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Last updated 2026-11-09

Privacy policy

Draft. The fields in square brackets are completed by the owner before launch, then this notice is removed.

01General information

This policy explains how [LEGAL ENTITY NAME] (“Pervenio”, “we”), [REGISTERED ADDRESS], [VAT / COMPANY NUMBER], handles personal data when you visit this website, book a call, write to us, buy a plan or use the Pervenio platform. For the website, enquiries and billing we are the data controller. For questions about your data, write to info@perven.io.

02Data we collect

We collect only what we need. Some data you give us; some is collected automatically when you use the site.

  • You provide: name, work email, company, phone number if you add it, and whatever you write in the booking calendar or the contact form.
  • When you buy: name, email, billing details, plan and payment status, shared with us by Whop. Your card details go to Whop and its payment partners, never to our servers.
  • When you use the platform: login details, workspace settings and the team members you invite.
  • Collected automatically: technical data your browser sends (IP address, device, browser, pages visited, the page you came from), hosting logs and, when product analytics is on, usage events, errors and session recordings.

03Cookies and analytics

We do not use advertising or cross-site tracking cookies. What the site uses falls into four groups. You can block or delete cookies in your browser at any time; the site keeps working without analytics.

  • Strictly necessary: only what is needed to deliver the pages securely. They need no consent. Today the site itself sets none.
  • Analytics (PostHog, when enabled): a first-party cookie and local storage that count visits, show how pages are used and record sessions, with text typed into form fields masked. Data is sent through our own address (/ingest) to PostHog Cloud EU in Frankfurt. Where the law requires consent, we ask for it first.
  • Checkout (Whop): when you open the checkout, Whop’s payment window sets its own cookies to process the payment and prevent fraud, under Whop’s privacy policy.
  • Booking and contact (GoHighLevel): the embedded calendar and form are served by LeadConnector, which may set its own cookies to make them work.

04How we use data

Each purpose has a legal basis under Article 6 of the GDPR. We do not sell personal data and we do not use it for automated decisions with legal or similarly significant effects on you.

  • Answering requests and booked calls: steps you asked for before a contract, or our legitimate interest in replying to you.
  • Delivering the plan you bought: performance of the contract: access, support and service messages.
  • Billing, tax and accounting: legal obligation.
  • Product analytics and session replay: your consent where required; otherwise our legitimate interest in improving the site, which you can object to at any time.
  • Security and abuse prevention: legitimate interest in protecting the site, the platform and our customers’ sending reputation.

05Where data is stored

The website is served by Vercel from its global network, so pages load from the location nearest to you. Analytics data is stored in the EU (PostHog Cloud EU, Frankfurt). Payment data stays with Whop, booking and form data with GoHighLevel. Platform data is stored with [PLATFORM HOSTING PROVIDER AND REGION].

06Data processing for customers

When you use the platform, the prospect lists, connected mailboxes, emails and replies you upload or generate are processed on your instructions. For that data you are the controller and we act as your processor under Article 28 of the GDPR. You are responsible for having a lawful basis to contact the people on your lists and for honouring their requests. Our Data Processing Agreement (DPA), with the list of sub-processors, is available on request at info@perven.io.

07Sharing and processors

We share data only with providers that help us run the service, under a contract and only for that purpose.

  • Vercel Inc. (US): website hosting and delivery, hosting logs.
  • Whop Inc. (US): checkout, payments, receipts and subscription management.
  • LeadConnector / GoHighLevel (US): booking calendar and contact form. We receive the data you type in.
  • PostHog Inc. (data stored in the EU): product analytics, error tracking and session replay, when enabled.
  • Advisers and authorities: accountants and lawyers bound by confidentiality, and public authorities when the law requires it.

08Retention

We keep data only as long as needed for the purpose it was collected for, then delete or anonymise it.

  • Contact and booking requests: 24 months from the last exchange, unless they lead to a contract.
  • Billing and tax records: 10 years, as required by tax law.
  • Analytics data: 12 months.
  • Backups: 30 days, then overwritten.
  • Platform data: for as long as your subscription is active, then deleted as set out in the DPA.

09Your rights

Under the GDPR you have the rights below. To use any of them, write to info@perven.io: it is free, we reply within one month and we may ask you to confirm your identity. You can:

  • access your data and get a copy of it;
  • have inaccurate data corrected;
  • have your data erased, or its use restricted;
  • receive the data you gave us in a portable format;
  • object to processing based on our legitimate interest, including analytics;
  • withdraw your consent, without affecting what was done before;
  • lodge a complaint with the Italian Garante per la protezione dei dati personali or the authority where you live or work.

10International transfers

Vercel, Whop and GoHighLevel are based in the United States. Transfers to providers certified under the EU-US Data Privacy Framework rely on that framework; other transfers rely on the European Commission’s Standard Contractual Clauses, with extra safeguards where needed. You can ask us for a copy of these safeguards.

11Security

The site is served only over HTTPS, access to personal data is limited to the people who need it, and we choose providers with recognised security practices. If a breach puts your data at risk, we notify the supervisory authority and, where required, you.

12Changes to this policy

We update this policy when the service or the law changes. The date at the top shows the current version. We tell customers about significant changes by email before they apply.

13Contact

[LEGAL ENTITY NAME], [REGISTERED ADDRESS], [VAT / COMPANY NUMBER]. Email: info@perven.io.