Lineagram
Lineagram Privacy Policy — DRAFT v0.1
DRAFT for lawyer review. Not published. Text in [BRACKETS] must be filled in or confirmed.
Facts below reflect the planned architecture (AWS eu-north-1, Stockholm); confirm before publishing.
Last updated: [DATE] · Controller: [LEGAL ENTITY NAME, address, registration no.] · Contact: [privacy@ DOMAIN]
1. Who we are and what this covers
Lineagram ("we") provides a family-tree editor and, for paying organisations, a shared workspace. This policy covers the website, the browser editor and the workspace service.
2. Roles
- Free browser editor: trees stay in your browser unless you choose to save them to an account. For account data we are the controller.
- Organisation workspaces: the organisation (e.g. a genealogy firm) is the controller of the tree data it uploads about its clients and their relatives; we are its processor under the Data Processing Agreement (see the DPA (4.3.2)). We are controller only for account, billing and security data.
3. Data we process
| Category | Examples | Purpose | Legal basis (GDPR) |
|---|---|---|---|
| Account | email, name, password hash, organisation membership | Provide the service, sign-in | Contract (Art. 6(1)(b)) |
| Tree content | names, dates, places, relationships, notes, media you upload — may include living people and special-category data (e.g. health, ethnicity in notes) | Store, display, export your trees | Contract; the controller (you/your organisation) is responsible for its own basis, incl. Art. 9 where applicable |
| Usage and security | IP address, device/browser, audit log of edits and shares | Security, abuse prevention, support | Legitimate interest (Art. 6(1)(f)) |
| Billing | plan, invoices; card data is handled by [PAYMENT PROVIDER], not stored by us | Payment, tax | Contract; legal obligation |
| Waitlist | email and, if you give it, firm name | Send you one launch email when paid plans open; nothing else | Consent (Art. 6(1)(a)) |
| Communications | verification and service emails; optional product news | Service; news only with consent | Contract; Consent (Art. 6(1)(a)) |
We do not sell personal data and do not use tree content to train AI models. [CONFIRM if AI features are added later.]
4. Living people
Tree content about living people is protected by default: it is hidden in shared/public views unless the tree owner explicitly reveals it. Owners must have a lawful basis to record living relatives.
5. Where data is stored; sub-processors
Primary storage is in the EU: AWS (eu-north-1, Stockholm) and Neon (Postgres, EU). Waitlist emails are processed by AWS and Neon. Our current sub-processors are listed in the sub-processor list (4.3.2). Transfers outside the EEA rely on adequacy decisions or Standard Contractual Clauses.
6. Retention
- Account and trees: until you delete them; deleted items stay in Trash for [30] days, then are permanently erased; backups expire within [35] days after that.
- Waitlist: deleted 6 months after launch, or sooner if you unsubscribe. To be removed, use the unsubscribe link in the launch email, or reply to it (hello@lineagram.com) and we delete your entry.
- Audit/security logs: [12] months. Invoices: as required by law ([7] years).
7. Your rights
Access, rectification, erasure, restriction, portability, objection, and withdrawal of consent at any time. Export is available in-app (GEDCOM/JSON). Contact [privacy@ DOMAIN]; you may complain to your supervisory authority [NAME, e.g. Swedish IMY or your local authority]. If your data is in an organisation's workspace, we will refer requests to that organisation.
8. Security
Encryption in transit (TLS) and at rest, role-based access, audit logging. [Complete from the E4 security work: 2FA, backup/restore.] Breaches are notified as required by Art. 33/34.
9. Cookies
Essential cookies only (session). [Add analytics/consent banner details if analytics are introduced.]
10. Children
The service is not directed at children under [16].
11. Changes
Material changes are announced by email and in-app at least [30] days ahead.