Privacy Policy

Organization: LTHS, Inc. (Litehouse)

Version: 3.0

Last Updated: April 2026

Applicable Frameworks: GDPR (EU Regulation 2016/679), UK GDPR and Data Protection Act 2018, EU-US Data Privacy Framework (DPF), UK-US Data Bridge, Standard Contractual Clauses (EU Commission Decision 2021/914), UK International Data Transfer Agreement (IDTA) / UK Addendum to EU SCCs, SOC 2 Type II.

1. About Litehouse and This Policy

LTHS, Inc. is a software company incorporated in the United States. We provide an enterprise data and analytics platform used by venue operators, live event businesses, and hospitality organisations.

This Privacy Policy explains how Litehouse collects, uses, and protects personal data in the context of operating and delivering our platform to enterprise clients, managing accounts, authentication, and platform access, and corporate activities including marketing, communications, and recruitment.

This Policy applies to personal data for which Litehouse acts as a data controller. Where Litehouse processes personal data on behalf of enterprise clients under their instruction, those clients are the data controllers and their own privacy policies apply to end-user data.

2. Our Identity and How to Contact Us

2.1 Data Controller

FieldDetails
Legal entityLTHS, Inc.
Trading nameLitehouse
Registered address2753 Camino Capistrano, San Clemente, CA 92672
Emailprivacy@litehou.se
Websitelitehou.se

2.2 EU Representative (Article 27 EU GDPR)

As a US-based organisation subject to EU GDPR, Litehouse has appointed GDPRLocal as its EU representative under Article 27 of Regulation (EU) 2016/679.

FieldDetails
OrganisationGDPRLocal Ltd
AddressOffice 2, 12A Lower Main Street, Lucan Co. Dublin, K78 X5P8, Ireland
Emailcontact@gdprlocal.com
ReferenceLTHS, Inc. / Litehouse

2.3 UK Representative (Article 27 UK GDPR)

Litehouse has also appointed GDPRLocal as its UK representative under Article 27 of the UK GDPR.

FieldDetails
OrganisationGDPRLocal Ltd
Address1st Floor Front Suite, 27-29 North Street, Brighton, England, BN1 1EB
Emailcontact@gdprlocal.com
ReferenceLTHS, Inc. / Litehouse

2.4 Data Protection Officer

Litehouse is in the process of formally designating a Data Protection Officer. Until that appointment is complete, privacy-related enquiries should be directed to privacy@litehou.se.

This policy will be updated with DPO contact details upon appointment.

3. Our Role as Controller and Processor

RoleContext and Obligations
Data ControllerLitehouse acts as controller for personal data it collects and processes for its own purposes, including account management, Auth0 authentication, security monitoring, analytics, marketing communications, and corporate operations.
Data ProcessorWhen processing personal data within customer-configured environments on behalf of enterprise clients, Litehouse acts under client instruction. The client is the data controller and Litehouse obligations are governed by the applicable Data Processing Agreement (DPA).

4. Personal Data We Collect

4.1 Platform Account and Authentication Data

  • Full name and business email address
  • Job title and organisation name
  • Auth0 authentication credentials and session tokens
  • IP address and device/browser information at login
  • Multi-factor authentication records
  • Account creation and last-login timestamps

4.2 Platform Usage and Telemetry Data

  • Feature usage logs and navigation events
  • API request metadata (endpoint, timestamp, response status)
  • Error logs and performance telemetry
  • Audit trail records of platform data access events

4.3 Communications and Marketing Data

  • Name, email address, job title, and organisation
  • Content of enquiries, support tickets, or correspondence
  • Marketing consent records and communication preferences
  • Website interaction data where cookie consent has been obtained

4.4 Data We Do Not Collect as Controller

Litehouse does not collect or control end-customer personal data processed within client-configured Customer Data Planes. That data is processed by Litehouse only as processor under client instruction.

5. How and Why We Use Personal Data

PurposeLawful Basis
Provisioning and managing platform access accountsContract
Auth0 authentication and session managementContract
System operation, monitoring, and performanceLegitimate Interest
Security monitoring and incident responseLegitimate Interest
Audit logging for compliance and oversightLegal Obligation / Legitimate Interest
Responding to enquiries and support requestsContract / Legitimate Interest
Marketing communications to business contactsLegitimate Interest (opt-out available at any time)
Compliance with legal obligationsLegal Obligation
Internal analytics to improve platform featuresLegitimate Interest

Where Litehouse relies on Legitimate Interest, a Legitimate Interest Assessment (LIA) has been or will be documented and is available on request.

5.1 Disclosure of Personal Data to Third Parties

In the course of the activities described above, Litehouse may disclose personal data to the following categories of third parties for the purposes indicated:

Category of RecipientPurpose of Disclosure
Cloud infrastructure provider (Microsoft Azure)Hosting and operating the Litehouse platform, including data storage and compute services
Identity and authentication provider (Auth0 / Okta)Processing authentication credentials and session management for platform access
Observability provider (Datadog EU1)Processing platform performance telemetry and error logs (PII redacted at ingestion)
EU and UK Representative (GDPRLocal Ltd)Receiving and forwarding data subject enquiries and supervisory authority communications on Litehouse's behalf
Professional advisors (legal counsel, auditors)Providing legal advice, audit, and compliance services where disclosure is necessary
Marketing and communications toolsSending marketing communications and managing contact preferences, where applicable and with appropriate consent
Law enforcement or regulatory authoritiesResponding to lawful requests, court orders, or regulatory obligations

Litehouse does not sell personal data. We require all third-party recipients to protect personal data in accordance with applicable data protection law and our contractual obligations.

6. International Data Transfers

6.1 Transfers to the United States - Data Privacy Framework

LTHS, Inc. (Litehouse) complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. Litehouse has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. DPF Principles with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. If there is any conflict between this policy and the EU-U.S. DPF Principles, the Principles govern.

To learn more about the Data Privacy Framework Program and to view our certification, visit dataprivacyframework.gov.

Litehouse is US-incorporated. Personal data of EU and UK individuals may be transferred to and processed in the United States for operations, engineering and security support, and platform management.

MechanismApplication
EU-US Data Privacy Framework (DPF)Litehouse participates in the EU-US DPF and is listed on the US Department of Commerce DPF Registry.
UK Extension to the DPF (UK Data Bridge)DPF participation extends to UK personal data under the UK-US Data Bridge.
Standard Contractual Clauses (SCCs)Where DPF coverage does not apply (or as supplementary protection), Litehouse uses the European Commission approved SCCs (2021/914).
UK IDTA / UK AddendumFor UK transfers not covered by the Data Bridge, Litehouse uses ICO-approved IDTA or the UK Addendum to EU SCCs.

6.2 Data Privacy Framework Recourse and Dispute Resolution

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Litehouse commits to refer unresolved complaints concerning our handling of personal data received in reliance on these frameworks to JAMS, an alternative dispute resolution provider based in the United States.

If you do not receive timely acknowledgment of your complaint, or if your complaint is not addressed to your satisfaction, visit jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. JAMS services are provided at no cost to you.

If your DPF Principles-related complaint cannot be resolved through these channels, you may be eligible to invoke binding arbitration under the DPF Annex I arbitral mechanism. More information is available at dataprivacyframework.gov. Litehouse is subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC) with respect to DPF compliance.

6.3 Regional Data Residency

For EU and UK customer deployments, personal data in Customer Data Planes is stored and processed in-region (EU or UK). Corporate support access is governed by zero-standing-access controls, JIT elevation, and full audit logging.

6.4 Onward Transfer Liability

In cases of onward transfer of personal data received pursuant to the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Litehouse is potentially liable under the DPF Principles if third-party agents processing personal data on our behalf do so in a manner inconsistent with the DPF Principles, unless Litehouse proves it is not responsible for the event giving rise to the damage.

Litehouse enters into written agreements with third-party agents that receive personal data transferred under the DPF, requiring them to provide the same level of protection as the DPF Principles and notify Litehouse if they can no longer meet that obligation.

7. Data Retention

Data CategoryRetention Period
Platform account and authentication dataDuration of the client contract plus 12 months following termination
Platform usage and audit logs24 months from creation, unless longer retention is required by law or client DPA
Security and incident logs12 months from creation (or longer for active investigation or legal hold)
Marketing and communications dataUntil consent is withdrawn or opt-out exercised, plus 6 months for suppression records
Correspondence and support tickets3 years from last communication
Legal compliance recordsAs required by law (typically 6-7 years)

At the end of each retention period, data is securely deleted or anonymised according to Litehouse deletion procedures. Clients may request earlier deletion in accordance with their DPA.

8. Your Rights as a Data Subject

RightWhat It Means
Access (Art. 15)Request confirmation whether your data is processed and obtain a copy with usage information.
Rectification (Art. 16)Request correction of inaccurate or incomplete data.
Erasure / Right to be Forgotten (Art. 17)Request deletion where data is no longer necessary, consent is withdrawn, objection is upheld, or processing was unlawful.
Restriction of Processing (Art. 18)Request restricted use while retaining data in limited circumstances.
Data Portability (Art. 20)Receive personal data in a structured machine-readable format and transmit it to another controller, where applicable.
Object (Art. 21)Object to processing based on legitimate interests; objection to direct marketing is absolute.
Withdraw ConsentWithdraw consent at any time where processing is consent-based.

8.1 How to Exercise Your Rights

Contact privacy@litehou.se, or contact the EU/UK representative listed in Section 2. Litehouse responds within one calendar month, with a possible extension of up to two additional months for complex requests.

No fee is charged unless requests are manifestly unfounded or excessive.

8.2 Note on Client-Controlled Data

For personal data held within a client deployment where that client is the data controller, rights should be exercised through the relevant client organisation. Litehouse assists clients as required by DPAs.

9. Right to Lodge a Complaint

JurisdictionSupervisory Authority
European UnionCompetent EU Data Protection Authority in the Member State of residence, work, or alleged infringement (see edpb.europa.eu).
United KingdomInformation Commissioner's Office (ICO): ico.org.uk, Tel: 0303 123 1113
United States (DPF matters)US Federal Trade Commission (FTC) - ftc.gov, or JAMS (see Section 6.2)

Litehouse welcomes the opportunity to address concerns directly before a supervisory authority is contacted.

10. Security

Litehouse implements appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction, including:

  • Encryption at rest (AES-256) and in transit (TLS 1.2+)
  • Role-based access control with zero-standing-access architecture
  • Privileged Identity Management with JIT access elevation
  • Multi-factor authentication for production access
  • Azure Bastion-tunnelled production access with audit logging
  • Network segmentation and private endpoints
  • Sensitive data scanning and PII redaction in logs
  • Regular penetration testing and vulnerability scanning
  • Regional data residency controls for EU and UK deployments

Security practices are subject to ongoing review and third-party audit. SOC 2 Type II certification is in progress.

11. Cookies and Website Tracking

The Litehouse public website at litehou.se may use cookies and similar tracking technologies. The platform, accessed through Auth0, uses strictly necessary cookies for session management and authentication.

Where non-essential cookies are used on the public website, Litehouse requests consent before placement. Consent can be withdrawn at any time via the cookie preference centre in the website footer.

A full Cookie Policy is available at litehou.se/cookies.

12. Sub-Processors and Third Parties

As a processor, Litehouse engages sub-processors to assist in platform delivery. Sub-processors are bound by contractual obligations equivalent to client DPA terms and are assessed for GDPR compliance.

Key sub-processors include:

  • Microsoft Azure - cloud infrastructure and regional hosting
  • Auth0 (Okta) - identity and authentication services
  • Regional observability provider (for example, Datadog EU1 for EU/UK deployments)

A current sub-processor register is available to clients on request as part of their DPA process.

13. Changes to This Policy

Litehouse may update this Privacy Policy from time to time to reflect changes in practices, legal obligations, or regulatory guidance. The Last Updated date at the top of this page indicates the most recent revision.

Material changes are communicated through appropriate channels. You are encouraged to review this Policy periodically.

14. Contact Us

Contact RouteDetails
General privacy enquiriesprivacy@litehou.se
EU data subjects / EU supervisory authoritiescontact@gdprlocal.com
UK data subjects / ICOcontact@gdprlocal.com
DPF complaints (JAMS)jamsadr.com/DPF-Dispute-Resolution

LTHS, Inc. (Litehouse) | privacy@litehou.se | litehou.se

Privacy Policy v3.0 - April 2026