Privacy Policy

This policy explains how EMYL LABS SL ("Lediv" or "we") handles your personal data when you visit lediv.com, use the app at lediv.app or otherwise deal with us (the "Service"). We built Lediv to collect as little as possible. This policy is written to meet the EU GDPR, the UK GDPR, the Swiss Federal Act on Data Protection and, where they apply, US state privacy laws. Read it with our Terms of Service.

1. Who we are

The controller of your personal data is EMYL LABS SL, a Sociedad de Responsabilidad Limitada (SL) established in Spain, NIF B93790822, Calle Mari Cruz Alvarez 6, Piso 3 B, 03203 Elche, Alicante, Spain. More company details are in our Legal notice.

For any privacy question or to use your rights, write to support@lediv.com. Our service emails come from no-reply@mail.lediv.com and replies go to that same support address. Article 37 GDPR does not require us to appoint a Data Protection Officer and we have not, so send any data protection matter to support@lediv.com.

2. Our role and yours

We are the controller of the data we decide to process ourselves, such as your account, billing identifiers, the emails we send, feedback, collaboration records and technical data.

Personal data in your content. Your projects, files and assets ("User Content") may hold personal data about other people. For that data you are the controller, so you need a lawful basis to include it and must inform the people concerned. We are your processor and use it only to provide the Service, under the data processing section of our Terms of Service. That section is the contract Article 28 GDPR requires, and it applies automatically with nothing to sign. When we assess a notice about your content, enforce our acceptable-use rules or answer an authority, we act as controller instead, to meet our own legal obligations.

Visitors to sites you publish. We serve published projects under lediv.site and at domains you connect. We set no cookies on those sites and build no profile of their visitors. For your site's content, we are your processor. For the technical data every request carries, such as IP address and user agent, we are the controller. Our infrastructure provider uses it to serve the request and we use it to run and protect the service, based on our legitimate interest in operating a secure hosting service (Article 6(1)(f) GDPR). It may appear in logs deleted within 7 days. For anything your site adds itself, such as analytics, forms or cookies, you are the controller, this policy does not apply, and informing your visitors and having a lawful basis for it are up to you. Visitors should ask whoever runs a site about their data there, since we do not know who they are.

Independent controllers. These parties decide for themselves how they use data. They are Stripe and its affiliate Sold through Link, LLC, our Merchant of Record, for the data you give at Link's checkout and in your Link account (Section 7), and Google and GitHub if you sign in with them (Section 6). The customer record we create at Stripe is different, as Stripe processes it as our processor.

3. What we collect, why and for how long

The table below lists each use of your data. "Contract" means Article 6(1)(b) GDPR, "legal obligation" Article 6(1)(c) and "legitimate interests" Article 6(1)(f). Where we rely on legitimate interests, we have weighed them against your rights and found they do not override them, in part because so little data is involved and because of how we delete or anonymize it.

Backups on Cloudflare R2 keep earlier versions of deleted or changed data and daily database exports for up to 30 days, then delete them automatically. If you use Lediv in a team, we process your account and billing data to perform our contract with the team owner, who pays. Your email is a contractual requirement, as without it we cannot create your account. No law obliges you to give us data, and everything else comes from your use of the Service or is optional.

Where data comes from and who sees it

Most data comes from you, but some comes from others. Google or GitHub send your profile when you sign in with them, and GitHub your email list, used only to pick your primary verified address. We keep the id, name and email and discard the rest. Your display name starts as that name. Link shares your order details. Whoever invites you gives us your email, and whoever reports your content gives us the notice. In those two cases we tell you when we act on it.

Collaborators see only your display name and color, and presence shows them your user id too. Owners see members' emails, roles and invitation status. Invitees see the name of the project or team. Your Lediv Agent chats belong to you. Others see the agent's edits, and the owner sees the credits your seat used this period, but not what you asked.

No automated decisions

We make no automated decisions with legal or similarly significant effects on you and do no profiling (Article 22 GDPR). Lediv Agent only changes the project you ask it to change, on your instruction, and makes no decisions about you.

4. Lediv Agent

Nothing goes to a model provider until you run a task (see the Lediv Agent section of our Terms of Service). Then we send your message, the chat so far, the file tree, the files the agent reads and your selection, plus two one-way hashes, of the project owner's account id for prompt caching and of yours for misuse screening. Never your name or email.

It goes to OpenRouter, Inc., our processor, which runs the model on Microsoft Azure as its subprocessor, possibly outside the EU under the safeguards in Section 8. OpenRouter deletes each request and its reply as soon as the reply is complete and keeps only metadata such as token counts and cost. No one, including us, uses them to train models. If your project holds personal data about others, the agent may send it, so only run it on such data if you have a lawful basis. You are its controller and we are your processor, with OpenRouter and Microsoft as our subprocessors.

We keep each chat for 30 days after its last task, up to 10 per project (an 11th deletes the least recently used), or until you delete it, the project, your access or your account. Chats are never in our backups. Restore records hold positions, not content, for 24 hours for your last 20 tasks. Log lines hold only ids and counts and last 7 days. Credit counters are kept per seat for as long as the owner's account exists. We do not read your chats unless you ask us to or the law or our acceptable-use rules require it.

5. Cookies and storage on your device

We use only strictly necessary cookies and functional storage, with no analytics, advertising or tracking cookies and no third-party web fonts. All of it is needed to run the Service or set by your own actions, so it is exempt from consent under Article 5(3) and Recital 66 of the ePrivacy Directive and Article 22.2 of Spanish Law 34/2002 (LSSI). That is why there is no cookie banner.

On sites you publish we set nothing, so any cookie there is your site's to disclose and, where needed, to get consent for. Sites under lediv.site share one parent domain, so a cookie scoped to it reaches the other sites and counts toward browsers' per-domain limit. Our publishing docs explain how to avoid this. Domains you connect are not affected.

Clearing them in your browser may sign you out and remove your offline cache.

6. Who receives your data

We do not sell or share your personal data. Only the processors below, acting on our instructions, and the independent parties named here receive it.

Before a new or replacement processor starts, we add it here, and you may object on reasonable data protection grounds within 30 days of that listing, as the data processing section of our Terms of Service sets out.

Link and Stripe. Sold through Link, LLC ("Link"), an affiliate of Stripe, is our Merchant of Record for all payments and subscriptions. Stripe and we are each an independent controller of the data collected at Link's checkout and in your Link account. Stripe uses it, as it decides, for the payment service, including support, order management and tax remittance, under the Link Privacy Policy. Our customer record at Stripe falls under Stripe's Data Processing Agreement.

Google and GitHub, only if you sign in with them, are independent controllers under their own policies and transfer safeguards. We receive your account id, name or username and email. The controller is Google Ireland Limited for the EEA and Switzerland and Google LLC (USA) elsewhere (policy), and GitHub, Inc. (USA) or GitHub B.V. (Netherlands), a Microsoft company (policy).

Others who see some data.

• An agent you connect receives whatever you let it read. You chose it, it is not our subprocessor, and its own terms govern whether it keeps or trains on that data, which we cannot see or control. Sending it other people's data is your decision. End it any time under Connected apps or Access tokens.
• esm.sh, a public CDN, serves the npm modules your project imports when you preview it in the editor, on our instruction. It sees your IP address, browser and those module names and versions, nothing else. Published sites do not use it.
• Public DNS resolvers of Cloudflare and, as fallback, Google see the names of domains we check for you, and nothing about you.
• Certificate Transparency logs, run by third parties, publicly and permanently record the TLS certificate of any domain you connect, as for every trusted certificate. No one can remove the entry, even after you disconnect.
• Better Stack and Healthchecks.io monitor our uptime and scheduled jobs and get no personal data, so no transfer safeguard is needed. Healthchecks.io is hosted at Hetzner in the EU and uses processors outside the EEA.
• Authorities and buyers. We may disclose data where the law requires, to enforce our Terms, to protect rights, safety and property, or in a merger, acquisition or asset sale, in which case we keep protecting your data and tell you of any new controller.

7. Payments (Link as Merchant of Record)

Payments go through Stripe Managed Payments, with Link as our Merchant of Record. When you buy a plan, Stripe is an independent controller of what you give Link at checkout and in your Link account, such as your name, email, billing address, payment details, tax id, order details and IP address. Link's Privacy Policy governs that, not this policy. Link shares your order details with us, as the Sold through Link Terms describe. We see them in our Stripe account but do not copy them into Lediv.

Stripe may transfer this data outside the EEA, including to the United States. According to Link's Privacy Policy, Stripe complies with the EU-U.S. Data Privacy Framework, its UK Extension and the Swiss-U.S. Data Privacy Framework and uses Standard Contractual Clauses where needed.

If you ask Link to delete your data, Stripe cancels the subscriptions sold to you through Link, deletes your data from the payment records in our Stripe account and tells us it has received your request. Your Lediv account remains, and you delete it in the app (Section 11).

8. International transfers

Lediv is operated from Spain, but most of our processors are in the United States, so your account data and User Content are routinely processed there and may be processed elsewhere. The table in Section 6 gives each one's location and safeguard. Where we rely on the EU-U.S. Data Privacy Framework, which remains in force, our agreements with Cloudflare, Resend and Sentry also include the Standard Contractual Clauses (Decision (EU) 2021/914) with the UK Addendum and Swiss adaptations. They cover what the Framework does not, such as Swiss transfers to Resend, and would continue if the Framework were invalidated. OpenRouter relies on the Clauses alone. Stripe, Link, Google and GitHub use their own safeguards. Write to support@lediv.com for a copy of any safeguard.

Infrastructure jurisdiction (Data Act). Under Article 28 of Regulation (EU) 2023/2854, the infrastructure of the Service is run by United States companies under United States jurisdiction. These are Cloudflare, Inc. (on a global network), Plus Five Five, Inc. (email), Functional Software, Inc. (errors) and, for Lediv Agent, OpenRouter, Inc. and Microsoft Corporation. Against government access to, or transfer of, non-personal data held in the Union that would conflict with Union or Member State law, we rely on encryption in transit and at rest, per-document authorization and our providers' contractual commitments to challenge such requests where possible and tell us where lawful.

9. Security

We use measures suited to the state of the art and the risks (Article 32 GDPR). Sign-in is passwordless, so there is no password to steal. Refresh tokens are stored only as hashes and session access tokens expire after 5 minutes. Data is encrypted in transit and at rest. Every document has its own authorization check, and requests are rate limited. Our API and published sites grant no cross-origin API access (no CORS grants). Every cookie carries the __Host- prefix, so no other host can set or overwrite it, and session cookies are SameSite=Strict, with Lax only on the short-lived sign-in cookies the redirect needs.

Your content is not end-to-end encrypted, so we can technically access it to run the Service, for example for sync. No system is completely secure, but we keep our measures current. If a breach is likely to put your rights and freedoms at high risk, we tell you without undue delay, and we notify the Spanish Data Protection Agency within 72 hours of becoming aware of it where the law requires. Report security problems to support@lediv.com.

10. Your rights

Subject to the law, you can do the following.

• Access your data (Article 15).
• Correct it (Article 16). Edit your name and color in the app. Your email is tied to your sign-in.
• Erase it (Article 17), by deleting your account (Section 11) or asking us.
• Restrict processing (Article 18).
• Object at any time to processing based on legitimate interests, on grounds relating to your situation (Article 21). We then stop unless we have compelling legitimate grounds that override your interests, rights and freedoms, or need it for legal claims.
• Take your data with you (Article 20). Export any project you own as a ZIP of your files and assets. See Switching and data formats.
• Withdraw consent at any time where we rely on it, without affecting earlier processing.

For anything you cannot do in the app, write to support@lediv.com. We reply within one month, or up to two months more for complex or numerous requests, and tell you if so (Article 12(3)). It is free unless a request is manifestly unfounded or excessive, when we may charge a reasonable fee or refuse (Article 12(5)).

You can complain to us at the same address. We acknowledge within 30 days and reply without undue delay with the outcome and what we did. You can also complain to a data protection authority, in particular the Spanish Data Protection Agency (Agencia Española de Protección de Datos, AEPD) or the one where you live or work, without coming to us first.

11. Deleting your account

You delete your account in the app and confirm by an email link valid for 15 minutes. If you have a subscription that still renews with Link, whether active, trialing or past due, deletion is blocked until you cancel it in the billing portal or your Link account. If you cannot, write to support@lediv.com and we handle both the cancellation and the deletion. If your subscription is already scheduled to cancel, deleting your account cancels it at once, and the rest of the billing period you already paid for is lost and not refunded.

Export your projects first if you want them. Before we confirm, we delete your account and its records (sessions, memberships, invitations, sign-in tokens, personal access tokens, app approvals and subscription record) and revoke every sign-in and connected app. We also delete your Stripe customer record. The purge then starts. It removes everything you own, trash included, takes your sites offline, releases their addresses, deletes their versions and disconnects your domains, which stay yours. Whatever it cannot finish at once, because storage failed or there is a lot of it, continues daily until done. You leave shared projects, but work you added to a project someone else owns stays in that project, which is theirs to keep or delete, so ask its owner if you want it removed. Feedback stays without your user id.

One record outlives your account. For a domain of yours set up at our infrastructure provider, we keep the domain name, an internal account reference and the date it was disconnected. Your DNS may keep pointing at us for years, and without this record a stranger could connect the domain and collect its traffic. With it, nobody can connect it without proving at its DNS that it is theirs. Our basis is our legitimate interest in preventing that takeover (Article 6(1)(f) GDPR). We keep it while the DNS may still point at us. We cannot see when that ends, so once it does, ask us at support@lediv.com and we check the DNS and delete the record. It holds nothing else about you.

12. Minimum age

Lediv is not for children. You must be 18 or older, or older still where your law sets a higher age. This precautionary rule is independent of Article 8 GDPR, since we rely on contract, not consent. We do not knowingly collect data from anyone under that age. If we learn we hold such data without appropriate consent, we delete the account and its data.

13. US state privacy laws

Laws such as the CCPA/CPRA almost certainly do not apply to us, as we are far below their thresholds. Even so, we do not sell your personal information or share it for cross-context behavioral advertising, and we do not use or disclose sensitive personal information in any way that would give you a right to limit it. Global Privacy Control signals therefore have nothing to act on. Section 3 sets out the categories, sources and uses, and the rights in Section 10 apply to everyone, wherever you live.

14. Changes to this policy

We may update this policy. It is part of your agreement with us, so changes follow the changes section of our Terms of Service. A change that does not reduce your rights or add to your obligations applies when published. For other material changes we give at least 30 days' notice in the app or by email, and you may terminate before they apply. The "Last updated" date shows when this version took effect. We review this policy at least every 12 months. Using the Service after a change takes effect means you acknowledge it.