LiffeyAI
Data protection, privacy and security
LiffeyAI holds the commercial intelligence of your business. This document explains exactly what data we hold, how it is processed, where it is stored, who can access it, and what rights you have over it. Last reviewed June 2026.
1. What LiffeyAI does and what data it holds
LiffeyAI is a commercial intelligence platform. It connects to your business documents, files, and knowledge sources, indexes them into a secure knowledge base, and makes them available to an AI assistant (called Liffey) that your team can query in plain language.
We hold the following categories of data on your behalf:
| Commercial Brain content | A structured set of components covering your Commercial Architecture: why you exist, your ICP, your positioning, your sales process, and so on. Each component is a document authored or approved by your team. |
| Connected source knowledge | Text extracted from documents, files, emails, and web pages that you choose to connect. This is chunked into passages and stored as a searchable knowledge base (the RAG corpus). |
| Member identity | Email addresses, roles (owner or member), and session data for the people you invite to your workspace. |
| Connected source credentials | Access tokens for any third-party sources you connect (Google Drive, Microsoft, Slack, GitHub, etc.). Stored encrypted; never used for any purpose other than reading your authorised sources. |
| Operational data | An audit log of significant actions (who edited what, when), AI usage counts, and generated documents you choose to save. |
We do not hold payment card data, national identity numbers, health data, or any special-category personal data under GDPR.
2. How connected sources work: what we store and what we do not
You can connect external sources to LiffeyAI: documents, folders, websites, email threads, and third-party platforms such as Google Drive, Microsoft 365, Slack, or GitHub. Connecting a source does not give LiffeyAI permanent access to your systems. We read the content you authorise at the time of connection and at each sync, then immediately derive our own representation of it. The live source files themselves are never stored by LiffeyAI.
What we do store is a derived version: the text we extracted and a numerical representation (embedding vector) of each passage. This derived version lives in your workspace's knowledge base in our EU database. It is used exclusively to answer your team's queries; it is never shared with other customers or used to train AI models.
The ingestion process works as follows:
- LiffeyAI reads the content of the source using the access you have authorised.
- The readable text is extracted (parsing PDFs, Word documents, spreadsheets, and so on where applicable).
- The text is split into overlapping passages of approximately 500 words.
- Each passage is converted into an embedding vector (a compact numerical representation of its meaning) using an EU-hosted AI model.
- The passage text and its embedding vector are stored in your workspace's EU knowledge base. The original file is not retained.
When a member asks Liffey a question, the question itself is converted into an embedding vector, and the most semantically relevant passages are retrieved from the knowledge base. Those passages, together with your Commercial Brain content, are sent to the AI model in-EU to generate an answer. LiffeyAI applies a recency weighting so that more recently added content is preferred when sources conflict or overlap.
Removing connected sources and extracted knowledge
You are in full control of what stays in your knowledge base. At any time you can remove a connected source. When you do, you choose between two outcomes:
| Archive (default) | The source is removed from your Connected Sources list and no further syncing occurs. The extracted knowledge (the text passages and embeddings) is retained in your knowledge base so Liffey can continue to reason over it. This is appropriate when the source is no longer active but the knowledge it contained is still useful. |
| Purge | The source record, all extracted text passages, and all embedding vectors are permanently deleted from the EU database. This is irreversible. Use this when the content is sensitive, out of date, or incorrect and you want it removed from the knowledge base entirely. |
Individual documents within a source can also be archived or purged independently through the Knowledge Base section of your settings, giving you document-level control without disconnecting the entire source.
3. The Commercial Brain and the knowledge base
LiffeyAI operates two distinct knowledge layers. Understanding the difference is important for assessing how your data is used:
| Commercial Brain | A structured set of components covering your commercial strategy: why you exist, the problems you solve, your ICP, your pricing, your sales process, and so on. These are human-authored documents that your owners explicitly create and approve. They are injected into every Liffey conversation as the verified, authoritative layer. Nothing enters a component without an owner reviewing and committing it. |
| Knowledge base | The derived representation of all content you have connected: documents, emails, files, web pages. Passages are retrieved dynamically when relevant to a question. They provide depth and evidence. The Commercial Brain provides the verified skeleton that the knowledge base supports. |
Neither layer is shared with other customers. Each workspace has its own fully isolated Commercial Brain and its own fully isolated knowledge base.
4. Where your data is stored and processed
LiffeyAI is built for EU data residency. Your database, application compute, and all AI processing run within the European Union. One component, version-controlled storage of your Commercial Brain source documents and brand assets, currently runs on GitHub (United States); we are migrating this to EU-resident storage. The full picture:
| Primary database | Managed PostgreSQL on Neon, Frankfurt, Germany (AWS eu-central-1). Holds all structured data, the full knowledge base (chunk text and embedding vectors), member records, audit logs, and the queryable Commercial Brain (the version served in the app). Encrypted at rest. Point-in-time recovery enabled. |
| Commercial Brain source storage | Your Commercial Brain documents and brand assets are version-controlled in a private, per-workspace Git repository hosted by GitHub (United States). This is the authoritative source the app projects into the EU database above. An EU-resident replacement is built and migration is planned; until then this is the one layer that is not EU-resident. |
| Application compute | Serverless functions hosted on Vercel, pinned to Frankfurt, Germany (fra1). Every API request is handled in-EU. |
| AI inference | Claude Sonnet (Anthropic) via AWS Bedrock, eu-central-1 (Frankfurt). Your prompts and retrieved knowledge are sent to this EU inference endpoint; they do not leave the EU. |
| AI search indexing (embeddings) | Amazon Titan Text Embeddings v2 via AWS Bedrock, eu-central-1. Text is converted to embedding vectors in-EU. |
| Transactional email | Resend, Ireland (EU-West-1). Used for sign-in codes and workspace invitations only. |
Source systems you choose to connect (Google Drive, Microsoft 365, Slack, GitHub, and so on) are governed by their own terms of service. LiffeyAI reads only what you authorise, processes the content in-EU, and stores only the extracted text and embeddings as described above.
5. How your workspace is kept separate
LiffeyAI is a multi-tenant platform. The following controls ensure that no customer can access another's data:
- Row-level tenant isolation. Every record in the database carries a workspace identifier. Every query and API request is scoped to that workspace and verified before execution. It is not possible to construct a request that returns data from a different workspace.
- Isolated content storage. Each workspace's Commercial Brain documents and brand assets live in their own private, per-workspace Git repository, and the queryable copy lives in per-workspace database tables. Content is never held in a shared file system.
- Encrypted credentials. Access tokens for connected sources are encrypted with AES-256-GCM at the application layer (in addition to database-level encryption at rest) using a key held separately from the data. A database breach alone cannot expose your credentials.
- Invite-only access. Your workspace is accessible only to email addresses you explicitly invite. Sign-in uses one-time codes sent to verified email addresses (no passwords). There is no self-sign-up.
- Role-based permissions. Owners can edit and approve changes to the Commercial Brain. Members can query and contribute. Neither role can see data from another workspace.
- Append-only audit log. Every significant action (brain edits, source connections, member changes, AI commits) is logged with the actor, timestamp, and before/after state. Logs cannot be edited or deleted.
6. AI model behaviour and data use
LiffeyAI uses foundation AI models to power the assistant. The following commitments apply:
- Your data is not used to train AI models. Anthropic and AWS operate under enterprise terms that prohibit using customer inputs to train or improve their models.
- Zero data retention at the AI layer. Prompts and responses are processed in memory and are not stored by the AI provider.
- AI processing stays in the EU. Both the inference model and the embedding model are served from AWS Frankfurt (eu-central-1). Your prompts and retrieved knowledge are processed in-EU and are not sent to US AI infrastructure. (Separately, your Commercial Brain source documents are version-controlled on GitHub in the US, as noted in section 4; that migration to EU storage is planned.)
- Query expansion. To improve search quality, LiffeyAI generates alternative phrasings of your question before retrieving knowledge (multi-query RAG). These alternative phrasings are generated using a lightweight AI model and are treated with the same data handling as the original query.
- No autonomous action. Liffey proposes; your team decides. The assistant can draft content and suggest updates to the Commercial Brain, but nothing is committed without explicit owner approval.
7. Sub-processors
LiffeyAI uses the following sub-processors to deliver the service. All are under data processing agreements consistent with GDPR:
| Neon | PostgreSQL database hosting. EU (Frankfurt, Germany). Processes all structured data and knowledge base content. |
| Vercel | Application hosting and serverless compute. EU (Frankfurt, Germany). Processes all application requests. |
| AWS / Anthropic (Bedrock) | AI inference (Claude Sonnet) and embedding generation (Titan). EU (Frankfurt, Germany). Processes prompt content and source text for embedding. No model training on customer data. |
| Resend | Transactional email. EU (Ireland). Processes email addresses for sign-in codes and invitations only. |
| GitHub (optional) | Source connector. US. Used only if you choose to connect a GitHub repository. LiffeyAI reads file content you authorise; the extracted text is stored in-EU. |
| Google / Microsoft / Slack (optional) | Source connectors. US / EU depending on your account settings. Used only if you choose to connect these sources. LiffeyAI reads only what you authorise; extracted text is stored in-EU. |
The complete, current sub-processor list and our standard Data Processing Agreement (DPA) are available on request at hello@liffey.ai.
8. How we protect access to your workspace
Access to your LiffeyAI workspace is controlled at multiple layers. We have deliberately avoided passwords: they are the most common source of credential breaches and they put the security burden on your team. Instead, LiffeyAI uses the following model:
| Invite-only access | Your workspace is closed. Nobody can create an account or sign in unless they have been explicitly invited by an owner of your workspace. There is no public sign-up. |
| One-time sign-in codes | Every sign-in, including the first, requires a one-time six-digit code sent to the verified email address. The code expires within 10 minutes and is rate-limited per email address and per IP address to prevent automated abuse. There is no password to steal, phish, or brute-force. |
| No persistent credentials | Sessions are time-limited (24 hours, or 30 days if the member chooses to stay signed in). There are no API keys or long-lived tokens issued to end users. |
| Role-based permissions | Each member is assigned a role by a workspace owner. Owners can connect sources, edit the Commercial Brain, manage members, and remove content. Members can query the brain and upload documents, but cannot make structural changes. Roles can be changed or revoked at any time by an owner. |
| Immediate revocation | When a member is removed, their access is revoked immediately. Active sessions are invalidated. They cannot re-join without a new invitation. |
| Audit trail | Every sign-in, every brain edit, every source connection, and every member change is logged with the actor, the timestamp, and the before/after state. Logs are append-only and cannot be edited or deleted. Owners can request their audit log at any time. |
| Connected source credentials | When you authorise LiffeyAI to read a connected source (for example, a Google Drive folder), the access token is encrypted with AES-256-GCM at the application layer before being stored, in addition to the database-level encryption at rest. A database breach alone cannot expose your source credentials. You can revoke this access at any time by disconnecting the source. |
| File upload validation | Documents uploaded directly to LiffeyAI are validated against their declared file type before processing. A file claiming to be a PDF, Word document, or spreadsheet is checked against its actual binary signature. Files that do not match are rejected before any content is extracted or stored. |
Infrastructure security
- Encryption in transit. All connections use TLS 1.2 or higher.
- Encryption at rest. The EU database is encrypted at rest by the hosting provider (Neon). Source credentials are additionally encrypted at the application layer with AES-256-GCM.
- Least-privilege service accounts. Each internal service (database, AI inference, email) has its own isolated credentials scoped only to what it needs. A breach of one service account cannot be used to access others.
- Audit logging. All significant actions are logged immutably. Logs are used for security review, incident response, and customer-requested audit trails.
- Backups. The database has continuous point-in-time recovery. Backups are stored within the EU.
- Source disconnection. When you remove a connected source, you can choose to archive (retain the extracted knowledge, hide the source) or purge (delete the source record, the extracted items, and all knowledge chunks). Purge is irreversible.
9. Your rights
Under GDPR and applicable data protection law, you have the following rights in relation to your data:
| Access | Request a copy of the data LiffeyAI holds about your workspace, including Commercial Brain content, indexed knowledge, member records, and the audit log. |
| Rectification | Correct inaccurate data. Commercial Brain content can be edited directly by workspace owners at any time. Member records can be corrected on request. |
| Erasure | Request deletion of your workspace and all associated data. We will confirm erasure in writing within 30 days. |
| Portability | Request an export of your Commercial Brain content and knowledge base in a machine-readable format. |
| Restriction | Request that we restrict processing of your data while a dispute is resolved. |
| Objection | Object to specific processing activities. We will respond within 30 days. |
To exercise any of these rights, contact hello@liffey.ai. We will acknowledge your request within 72 hours and respond fully within one calendar month. Where a request is complex or we have received a number of requests simultaneously, we may extend this by a further two months; if so, we will notify you within the first month and explain the reason for the extension.
10. Data retention
We retain your data for as long as your workspace is active. Specific retention periods:
| Commercial Brain content | Retained for the lifetime of the workspace. Deleted on workspace closure or on erasure request. |
| Knowledge base (indexed source content) | Retained until you remove the source or request purge. Archiving retains the knowledge; purge deletes it permanently. |
| Member records | Retained while membership is active. Revoked members are soft-deleted (record retained for audit purposes, access removed immediately). |
| Audit log | Retained for 2 years from the date of each event. |
| AI usage logs | Aggregated usage counts retained for billing purposes. No conversation content is retained beyond the active session. |
| Conversation history | LiffeyAI does not persist conversation history across sessions. Each session starts fresh from the knowledge base. |
11. Enterprise: dedicated deployment in your jurisdiction
For enterprise customers with specific data residency or isolation requirements, LiffeyAI offers a dedicated, single-tenant deployment in the jurisdiction of your choice. This provides:
- A dedicated database in your chosen region (EU, UK, US, or other).
- Dedicated compute pinned to that region.
- In-region AI inference and embedding, so your content never leaves your jurisdiction.
- The option to bring your own AI API keys (BYOK), so prompts are processed under your own account with your provider.
- Isolated encryption keys (optionally customer-managed).
- Complete logical and physical separation from the shared platform.
To discuss the enterprise plan, contact hello@liffey.ai.
12. Incident response and breach notification
In the event of a confirmed security incident affecting your data, LiffeyAI will notify affected workspace owners within 72 hours of becoming aware of the incident, consistent with our GDPR obligations. Notifications will describe the nature of the incident, the data affected, the likely consequences, and the measures taken or proposed. Contact hello@liffey.ai to report a suspected security issue.
13. Lawful basis for processing
LiffeyAI processes personal data on the following lawful bases under Article 6 of the GDPR:
| Contract (Art. 6(1)(b)) | Processing member email addresses, roles, and session data is necessary to deliver the service you have contracted for. Without this processing, we cannot authenticate your team or control access to your workspace. |
| Legitimate interests (Art. 6(1)(f)) | Processing connected source content and Commercial Brain data is necessary to deliver the core intelligence service. The processing is proportionate to the business purpose and does not override your fundamental rights. You control what is connected, what is retained, and what is deleted. |
| Legal obligation (Art. 6(1)(c)) | Retaining the audit log for a defined period is necessary to meet our legal obligations and to respond to lawful requests from supervisory authorities. |
LiffeyAI is the data processor acting on your instructions. You, as the customer, are the data controller for the commercial data you bring into the platform. This means you determine the purposes and means of processing your data; we process it only as directed by your use of the service and by our Data Processing Agreement. A standard DPA is available on request at hello@liffey.ai.
14. International data transfers
All core processing (database, compute, AI inference, and embeddings) takes place within the European Union. No personal data or commercial content is transferred to the United States or other third countries as part of the standard service.
Where you choose to connect optional third-party sources (such as Google Drive, GitHub, or Slack), those providers may process data in the United States. LiffeyAI reads only the content you specifically authorise and immediately processes and stores it in-EU. The transfer of data to those optional connectors is covered by Standard Contractual Clauses (SCCs) under Article 46(2) GDPR, entered into between LiffeyAI and each relevant sub-processor. A list of those sub-processors and the SCCs in place are available on request.
If you have specific requirements around international transfers, such as a prohibition on any third-country processing, please contact us at hello@liffey.ai to discuss the enterprise dedicated deployment option, which can be configured to eliminate optional-connector transfers entirely.
15. Security certifications and assurance
LiffeyAI is an early-stage company and does not yet hold its own SOC 2 or ISO 27001 certification. We are working toward SOC 2 Type II as our first formal certification. We will update this document when that process is complete.
In the meantime, the infrastructure and AI providers that underpin the service are certified independently:
| Neon (database) | SOC 2 Type II (all five Trust Service Criteria). ISO 27001:2022. ISO 27701. GDPR compliant with SCCs. Annual audits. Trust Center: trust.neon.com |
| Vercel (compute) | SOC 2 Type II (Security, Confidentiality, Availability). ISO 27001:2022. GDPR compliant with SCCs and EU-US Data Privacy Framework. Trust Center: security.vercel.com |
| AWS Bedrock (AI inference and embeddings) | SOC 2 Type II (Security, Availability, Confidentiality). ISO 27001:2022, ISO 27017, ISO 27018, ISO 27701. Bedrock is explicitly in scope. Data residency in eu-central-1. Compliance reports available via AWS Artifact. |
| Anthropic (Claude model) | SOC 2 Type II. ISO 27001:2022. ISO/IEC 42001:2023 (AI Management Systems). No model training on customer content. Trust Center: trust.anthropic.com |
| Resend (email) | SOC 2 Type II (all five Trust Service Criteria). GDPR compliant with SCCs. Security details: resend.com/security |
We can share sub-processor SOC 2 reports and ISO certificates on request, subject to any NDA requirements from those providers. Contact hello@liffey.ai.
16. Children
The LiffeyAI service is a business-to-business platform intended for use by organisations and their authorised employees. It is not directed at individuals under the age of 16 and we do not knowingly process personal data of children. If you believe a person under 16 has been added as a workspace member in error, please contact hello@liffey.ai and we will remove that access immediately.
17. Your right to complain to a supervisory authority
If you believe we have not handled your data in accordance with applicable data protection law, you have the right to lodge a complaint with the relevant supervisory authority. LiffeyAI is based in Ireland. The relevant authority for Ireland is:
Data Protection Commission (DPC)
21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland
www.dataprotection.ie
If you are based in another EU member state, you may also contact your local supervisory authority. We would, however, appreciate the opportunity to address any concern directly before a formal complaint is made. We would appreciate the opportunity to resolve any concern directly; please contact us at hello@liffey.ai.
18. Changes to this document
We may update this document as our infrastructure, certifications, or practices evolve. Material changes will be communicated to workspace owners by email before they take effect. The current version is always available at this URL. Last reviewed June 2026 and signed off by the LiffeyAI data controller.
LiffeyAI
Data controller for your workspace data: you, as the customer. Data processor: LiffeyAI (trading name of Fractional Edge Ltd, company registration number 782670, registered in Ireland).
Data protection contact: hello@liffey.ai
This document was last reviewed June 2026. For the Data Processing Agreement or the full sub-processor list, email hello@liffey.ai.