> For the complete documentation index, see [llms.txt](https://docs.acolad.ai/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://docs.acolad.ai/commercial-and-legal/privacy-policy-notification.md). # Privacy Policy Notification {% file src="/files/YlSH7Uuj4FgYORJ706RB" %} ## Privacy Policy Notification This Privacy Policy explains how Acolad Luxembourg (“Acolad”, “we”, “us”) processes personal data in connection with the use of Lia Go, an AI-based translation, content, and multimedia service (the “Service”). This Privacy Policy applies exclusively to business users acting on behalf of a legal entity. Lia Go is not intended for consumer or private use. ### 1. Roles and Responsibilities #### 1.1 Data Controller and Processor Roles * Acolad Luxembourg acts as data controller for personal data relating to: * user accounts and authentication * workspace and access management * billing, payments, and subscriptions * security, monitoring, logs, and compliance * communications and support * user profile and preference data * Customers act as data controllers for personal data contained in content submitted to the Service (“Customer Content”), including Input and Output. * Acolad Luxembourg acts as data processor for Customer Content on behalf of the Customer, in accordance with the applicable Data Processing Agreement (DPA). ### 2. Categories of Personal Data Processed #### 2.1 Account, Authentication, and Profile Data * Name and business contact details (e.g. email address) * User role and workspace association * Authentication and access identifiers * Authentication data received from third-party identity providers (such as Google or Microsoft), limited to what is necessary to create and manage user accounts * Optional profile information provided by the user, such as display name and avatar #### 2.2 Usage, Preference, and Technical Data * Usage events and feature interactions * User preferences and settings (such as interface language and display mode) * Log data, timestamps, IP address * Device, browser, and session metadata * Error and performance diagnostics #### 2.3 Billing and Subscription Data * Subscription details * Invoicing and payment status * Payment identifiers Acolad does not receive or store full payment card details. Payment card information is processed directly by Acolad’s payment service provider in accordance with applicable payment security standards. #### 2.4 Customer Content (Processor Role) * Text, files, audio, or other materials uploaded by or on behalf of the Customer * Generated Output derived from such content ### 3. Purposes and Legal Bases of Processing Acolad processes personal data for the following purposes:
PurposeLegal Basis
Providing and operating the ServicePerformance of a contract
User authentication, profile management, and access controlPerformance of a contract
Billing, invoicing, and paymentsPerformance of a contract
Security, fraud prevention, and abuse detectionLegitimate interests
Service monitoring, reliability, configuration, and improvementLegitimate interests
Legal compliance and enforcementLegal obligation
Where Acolad acts as processor, processing is carried out solely on the Customer’s documented instructions. ### 4. Use of AI and Automated Processing Customer Content may be processed using AI-based systems to deliver the Service. Acolad does not use Customer Content to train general-purpose AI models. Acolad may process limited Input and Output data for internal, non-public purposes such as: * quality monitoring * system evaluation * prompt optimization * routing and debugging Such processing does not involve external disclosure of Customer Content in an identifiable manner. ### 5. Data Sharing and Subprocessors Acolad may share personal data with: * infrastructure and cloud providers * AI service providers * payment processors * analytics, monitoring, and security providers Subprocessors are engaged in accordance with GDPR Article 28. An up-to-date Subprocessor List is made available by Acolad on demand. ### 6. Data Location and International Transfers #### 6.1 Primary Hosting Acolad ensures that the primary storage and hosting of Customer Content (including Input and Output) is located within the European Economic Area (EEA). #### 6.2 International Transfers Personal data may be processed outside the EEA only where required for specific Service delivery (e.g., via global AI model providers). In such cases, Acolad ensures that such transfers are subject to appropriate safeguards in accordance with Chapter V of the GDPR, including Adequacy Decisions or Standard Contractual Clauses. ### 7. Data Retention * Account, profile, preference, billing, and usage data are retained for as long as necessary to provide the Service and comply with legal obligations. * Customer Content is retained until deleted by the Customer or upon Workspace closure, subject to technical and legal retention requirements. * Limited technical data (e.g. logs and backups) may be retained for security, audit, dispute resolution, and compliance purposes. ### 8. Security Measures Acolad implements appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or disclosure, including: * access controls * encryption in transit * monitoring and logging * role-based permissions ### 9. Data Subject Rights Where Acolad acts as data controller, data subjects may exercise their rights under applicable data protection law, including: * right of access * right to rectification * right to erasure * right to restriction of processing * right to object Requests relating to Customer Content must be addressed to the relevant Customer as data controller. Acolad will provide reasonable assistance where required by law. Data subjects also have the right to lodge a complaint with the Luxembourg National Commission for Data Protection (CNPD). ### 10. Cookies and Similar Technologies The Service uses cookies and similar technologies for authentication, security, functionality and analytics. Our Cookie Policy describes the cookies we use, what each one does, who provides it and how long it lasts. You can read it and change your choices at any time in the Service, under :circle-question: *(Help) > Cookie preferences*. Where consent is required for non-essential cookies, we ask for it before those cookies are set, and you can withdraw it at any time in the same place. ### 11. Changes to this Privacy Policy Notification Acolad may update this Privacy Policy from time to time. Material changes will be communicated through the Service or by email. ### 12. Contact Details Data controller: Acolad Luxembourg Registered address: 14–16 Avenue Pasteur, L-2310 Luxembourg [Data Protection Officer (DPO)](mailto:data-protection-team@acolad.com) [Privacy contact](mailto:data-protection-team@acolad.com) --- # Agent Instructions This documentation is published with GitBook. GitBook is the documentation platform designed so that both humans and AI agents can read, navigate, and reason over technical content effectively. Learn more at gitbook.com. ## Querying This Documentation If you need additional information that is not directly available in this page, you can query the documentation by asking a question. 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