Processing payments
• Sending invoices and billing information
• Providing customer support

3.2 Legitimate Interests (Article 6(1)(f))

• Improving our Service and user experience
• Preventing fraud and security threats
• Analyzing Service usage to understand customer needs
• Complying with legal obligations
• Marketing and business development
• B2B sales outreach and prospecting to relevant professional contacts (subject to your right to object)

3.3 Consent (Article 6(1)(a))

• Sending marketing emails, newsletters, and promotional content (opt-in)
• Recording Design Partner feedback sessions (explicit consent)
• Using cookies beyond strictly necessary (with consent banner)

3.4 Legal Obligation (Article 6(1)(c))

• Compliance with tax authorities
• Response to lawful government requests
• Fraud prevention and detection

4. HOW WE USE YOUR PERSONAL DATA

4.1 Service Delivery

• Creating and managing your account
• Delivering LivPro software and features
• Processing payments and billing
• Sending transactional emails (trial confirmations, payment receipts, password resets)
• Providing customer support

4.2 Service Improvement

• Analyzing usage patterns to improve features
• Identifying bugs and technical issues
• Understanding user needs and pain points
• Testing new features
• Optimizing performance

4.3 Marketing & Communications

• Sending newsletters (only if you've opted in)
• Announcing new features or updates
• Sending promotional content (only to opted-in subscribers)
• Conducting surveys and requesting feedback
• Remarketing on third-party platforms (with your consent via cookies)

4.4 Legal & Compliance

• Enforcing our Terms of Service
• Protecting against fraud, abuse, or security threats
• Complying with court orders or legal requests
• Maintaining audit trails for regulated industries
• Responding to legitimate data subject access requests

4.5 Business Operations

• Contacting you about your account or Service changes
• Conducting business analytics
• Creating aggregated, anonymized reports
• Training our team and customer support staff

4.6 Legitimate Business Purposes

• Sending targeted outreach to potential customers (B2B)
• Partnership and business development opportunities
• Profiling for appropriate service tier recommendations

5. DATA SHARING & THIRD PARTIES

5.1 Service Providers (Data Processors)

We share data with trusted service providers who act as Data Processors under GDPR:

5.2 Legal Requirements

We may disclose personal data when required by law:

• Court orders or legal process
• Requests from Irish Data Protection Commission
• Subpoenas from law enforcement
• Government tax authorities
• Fraud investigations

We will notify you of such requests unless legally prohibited.

5.3 Business Transfers

If LivPro is acquired, merged, or assets are sold, your data may be transferred as part of that transaction. We will provide notice and allow opt-out if applicable.

5.4 No Third-Party Marketing

We do NOT share your personal data with third parties for their marketing purposes without explicit consent.

6. INTERNATIONAL DATA TRANSFERS

6.1 EU to US Transfers

Some of our service providers are based outside the EEA (e.g. Paddle in the UK, Resend in the US). GDPR restricts transfers of personal data outside the EU/EEA.

Our Safeguards:

• Standard Contractual Clauses (SCCs) are in place with all US processors
• Privacy Shield (where applicable—though limited post-Schrems II)
• Data Binding Corporate Rules where available
• Regular assessment of data protection frameworks

Your Rights:

• You have the right to know about international transfers
• You can request information on safeguards in place
• You can object to transfers if you believe they violate GDPR

7. DATA SECURITY

7.1 Security Measures

We implement comprehensive security controls:

Technical Safeguards:

• End-to-end encryption for data in transit (TLS 1.2+)
• AES-256 encryption for data at rest
• Regular security audits and penetration testing
• Firewalls and intrusion detection systems
• Secure API authentication (OAuth 2.0, API keys)
• Regular security patches and updates

Organizational Safeguards:

• Limited employee access (need-to-know basis)
• Background checks for employees
• Data protection training for all staff
• Secure access controls and multi-factor authentication
• Confidentiality agreements with all employees

Incident Response:

• 24/7 monitoring for security threats
• Incident response plan in place
• Notification procedures for data breaches
• Contact with Irish DPC for reportable breaches (within 72 hours)

7.2 Data Breach Notification

If we discover a data breach affecting your personal data:

• We will notify you within 72 hours (or as required by law)
• We will inform the Irish Data Protection Commission
• We will provide information about the breach, affected data, and steps we're taking
• We will offer support and remediation measures

8. DATA RETENTION

We retain personal data only as long as necessary for the purpose it was collected:

Deletion:

• When a firm's trial or subscription ends, its workspace data is kept for 90 days and then permanently deleted. We email the firm's owners when access ends and again 7 days before deletion
• A firm can ask us to delete its data sooner at any time, or delete it itself in the app (Admin → Users)
• You can request deletion at any time (subject to legal obligations)
• Aggregated, anonymized data may be retained indefinitely

9. YOUR GDPR RIGHTS

Under GDPR, you have the following rights:

9.1 Right of Access (Article 15)

You have the right to obtain a copy of your personal data we hold. We will provide this in a structured, commonly-used electronic format within 30 days.

How to Request: Email: support@livpro.io, Subject: "Data Access Request"

9.2 Right of Rectification (Article 16)

You can request correction of inaccurate or incomplete data.

How to Request: Email: support@livpro.io, Subject: "Data Correction Request"

9.3 Right of Erasure (Article 17)

You can request deletion of your personal data (the "right to be forgotten") under certain conditions.

Conditions:

• Data is no longer necessary
• You withdraw consent
• You object and no legitimate interest exists
• Data is processed illegally

We may NOT delete if:

• Required by law (tax records, regulatory obligations)
• Needed for contract performance
• Required for legal claims

9.4 Right to Restrict Processing (Article 18)

You can request that we limit how we use your data while we verify accuracy or assess legitimate interests.

9.5 Right to Data Portability (Article 20)

You can request your personal data in a portable, machine-readable format (e.g., CSV) to transfer to another provider.

How to Request: Email: support@livpro.io, Subject: "Data Portability Request"

9.6 Right to Object (Article 21)

You can object to:

• Processing based on legitimate interests
• Direct marketing
• Profiling
• Automated decision-making

9.7 Right to Withdraw Consent (Article 7)

If processing is based on consent (e.g., marketing emails), you can withdraw consent at any time. Unsubscribe links are in every marketing email.

9.8 Right to Lodge a Complaint

If you believe we've violated your privacy rights, you can lodge a complaint with the Irish Data Protection Commission:

10. COOKIES & TRACKING

10.1 Types of Cookies We Use

10.2 Cookie Management

You can control cookies through:

• Browser settings: Disable cookies in your browser preferences
• Cookie banner: Accept/reject non-essential cookies on first visit
• Our preference center: Manage cookie choices anytime

We do NOT track you across unrelated websites (no cross-site tracking).

11. CHILDREN'S PRIVACY

LivPro is not designed for children under 16. We do not knowingly collect data from children.

If we become aware that we've collected data from a child under 16:

• We will delete it immediately
• We will notify parent/guardian
• We will comply with Irish Children's Rights laws

If you're under 16: Please do not use LivPro or provide personal data.

12. UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy when our practices change or to comply with legal requirements.

When we update this policy:

• We will post the updated version on this page
• The "Last Updated" date will change
• For material changes affecting your rights, we will notify you via email or prominent notice

Your continued use of LivPro after updates constitutes acceptance of the revised policy.

13. CONTACT US

For privacy questions, requests, or complaints:

14. LEGAL REFERENCES

This Privacy Policy complies with:

• GDPR (EU Regulation 2016/679)
• Data Protection Act 2018 (as amended by GDPR)
• ePrivacy Regulations (SI 2011/1.336)
• Irish Data Protection Commission guidance
• EDPB decisions (especially Schrems II on international transfers)