Data Processing Agreement

Last updated 25 October 2026

This agreement applies when Kodeo Labs Ab (“we”, the processor) processes personal data on behalf of a customer (the controller) in Lisvo. It is built on the standard contractual clauses between controllers and processors that the European Commission adopted under Article 28(7) of the GDPR (Commission Implementing Decision (EU) 2021/915). The clauses are reproduced unchanged. The options they leave open are chosen below, and Annexes I to IV describe what Lisvo actually does: the processing, the security measures, the sub-processors and the deletion routines.

Part A: How this agreement applies

A1. What it covers. The personal data we process on the customer’s behalf when it uses Lisvo: reviews, feedback, replies and the data derived from them, as described in Annex II (the “Customer Personal Data”). It does not cover personal data for which we decide the purposes ourselves: our website, early-access requests, user accounts, sign-in records and messages to us. There we are the controller, and the Privacy Policy applies.

A2. Who it applies to, and when. It forms part of the Terms of Service and applies to every customer from the day the customer’s workspace is created, including a free early-access pilot. The customer accepts it expressly, in writing: by confirming, for example by email, that it accepts the Terms of Service and this agreement, each in the version we name by its “Last updated” date, or by signing it. In that confirmation the customer gives the details Annex I asks for: its legal name, its address and its contact person. We set up the workspace after that. It is a contract in electronic form, as Article 28(9) of the GDPR allows.

A3. A customer that is itself a processor. If the customer processes the data for someone else (for example an agency managing a client’s apps), it confirms that it is authorised to give us the instructions in this agreement for that controller, and to engage us as its sub-processor on these terms.

A4. Instructions. The customer’s documented instructions are this agreement, the Terms of Service, and the customer’s own use of Lisvo’s features: connecting a store account, switching Autopilot on for an app, creating a webhook, deleting an app. Further instructions are given in writing to support@lisvo.io.

A5. Requests from reviewers and other data subjects. If a person contacts us about Customer Personal Data, we do not answer on the customer’s behalf. Without undue delay we refer the person to the customer, or forward the request to the customer with only the information that is needed. We delete Customer Personal Data on the customer’s instruction, or where the law requires it.

A6. At the end. When the customer’s account is closed, or the customer asks, we delete the Customer Personal Data within 30 days (Clause 10(d)). On request we first prepare a copy of it for the customer, and on request we confirm the deletion in writing. Copies in our hosting provider’s database backups expire on the provider’s schedule and cannot be edited: see Annex II.

A7. Sub-processors. The customer gives its general authorisation (Clause 7.7(a), Option 2) to the sub-processors in Annex IV. We tell the customer of an intended change at least 30 days in advance, by email to the workspace owner, with what the customer needs to object. If the customer objects on reasonable grounds and we cannot accommodate it, either of us may end the agreement.

A8. Precedence. On personal data, the Clauses prevail over the Terms of Service (Clause 4). Liability is governed by the Terms of Service.

Part B: The Standard Contractual Clauses

The Clauses below are the Annex to Commission Implementing Decision (EU) 2021/915 of 4 June 2021 (OJ L 199, 7.6.2021, p. 18), unchanged (Clause 2). Options chosen: Regulation (EU) 2016/679 only, in Clauses 1(a), 8(c) and 9; general written authorisation of sub-processors with 30 days’ notice, in Clause 7.7(a) (Option 2). Clause 5, the optional docking clause, is not used.

Section I

Clause 1: Purpose and scope

(a) The purpose of these Standard Contractual Clauses (the Clauses) is to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

(b) The controllers and processors listed in Annex I have agreed to these Clauses in order to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 and/or Article 29(3) and (4) of Regulation (EU) 2018/1725.

(d) Annexes I to IV are an integral part of the Clauses.

(e) These Clauses are without prejudice to obligations to which the controller is subject by virtue of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(f) These Clauses do not by themselves ensure compliance with obligations related to international transfers in accordance with Chapter V of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

Clause 2: Invariability of the Clauses

(a) The Parties undertake not to modify the Clauses, except for adding information to the Annexes or updating information in them.

(b) This does not prevent the Parties from including the standard contractual clauses laid down in these Clauses in a broader contract, or from adding other clauses or additional safeguards provided that they do not directly or indirectly contradict the Clauses or detract from the fundamental rights or freedoms of data subjects.

Clause 3: Interpretation

(a) Where these Clauses use the terms defined in Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively, those terms shall have the same meaning as in that Regulation.

(b) These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively.

(c) These Clauses shall not be interpreted in a way that runs counter to the rights and obligations provided for in Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or in a way that prejudices the fundamental rights or freedoms of the data subjects.

Clause 4: Hierarchy

In the event of a contradiction between these Clauses and the provisions of related agreements between the Parties existing at the time when these Clauses are agreed or entered into thereafter, these Clauses shall prevail.

Clause 5: Docking clause (optional)

Not used. The Parties have not included the optional docking clause.

Section II: Obligations of the Parties

Clause 6: Description of processing(s)

The details of the processing operations, in particular the categories of personal data and the purposes of processing for which the personal data is processed on behalf of the controller, are specified in Annex II.

Clause 7: Obligations of the Parties

7.1 Instructions

(a) The processor shall process personal data only on documented instructions from the controller, unless required to do so by Union or Member State law to which the processor is subject. In this case, the processor shall inform the controller of that legal requirement before processing, unless the law prohibits this on important grounds of public interest. Subsequent instructions may also be given by the controller throughout the duration of the processing of personal data. These instructions shall always be documented.

(b) The processor shall immediately inform the controller if, in the processor’s opinion, instructions given by the controller infringe Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or the applicable Union or Member State data protection provisions.

7.2 Purpose limitation

The processor shall process the personal data only for the specific purpose(s) of the processing, as set out in Annex II, unless it receives further instructions from the controller.

7.3 Duration of the processing of personal data

Processing by the processor shall only take place for the duration specified in Annex II.

7.4 Security of processing

(a) The processor shall at least implement the technical and organisational measures specified in Annex III to ensure the security of the personal data. This includes protecting the data against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to the data (personal data breach). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purposes of processing and the risks involved for the data subjects.

(b) The processor shall grant access to the personal data undergoing processing to members of its personnel only to the extent strictly necessary for implementing, managing and monitoring of the contract. The processor shall ensure that persons authorised to process the personal data received have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

7.5 Sensitive data

If the processing involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions and offences (“sensitive data”), the processor shall apply specific restrictions and/or additional safeguards.

7.6 Documentation and compliance

(a) The Parties shall be able to demonstrate compliance with these Clauses.

(b) The processor shall deal promptly and adequately with inquiries from the controller about the processing of data in accordance with these Clauses.

(c) The processor shall make available to the controller all information necessary to demonstrate compliance with the obligations that are set out in these Clauses and stem directly from Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725. At the controller’s request, the processor shall also permit and contribute to audits of the processing activities covered by these Clauses, at reasonable intervals or if there are indications of non-compliance. In deciding on a review or an audit, the controller may take into account relevant certifications held by the processor.

(d) The controller may choose to conduct the audit by itself or mandate an independent auditor. Audits may also include inspections at the premises or physical facilities of the processor and shall, where appropriate, be carried out with reasonable notice.

(e) The Parties shall make the information referred to in this Clause, including the results of any audits, available to the competent supervisory authority/ies on request.

7.7 Use of sub-processors

(a) The processor has the controller’s general authorisation for the engagement of sub-processors from an agreed list. The processor shall specifically inform in writing the controller of any intended changes of that list through the addition or replacement of sub-processors at least 30 days in advance, thereby giving the controller sufficient time to be able to object to such changes prior to the engagement of the concerned sub-processor(s). The processor shall provide the controller with the information necessary to enable the controller to exercise the right to object.

(b) Where the processor engages a sub-processor for carrying out specific processing activities (on behalf of the controller), it shall do so by way of a contract which imposes on the sub-processor, in substance, the same data protection obligations as the ones imposed on the data processor in accordance with these Clauses. The processor shall ensure that the sub-processor complies with the obligations to which the processor is subject pursuant to these Clauses and to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(c) At the controller’s request, the processor shall provide a copy of such a sub-processor agreement and any subsequent amendments to the controller. To the extent necessary to protect business secret or other confidential information, including personal data, the processor may redact the text of the agreement prior to sharing the copy.

(d) The processor shall remain fully responsible to the controller for the performance of the sub-processor’s obligations in accordance with its contract with the processor. The processor shall notify the controller of any failure by the sub-processor to fulfil its contractual obligations.

(e) The processor shall agree a third party beneficiary clause with the sub-processor whereby - in the event the processor has factually disappeared, ceased to exist in law or has become insolvent - the controller shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the personal data.

7.8 International transfers

(a) Any transfer of data to a third country or an international organisation by the processor shall be done only on the basis of documented instructions from the controller or in order to fulfil a specific requirement under Union or Member State law to which the processor is subject and shall take place in compliance with Chapter V of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725.

(b) The controller agrees that where the processor engages a sub-processor in accordance with Clause 7.7. for carrying out specific processing activities (on behalf of the controller) and those processing activities involve a transfer of personal data within the meaning of Chapter V of Regulation (EU) 2016/679, the processor and the sub-processor can ensure compliance with Chapter V of Regulation (EU) 2016/679 by using standard contractual clauses adopted by the Commission in accordance with of Article 46(2) of Regulation (EU) 2016/679, provided the conditions for the use of those standard contractual clauses are met.

Clause 8: Assistance to the controller

(a) The processor shall promptly notify the controller of any request it has received from the data subject. It shall not respond to the request itself, unless authorised to do so by the controller.

(b) The processor shall assist the controller in fulfilling its obligations to respond to data subjects’ requests to exercise their rights, taking into account the nature of the processing. In fulfilling its obligations in accordance with (a) and (b), the processor shall comply with the controller’s instructions

(c) In addition to the processor’s obligation to assist the controller pursuant to Clause 8(b), the processor shall furthermore assist the controller in ensuring compliance with the following obligations, taking into account the nature of the data processing and the information available to the processor:

(1) the obligation to carry out an assessment of the impact of the envisaged processing operations on the protection of personal data (a ‘data protection impact assessment’) where a type of processing is likely to result in a high risk to the rights and freedoms of natural persons;

(2) the obligation to consult the competent supervisory authority/ies prior to processing where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the controller to mitigate the risk;

(3) the obligation to ensure that personal data is accurate and up to date, by informing the controller without delay if the processor becomes aware that the personal data it is processing is inaccurate or has become outdated;

(4) the obligations in Article 32 of Regulation (EU) 2016/679.

(d) The Parties shall set out in Annex III the appropriate technical and organisational measures by which the processor is required to assist the controller in the application of this Clause as well as the scope and the extent of the assistance required.

Clause 9: Notification of personal data breach

In the event of a personal data breach, the processor shall cooperate with and assist the controller for the controller to comply with its obligations under Articles 33 and 34 of Regulation (EU) 2016/679 or under Articles 34 and 35 of Regulation (EU) 2018/1725, where applicable, taking into account the nature of processing and the information available to the processor.

9.1 Data breach concerning data processed by the controller

In the event of a personal data breach concerning data processed by the controller, the processor shall assist the controller:

(a) in notifying the personal data breach to the competent supervisory authority/ies, without undue delay after the controller has become aware of it, where relevant/(unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons);

(b) in obtaining the following information which, pursuant to Article 33(3) of Regulation (EU) 2016/679, shall be stated in the controller’s notification, and must at least include:

(1) the nature of the personal data including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned;

(2) the likely consequences of the personal data breach;

(3) the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

(c) in complying, pursuant to Article 34 of Regulation (EU) 2016/679, with the obligation to communicate without undue delay the personal data breach to the data subject, when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons.

9.2 Data breach concerning data processed by the processor

In the event of a personal data breach concerning data processed by the processor, the processor shall notify the controller without undue delay after the processor having become aware of the breach. Such notification shall contain, at least:

(a) a description of the nature of the breach (including, where possible, the categories and approximate number of data subjects and data records concerned);

(b) the details of a contact point where more information concerning the personal data breach can be obtained;

(c) its likely consequences and the measures taken or proposed to be taken to address the breach, including to mitigate its possible adverse effects.

The Parties shall set out in Annex III all other elements to be provided by the processor when assisting the controller in the compliance with the controller’s obligations under Articles 33 and 34 of Regulation (EU) 2016/679.

Section III: Final provisions

Clause 10: Non-compliance with the Clauses and termination

(a) Without prejudice to any provisions of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725, in the event that the processor is in breach of its obligations under these Clauses, the controller may instruct the processor to suspend the processing of personal data until the latter complies with these Clauses or the contract is terminated. The processor shall promptly inform the controller in case it is unable to comply with these Clauses, for whatever reason.

(b) The controller shall be entitled to terminate the contract insofar as it concerns processing of personal data in accordance with these Clauses if:

(1) the processing of personal data by the processor has been suspended by the controller pursuant to point (a) and if compliance with these Clauses is not restored within a reasonable time and in any event within one month following suspension;

(2) the processor is in substantial or persistent breach of these Clauses or its obligations under Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725;

(3) the processor fails to comply with a binding decision of a competent court or the competent supervisory authority/ies regarding its obligations pursuant to these Clauses or to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(c) The processor shall be entitled to terminate the contract insofar as it concerns processing of personal data under these Clauses where, after having informed the controller that its instructions infringe applicable legal requirements in accordance with Clause 7.1 (b), the controller insists on compliance with the instructions.

(d) Following termination of the contract, the processor shall, at the choice of the controller, delete all personal data processed on behalf of the controller and certify to the controller that it has done so, or, return all the personal data to the controller and delete existing copies unless Union or Member State law requires storage of the personal data. Until the data is deleted or returned, the processor shall continue to ensure compliance with these Clauses.

Annexes

Annex I: List of parties

Controller

Name: the customer, as it names itself in its written acceptance
Address: as the customer gives it in its written acceptance
Contact person: as the customer names them in its written acceptance (name, position and email); until it names another, the workspace owner
Signature and accession date: the date of the customer’s written acceptance (an email counts) of the Terms of Service and this agreement, in the versions named by their dates; or the date of signature if the customer signs. The agreement applies from the day the workspace is created

Processor

Name: Kodeo Labs Ab, business ID 3122668-6, registered in Jomala, Åland, Finland
Address: registered office in Jomala, Åland, Finland. We give the postal address on request.
Data protection officer: none appointed. Contact person: the person responsible for privacy at Kodeo Labs Ab, support@lisvo.io
Signature and accession date: as for the controller; Kodeo Labs Ab accepts by naming the versions in its email, or by signing

Annex II: Description of the processing

Categories of data subjects

People who write reviews of the customer’s apps in the Apple App Store or Google Play (“reviewers”).
People who send feedback through the customer’s own apps (the customer’s end users).
Anyone who is named or described in the text of a review, a feedback message or a reply.

Categories of personal data

Reviews: the reviewer’s public nickname; the rating, title and text of the review (free text, which can contain any personal data the reviewer chose to write); language, country, app version and date; and the replies sent to it.
Feedback: the message text; an email address, if the end user gave one; and whatever other data the customer’s own app sends with the message.
Derived data: translations, summaries, topics and sentiment, reply drafts, and the records of automatic reply decisions (the reply, the confidence, the flags, the reason and the instructions that applied).
Webhook events and their delivery records, which carry the data above to the addresses the customer has set.

Not processed: reviewers’ real names or email addresses (the stores do not give them to us), and the customer’s store account passwords (we never ask for them).

Sensitive data, and the restrictions and safeguards applied

None is sought. Free text can contain data of any kind, including sensitive data, and Lisvo cannot detect it with certainty. The safeguards are:

Autopilot never sends a reply when it flags a sensitive subject (privacy, billing, account, data loss, legal or security) or is unsure: it leaves the review to the customer’s people. It is off until an owner switches it on for an app, and it answers only reviews posted after that.
Strict purpose limitation, as set out below and in Clause 7.2.
Lisvo’s systems process Customer Personal Data automatically. Our own people open it only when that is necessary for a legitimate purpose: support, troubleshooting, security, running the service or a legal obligation. They do not read it otherwise. For data obtained through Google’s Play APIs, access is limited further, as Google’s API Services User Data Policy (Limited Use) requires.
The data sent to the AI sub-processor is limited, as Annex III describes.

Nature of the processing

Storing; showing the data to the customer’s users; translating and analysing review text (language, sentiment, topics, a summary); drafting replies; deciding whether an automatic reply may be sent; publishing replies to the stores under the customer’s own developer account when the customer, or Autopilot, sends them; forwarding events to the webhook addresses the customer sets; and deleting.

Purposes of the processing

To provide Lisvo to the customer as the Terms of Service describe: reading the customer’s reviews and feedback, translating and analysing them, drafting and sending replies, and showing the results. Also support, security and keeping the service running, at the customer’s request.

Duration of the processing

For as long as the customer’s account exists. Deleting an app, unlinking a store, or disconnecting a store account deletes the matching data at once. When the account is closed, or the customer asks, the Customer Personal Data is deleted within 30 days, after a copy if the customer asks for one. Copies in the database backups of our hosting provider expire on its schedule, which is currently at most 7 days, and cannot be edited; Clause 10(d) keeps the Clauses in force for them until they expire.

For sub-processors: the subject matter, nature and duration are as above, limited to what Annex IV states for each.

Annex III: Technical and organisational measures

User identification and authorisation

There are no passwords. A user signs in with a one-time code sent to their email (six random digits, valid for 10 minutes, with a limited number of attempts; sending is rate-limited per address, per IP address and overall, and can be switched off at once) or with Google or Microsoft.
Accounts are created by us for the people the customer names. There is no self-signup.
The API is reached with a short-lived access token (15 minutes, kept in the browser’s memory only) and a refresh token in an HttpOnly cookie (60 days; Secure and SameSite=Lax in production).
Every request to the product API is authenticated through one component that looks up the user’s workspace membership each time. A workspace whose subscription is inactive becomes read-only.
There are two roles, owner and member. Only an owner can connect or disconnect store accounts, create webhooks and feedback keys, delete apps or unlink stores, and switch Autopilot on or change it.
Customers are kept apart: every request selects data through the user’s own workspace. Automated tests check that one workspace cannot read or change another’s data, including in the scheduled jobs, Autopilot, feedback intake and webhooks.

Protection of data in transmission

All traffic that carries Customer Personal Data uses HTTPS. The API redirects to HTTPS and sets HTTP Strict Transport Security (30 days).
Events sent to the customer’s webhook addresses use HTTPS only, are signed with HMAC-SHA256 and a secret of its own for each address, and are never sent to a non-public address: the destination is checked on every delivery.
Apple’s incoming notifications are verified by an HMAC-SHA256 signature over the raw body and are processed once.

Protection of data in storage, and encryption

The customer’s store credentials (Google’s refresh token, the Apple API key and Apple’s webhook secrets) are encrypted in the database at the application level, are never shown again and are never written to logs. The key is held in the service’s environment, apart from the database.
The database and its backups are encrypted at rest by the hosting provider.
Feedback API keys are stored only as SHA-256 hashes, shown once when created, limited to one app and revocable.
Review text is stored as received: no pseudonymisation is applied to it.
Images the customer uploads (app icons, workspace logos) are checked before they are served; SVG files are sanitised by an allow-list.

Data minimisation, including towards the AI sub-processor

To analyse, translate and draft replies, the following is sent to the AI sub-processor: the review’s title and text, its rating, language and store; any reply already posted to it; the sentiment and type of issue from our own analysis of it; the app’s topic labels, name and description; the customer’s own reply instructions; and the text to be translated when someone asks for a translation (a review, a reply or a draft reply). Reviewers’ nicknames and email addresses, and all account data, are not sent. Feedback messages from the customer’s apps are not sent to it at all.
Our record of AI use holds token counts, the model and the cost, and no text.

Availability, resilience and restoring

The API and the database run with a hosting provider (Annex IV), which keeps database backups for a limited time, so that the database can be restored after a technical incident.

Logging and accountability

Every automatic reply decision is stored with the reply, the confidence, the flags, the reason and the instructions it ran under, so that it can be explained afterwards.
Login-code emails are logged (address, IP address, time) and the log is deleted after 30 days.
Each account closure leaves a record (time and workspace id, no personal data) that is kept outside the database, so that it can be shown that the deletion was carried out.

Limited retention, erasure and portability

Deleting an app, unlinking a store or disconnecting a store account deletes the matching data at once. Disconnecting a Google Play account also asks Google to revoke the access token.
Closing an account deletes the workspace and everything under it (apps, reviews, replies, decisions, feedback, webhooks, store connections), asks Google to revoke its tokens, and deletes the people who only used it. The procedure is tested automatically.
On request we prepare a copy of the Customer Personal Data for the customer.

Organisational measures

Access to production systems and to Customer Personal Data is limited to the people at Kodeo Labs Ab who need it to run the service, and they are bound by confidentiality (Clause 7.4(b)).
Lisvo’s systems process Customer Personal Data automatically. Our own people open it only when that is necessary for a legitimate purpose: support, troubleshooting, security, running the service or a legal obligation. They do not read it otherwise. For data obtained through Google’s Play APIs, access is limited further, as Google’s API Services User Data Policy (Limited Use) requires.
Every sub-processor is engaged under data processing terms that bind it to the same obligations (Clause 7.7(b)).
Kodeo Labs Ab holds no security certification and does not claim one.

Assistance to the controller (Clauses 8 and 9)

Requests from data subjects (Clause 8(a) and (b)). We do not answer on the customer’s behalf. Without undue delay we refer the person to the customer, or forward the request to the customer with only the information that is needed. The customer can delete an app, a store link or a webhook itself; for anything else we act on a written instruction to support@lisvo.io.
Impact assessments and prior consultation (Clause 8(c)). On request we provide the information in this agreement and answer the controller’s reasonable questions about the processing.
Personal data breach (Clause 9.2). We notify the customer’s workspace owner by email without undue delay after we become aware of a breach, with the information Clause 9.2 lists, name support@lisvo.io as the contact point, and keep the customer informed as we learn more.
Questions and audits (Clause 7.6). We answer the controller’s questions about the processing promptly and provide information about our measures on request.

Annex IV: List of sub-processors

The customer has given its general authorisation to the sub-processors below (Clause 7.7(a), Option 2). This list is the agreed list that Clause 7.7(a), Option 2 refers to. We announce a change to this list at least 30 days in advance, as Part A says.

Render Services, Inc., 525 Brannan St, San Francisco, CA 94131, United States of America. Contact: Render’s Privacy Team, privacy@render.com (as stated in its data processing terms, render.com/dpa).
- Processing: hosts the Lisvo API, the scheduled jobs and the PostgreSQL database in which all Customer Personal Data is stored. The API and the database run in Render’s Frankfurt (Germany) region.
- Transfers: Render takes part in the EU-US Data Privacy Framework (listed as active, checked 2026-10-25) and its data processing terms include the standard contractual clauses.
- Render’s own sub-processors, including Cloudflare at its network edge, are listed at render.com/trust.
OpenAI (OpenAI Ireland Ltd for customers in the European Economic Area, with its group company OpenAI OpCo, LLC, 1455 3rd Street, San Francisco, CA 94158, United States of America). Contact: Data Protection Officer, privacy@openai.com (as stated in its data processing terms, openai.com/policies/data-processing-addendum).
- Processing: analyses and translates review text, drafts replies and helps decide whether an automatic reply may be sent. It receives only what Annex III lists, in requests sent with OpenAI’s storage option switched off. OpenAI may still keep the text for up to 30 days to monitor for abuse (zero data retention is not enabled), and it does not use API data to train its models by default; we have not opted in to sharing data with OpenAI. No processing region is configured, so the text can be processed in the USA and wherever else OpenAI operates.
- Transfers: the standard contractual clauses in its data processing terms. OpenAI is not on the Data Privacy Framework list.
- Its sub-processors are listed at openai.com/policies/sub-processor-list.

Not sub-processors: Apple and Google (the customer’s own store accounts, used on the customer’s instruction), Netlify (serves the app’s static files and receives no Customer Personal Data), Resend (login-code emails) and Spaceship (email). The Privacy Policy lists the providers we use for our own processing.