Draft — pending legal review
This page has not been reviewed by counsel and is not yet in force. Text in [[double brackets]] is a placeholder for a decision the business still has to make.
Data Processing Addendum
Last updated: [[LAST UPDATED DATE]]
A plain-language summary of the DPA that covers personal data you process through Livqeno, where it stands today, and how to get a copy to sign. The full template governs if it differs from this summary.
1.What the DPA is
When your app sends your end users’ personal data through Livqeno (audio and video, chat, identities, telemetry, push tokens, attachments, live streams), you are the controller and Livqeno is your processor. Article 28 of the GDPR and UK GDPR requires a contract between us for that processing. The Data Processing Addendum (DPA) is that contract. It forms part of our Terms of Service.
For your own developer account data, Livqeno is an independent controller, and our Privacy Policy applies instead.
2.Current status
Full template: [[DPA TEMPLATE URL — set DPA_TEMPLATE_URL in src/lib/legal.ts]]. Until it is published, request a copy as described in section 6.
3.Key terms
| Topic | What the DPA says |
|---|---|
| Instructions | We process your end users’ data only on your documented instructions: the agreement, the DPA, and how you configure the Services (API calls, project settings, retention settings). |
| Your responsibilities | You need a lawful basis for the processing; you do not put special-category data in identifiers, room names or metadata; you configure retention (chat messages are kept until you set one); you secure your API keys and backend. |
| Confidentiality | People authorised to process your data are bound by confidentiality. |
| Security | We maintain the technical and organisational measures in Annex II, summarised on our Security page, and will not reduce the overall level of security. |
| Subprocessors | General authorisation for the subprocessors on our Subprocessors page. [[30]] days’ notice of a new one, with a right to object and, if unresolved, to terminate the affected Services with a refund of prepaid fees. |
| Data subject requests | API tools for your users’ requests: chat export (GET /v1/chat/users/{userId}/export), chat erasure (DELETE /v1/chat/users/{userId}/data) and conversation deletion (DELETE /v1/chat/conversations/{room}). Requests sent to us directly are passed to you. |
| Personal data breaches | We notify you without undue delay, and within [[48]] hours of becoming aware, with what we know at the time. |
| Return and deletion | You can export data through the APIs before termination. We delete your data within [[30]] days of termination unless the law requires us to keep it. Permanent project deletion runs 30 days after it is scheduled. Backups expire on the provider’s schedule: [[BACKUP RETENTION]]. |
| Audits | We provide the information needed to show compliance (the annexes, the security whitepaper and, when they exist, third-party audit reports). You may audit once a year on [[30]] days’ notice, at your cost, under confidentiality, where that information is not enough. |
| International transfers | EU Standard Contractual Clauses (Module Two, controller to processor) and the UK International Data Transfer Addendum, where needed. [[SCC options: docking clause, Clause 17 governing law, Clause 18 forum]] |
| Liability and precedence | Liability follows the limits in the Terms. On data protection matters, the DPA prevails over the Terms. Governing law: [[GOVERNING LAW]]. |
4.Details of processing (Annex I)
| Item | Detail |
|---|---|
| Data exporter | You, the customer (controller) |
| Data importer | [[LEGAL ENTITY NAME]] (processor). Contact: [[PRIVACY CONTACT EMAIL]] |
| Data subjects | Your end users (app users, meeting participants, chat users, stream hosts and viewers) and your staff who use the dashboard |
| Personal data | Identifiers you choose; metadata you supply; chat messages, reactions and attachments; push device tokens; connection telemetry; IP addresses in transient logs; audio and video in transit; live-stream output if you use live streaming |
| Special categories | None intended. Do not send them. We cannot sign a HIPAA Business Associate Agreement today |
| Frequency | Continuous |
| Purpose | Providing real-time communication: routing media, storing and delivering chat, push, webhooks, live-stream transcoding and delivery, usage metering, troubleshooting |
| Retention | As you configure it. Connection telemetry is kept 30 days and the chat event log 7 days. Calls are not recorded |
5.What is not fully supported yet
We would rather you hear this from us than find it in a review. These items are open in the draft:
- The erasure API covers chat message content, edit history, attachments, reactions, read state, devices and blocks. Call participant records, token records and usage records cannot be erased through the API yet.
- Data processing agreements with each subprocessor are being accepted and filed.
- Written confidentiality agreements for personnel are not yet on file.
- Automated alerting is not in place yet, which limits how quickly we can detect, and so become aware of, a breach.
- Several hosting regions are still being confirmed (see the Subprocessors page).
6.How to request a signed copy
Email [[PRIVACY OR LEGAL CONTACT EMAIL]] with the subject “DPA request” and include:
- your organisation’s full legal name and registered address;
- the name, title and email address of the person who will sign;
- the email address of the Livqeno account that owns your projects;
- whether you need the UK Addendum or Swiss transfer terms;
- any changes to the template you need, with a short reason.
Until legal review is complete we can share the draft for your review, but cannot sign it. We will countersign once the DPA is final. [[SIGNING PROCESS, e.g. e-signature tool and turnaround time]]