Privacy Policy

1. Data Controller and Processor Roles

1.1 Controller. Llewellyn Systems acts as the Data Controller for personal information collected directly from visitors to our websites, marketing contacts, and prospective customers.

1.2 Processor. When processing Customer Data on behalf of our customers, Llewellyn Systems acts as a Data Processor (or Service Provider under CCPA). Our customers remain the Data Controller for their end-user data.

1.3 Contact. Data Protection Officer: privacy@llewellynsystems.com

2. Information We Collect

2.1 Information You Provide. Account registration data (name, email, organization); billing and payment information; communications with our support team.

2.2 Automatically Collected Information. Device identifiers, IP addresses, browser type, operating system; usage data, feature interactions, and performance metrics; cookies and similar tracking technologies.

2.3 Third-Party Sources. Business contact information from partners; publicly available professional information; identity verification services for compliance purposes.

3. Lawful Bases for Processing

We process personal data under the following lawful bases:

• Contract Performance: Processing necessary to provide odeMERIDIAN and fulfill our contractual obligations.
• Legitimate Interests: Product improvement, security, fraud prevention, and business analytics, balanced against data subject rights.
• Legal Compliance: Processing required to comply with applicable laws, regulations, and legal processes.
• Consent: Where required by law, such as for certain marketing communications or optional data processing activities.

4. How We Use Information

• Provide, maintain, and improve odeMERIDIAN and services
• Process transactions and send related information
• Send technical notices, updates, security alerts, and support messages
• Respond to comments, questions, and customer service requests
• Monitor and analyze trends, usage, and activities
• Detect, investigate, and prevent fraudulent transactions and security incidents
• Comply with legal obligations and enforce our agreements

5. Data Sharing and Disclosure

We do not sell your personal information. We may share information with:

• Service Providers: Third-party companies that help us operate, such as hosting, payment processing, and analytics.
• Legal Requirements: When required by law, regulation, or legal process.
• Business Transfers: In connection with any merger, acquisition, or sale of assets.

6. International Data Transfers

Your information may be transferred to and processed in jurisdictions outside your country of residence. We implement appropriate safeguards including Standard Contractual Clauses (SCCs) approved by the European Commission, UK International Data Transfer Agreement (IDTA), and supplementary security measures.

7. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access, correct, or delete your personal information
• Restrict or object to processing
• Data portability
• Withdraw consent (where processing is based on consent)
• Lodge a complaint with a supervisory authority

To exercise your rights, contact us at privacy@llewellynsystems.com.

8. Data Retention

We retain personal information for as long as necessary to provide the Services and fulfill the purposes described in this Policy. Upon account termination, Customer has 30 days to request data export before deletion.

9. Security

We implement appropriate technical and organizational measures to protect personal information, including encryption in transit (TLS 1.3) and at rest (AES-256), role-based access control, and continuous security monitoring.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated with at least 30 days' notice. Continued use of the Services constitutes acceptance of updated terms.

11. Contact

Llewellyn Systems, LLC — A subsidiary of Sound of Life Media, Inc.
2601 Blanding Ave, Ste C248, Alameda, CA 94501
Privacy: privacy@llewellynsystems.com
DPO: dpo@llewellynsystems.com