Privacy Policy

Last updated: April 2026 — Effective immediately upon publication.

This policy describes how Provectio collects, uses, stores, and protects personal data. It applies to users of the Provectio platform, buyers of Provectio editions, and clients who submit material for audit or measurement services through provectio.legal. Provectio measures. It does not advise.

1. Data controller

Provectio
Trading name of Keith Shepherd, Danish sole proprietor (enkeltmandsvirksomhed)
CVR: 40108548
Proprietor: Keith Shepherd
Address: Valdemarsvej 33, 8960 Randers SØ, Denmark
Contact: legal@provectio.legal
Privacy enquiries: legal@provectio.legal

Provectio is registered and operates under Danish law. The supervisory authority with jurisdiction over Provectio's data processing activities is the Danish Data Protection Authority, Datatilsynet (datatilsynet.dk).

2. Data we collect

We collect the following categories of personal data:

Account data: full name, email address, organisation name (optional), account creation date.
Authentication data: password hash (stored using PBKDF2-HMAC-SHA256 with a random salt; the plaintext password is never stored).
Consent records: timestamps and records of consents given or withdrawn, as required by GDPR Article 7.
Usage data: the analysis requests you submit, including submitted text and analysis results. This data is processed to deliver the service and is not retained on Provectio servers after analysis, subject to the retention rules in Section 5.
Session data: a session token stored in an HTTP-only, secure cookie, used solely to authenticate your session.
Purchase data: buyer email address, product selected, assent records, withdrawal-waiver records where applicable, and transaction references required to deliver digital products and maintain accounting records.

We do not collect payment card numbers directly. Payment processing is handled by Stripe as an independent payment processor.

3. Legal basis for processing

We process your personal data on the following legal bases under GDPR Article 6:

Consent (Article 6(1)(a)): optional marketing communications and any optional data fields that are clearly presented on a consent basis. You may withdraw consent at any time.
Contractual necessity (Article 6(1)(b)): account administration, edition delivery, payment-related records, and audit or measurement services requested by you.
Legitimate interests (Article 6(1)(f)): fraud prevention, system security, and the integrity of the governed analysis service. These interests do not override your rights.
Legal obligation (Article 6(1)(c)): where we are required to retain records by applicable law.

4. Third-party processors

Provectio uses the following third-party processors to deliver the service:

Anthropic API — analysis text is sent to the Anthropic API for semantic classification. Anthropic does not use API inputs or outputs for model training under its default API terms. Retention terms applicable to Provectio's usage are confirmed in the Data Processing Agreement for each engagement. See Anthropic's privacy policy.
Cloudflare — Cloudflare provides DDoS protection, TLS termination, and the Turnstile CAPTCHA widget used on registration and login forms. Cloudflare processes IP addresses and request metadata as part of its service. See Cloudflare's privacy policy.
Stripe — payment processing. Stripe handles all payment card data directly; no card numbers are transmitted to or stored on Provectio servers. Stripe is PCI-DSS Level 1 certified. See Stripe's privacy policy.
Hetzner Online GmbH — infrastructure hosting. Provectio's server is located in Hetzner's Helsinki, Finland data centre (within the EEA). See Hetzner's privacy policy.

We do not use Google Analytics, Facebook Pixel, or any third-party advertising or tracking technologies.

5. Data retention

Account data is retained for as long as your account remains active. When you delete your account, all associated personal data is erased immediately.
Forensic receipts (cryptographic integrity records containing metadata, integrity hashes, and analysis outputs required for verification, but not the raw input text) are retained for two years for audit verification purposes.
Consent logs are retained for as long as your account is active, and are erased with the account.
Evidence of marketing consent outlives the account, in one narrow and limited form. If you consented to marketing and later delete your account, we keep a record that consent was given and when — with your email address replaced by a keyed hash, so the record cannot be read back to identify or contact you. Its only purpose is to answer a later complaint or a supervisory authority asking whether marketing was lawfully consented to. The lawful basis is Article 17(3)(e), retention for the establishment, exercise or defence of legal claims. The record is deleted automatically five years after the account is erased. Consents relating to service delivery are not kept in this way, because that processing rests on contractual necessity rather than consent.
Submitted analysis text is not stored on Provectio servers after the analysis is complete.
Billing and payment data (transaction records, invoice references) is retained for seven years as required by Danish bookkeeping legislation (bogforingsloven). Payment card details are held by Stripe, not by Provectio.
Email captures from downloads and purchases (email address and related delivery metadata submitted via the download or purchase gate) are retained for as long as needed to deliver the requested product, maintain re-download support, and preserve the associated transaction record, unless a longer retention period is required by law.

6. Cookies

Provectio uses a single session cookie:

Name: provectio_session
Purpose: authenticates your session after sign-in.
Duration: 24 hours.
Flags: HTTP-only, Secure, SameSite=Lax. The cookie cannot be read by client-side JavaScript and is not transmitted over unencrypted connections.

We do not use tracking cookies, analytics cookies, or advertising cookies. No cookie banner is displayed because no consent-requiring cookies are set.

7. Your rights under GDPR

As a data subject in the European Economic Area, you have the following rights. To exercise any of them, contact legal@provectio.legal or use the automated tools listed below.

Right	Article	How to exercise
Right of access — obtain a copy of all data we hold about you	Art. 15	Sign in and call `GET /auth/export-data`, or email legal@provectio.legal
Right to rectification — correct inaccurate personal data	Art. 16	Email legal@provectio.legal
Right to erasure — delete your account and all associated data	Art. 17	Sign in and call `DELETE /auth/delete-account`, or email legal@provectio.legal
Right to restriction of processing	Art. 18	Email legal@provectio.legal
Right to data portability — receive your data in a structured, machine-readable format	Art. 20	The `GET /auth/export-data` endpoint returns JSON. Email us if you require another format.
Right to withdraw consent at any time, without affecting lawfulness of prior processing	Art. 7(3)	Email legal@provectio.legal
Right to object to processing	Art. 21	Email legal@provectio.legal

We respond to data subject requests within 30 days. There is no charge for requests unless they are manifestly unfounded or excessive.

8. Supervisory authority

If you believe your rights have not been respected, you have the right to lodge a complaint with the Danish Data Protection Authority:

Datatilsynet
Carl Jacobsens Vej 35
2500 Valby, Denmark
datatilsynet.dk
dt@datatilsynet.dk

9. Data security

Provectio operates exclusively over HTTPS. Session tokens are signed JWTs transmitted via HTTP-only secure cookies. Passwords are stored as PBKDF2-HMAC-SHA256 hashes with unique per-user salts using 260,000 iterations. The plaintext password is never stored or logged. Database access is restricted to the application process.

10. International transfers

Provectio's primary infrastructure is hosted by Hetzner Online GmbH in Helsinki, Finland, within the European Economic Area.

Two processors involve transient data transfers to the United States:

Anthropic, PBC (San Francisco, USA) processes analysis text via its API. Anthropic does not use API inputs or outputs for model training under its default API terms. Retention terms applicable to Provectio's usage are confirmed in the Data Processing Agreement for each engagement. Cross-border transfer safeguards are documented in the applicable contractual documentation for the engagement, including Standard Contractual Clauses where required.
Stripe, Inc. (San Francisco, USA) processes payment data. Stripe maintains its own international transfer mechanisms and privacy documentation for payment processing.

Cloudflare, Inc. may route traffic through non-EEA points of presence as part of its CDN and DDoS protection services. Cloudflare maintains its own transfer safeguards and privacy documentation for those services.

11. Changes to this policy

We may update this policy when the service changes. Material changes will be communicated by email to registered users. The effective date at the top of this page shows when the current version came into force.

12. Contact

Questions about this policy or about how Provectio handles personal data should be directed to legal@provectio.legal.