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Privacy Policy

Version 1.1 · Effective 16.09.2026
Written in plain language, following ISO 24495-2:2025.

The quick version

This Policy explains how LvR Management Ltd uses your personal data when you use LvR Mentoring ON RECORD. We collect only what we need to give you the Service, take payment, and keep it running safely. We don't sell your data. You have rights over your data — you can access it, correct it, ask us to delete it, and complain to the ICO if you're unhappy with how we've handled it.

This Policy applies to customers and visitors to the ON RECORD site.

What's in this document

  • 1. Who we are and how to reach us
  • 2. What personal data we collect
  • 3. Why we use your data, and the legal basis
  • 4. Who we share it with
  • 5. International data transfers
  • 6. How long we keep your data
  • 7. Your rights
  • 8. Cookies and similar technologies
  • 9. Children
  • 10. Changes to this Policy
  • 11. Contact us

1. Who we are and how to reach us

LvR Management Ltd is the data controller for the personal data described in this Policy. We are a company registered in England & Wales (registered office ME19 6NR).

Contact us at contact@lvrmentoring.com for any privacy question, including to exercise your rights.

We have not appointed a Data Protection Officer because we are not required to. Send any DPO-type request to the same email and it will reach the right person.

EU representative. We are in the process of appointing a representative in the EU/EEA under Article 27 GDPR to support our EU/EEA customers. Once appointed, their contact details will be added here.

2. What personal data we collect

CategoryExamples
Account dataName, email address, password (stored hashed), country
Payment dataPayment card token, billing address, VAT status. We don't see or store your full card number — that stays with our payment processor.
Purchase dataPurchase date, access expiry date, refunds
Usage dataWhat you watch, how far, from what device, IP address, session length
LvR GPT dataThe prompts you send and the responses you receive
Support dataEmails you send us and our responses
Marketing dataWhether you opened The Drop, click-throughs, unsubscribe status

3. Why we use your data, and the legal basis

PurposeLegal basis (UK GDPR)
Setting up your account, taking payment, giving you accessPerformance of a contract with you
Running the Service (hosting, streaming, LvR GPT)Performance of a contract with you
Sending The Drop newsletter as part of your accessPerformance of a contract with you
Marketing emails about other LvR products or offersConsent (you can unsubscribe any time)
Analytics and improving the ServiceLegitimate interests (our interest in improving the Service, balanced against your privacy)
Preventing fraud and abuseLegitimate interests (protecting the Service and other users)
Legal, tax, and accounting obligationsLegal obligation
Handling disputes and enforcing our TermsLegitimate interests (protecting our rights)

Automated decisions and profiling. We don't make legally significant automated decisions about you. Content recommendations are based on your viewing activity — you can opt out of personalised recommendations in your account settings.

LvR GPT training. Recordings and platform content may be used to inform LvR GPT's responses to customers. Neither recordings, session transcripts, nor customer prompts are used to train or fine-tune LvR GPT's underlying model, or any third-party AI model — no additional lawful basis is needed for this. If that changes, we'll add a consent-based lawful basis here, an opt-in mechanism, and a matching change to the LvR GPT section of our Terms & Conditions.

4. Who we share it with

We share data only with parties that help us run the Service, and only to the extent needed for them to do so:

  • Vimeo OTT — for hosting, streaming, and (subject to setup) payment processing
  • Stripe — for taking payment
  • Resend — for sending emails
  • Anthropic (Claude) and Voyage AI — for running LvR GPT
  • Our professional advisers (lawyers, accountants, auditors)
  • Authorities — where we're legally required to disclose data

We don't sell your data.

5. International data transfers

Some of our providers are outside the UK — including in the EU, the US, and other countries.

For transfers outside the UK, we rely on:

  • an adequacy decision, where the destination country is recognised as adequate; or
  • the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU SCCs, with additional safeguards where needed.

You can ask us for a copy of the relevant safeguards at contact@lvrmentoring.com.

6. How long we keep your data

DataRetention
Account and purchase dataFor as long as you have an account, then up to 6 years for tax and legal reasons
Payment dataUp to 6 years for tax and legal reasons
Usage dataUp to 24 months, then anonymised
LvR GPT prompts and responsesUp to 12 months, then deleted or anonymised for improvement purposes
Support correspondenceUp to 3 years after resolution
Marketing dataUntil you unsubscribe, then a short suppression record so we don't email you again

7. Your rights

You have the right to:

  • access the personal data we hold about you;
  • correct inaccurate data;
  • ask us to delete your data (in some circumstances);
  • restrict or object to processing (in some circumstances);
  • portability — get a copy of your data in a portable format;
  • withdraw consent where processing is based on consent (this doesn't undo what we did before);
  • complain to the ICO at ico.org.uk if you're unhappy with how we've handled your data. We'd appreciate the chance to sort it out first — contact us at contact@lvrmentoring.com.

8. Cookies and similar technologies

Our website itself does not use non-essential cookies or tracking technologies. Checkout, account access, and video streaming take place on Vimeo OTT's platform, which sets its own cookies under its own cookie policy. If this changes — for example, if we add analytics or marketing cookies to our own site — we'll publish a separate Cookie Policy and, where required, a consent banner before doing so.

9. Children

The Service is for adults (18+). We don't knowingly collect personal data from children. If you think a child has given us their data, contact us and we'll delete it.

10. Changes to this Policy

We may update this Policy. If we make a material change, we'll tell you (by email or through a notice in the Service) before it takes effect.

11. Contact us

LvR Management Ltd
ME19 6NR, United Kingdom
Email: contact@lvrmentoring.com

Version history

v1.1 — 16.09.2026 — updated wording to reflect the move from an annual subscription to a one-time purchase.
v1.0 — 09.09.2026 — first published.

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