Privacy Policy

This policy explains what we hold about you, why we hold it, where it lives, who else touches it, and what you can ask us to do with it.

It is written to meet the EU and UK General Data Protection Regulation, because our clients live all over the world and the strictest standard is the only one that serves all of them. If you are in the United States, section 11 adds what your state law gives you.

Two things worth knowing before you read the rest:

• We run no analytics and no advertising trackers. No Google Analytics, no tag manager, no Meta pixel, nothing. We do not profile you, we do not advertise to you, and we have never sold anyone's data.
• Documents in your vault are encrypted in your browser before they reach us. We hold the encrypted result and no key to it, so for those documents we genuinely cannot read what we are storing.

1. Who we are

Savoir Faire Society LLC, a limited liability company formed in Wyoming, United States, at 1200 Brickell Avenue, Miami, Florida 33131, is the controller of the personal data described here — we decide why and how it is processed.

Write to us about anything in this policy at [email protected].

2. What we collect

Things you give us directly:

Things we record as you use the Lounge:

Things we get from elsewhere:

• Stripe tells us that a payment succeeded, its amount, and the card's last four digits, brand and country. We never receive your full card number.
• If a concierge set your Lounge up from our internal records, the setup details they already held about you.

Calls with us. If we record a video call with you, we do it with Fathom, and we keep the recording, its transcript, the summary and action items Fathom writes, and who was on the call — names and email addresses — in our own archive, which is in Google Cloud in Frankfurt (europe-west3). Everyone on a call is told at the start that it is being recorded. In our own systems, only authorised FCC staff can review a recording; it is never shown in your Lounge, and never to another client from our systems. The recording also remains in Fathom's own app, which our workspace uses.

We do not collect your full card number, your vault passphrase, or your location beyond what an IP address implies.

3. Why, and on what legal basis

Special category data. Identity documents can reveal things GDPR treats as sensitive — nationality, and sometimes more. Where that is so, we process them because you have explicitly consented by uploading them for us to act on, or because we need them to establish, exercise or defend legal claims. You are never obliged to upload a document; the consequence of not doing so is that we cannot do the work that needs it.

Nothing here involves automated decision-making that produces legal effects for you. The Lounge drafts proposals from what you tell us — including from a voice note — but a human confirms every one of them before anything changes.

4. Where your data is stored

Your Lounge is hosted and stored in the European Union — in Google Cloud's europe-west3 region, in Frankfurt, Germany. That covers the database, your encrypted vault documents, your billing records and the application itself.

That is the substance of it. But some of the companies that help us run the service are outside the EU, and it would be wrong to tell you otherwise — section 5 names every one of them and where it is, and section 6 explains what protects a transfer.

5. Who else processes your data

These are our sub-processors. Each one gets only what it needs for its job, and each is bound by a contract that limits it to that.

And two that apply only where the feature concerned is switched on:

If you record a voice note while transcription is enabled, the audio is sent to a speech provider and the transcript to a language model. Neither is used to train anyone's model. If you would rather that did not happen, type your answer instead of recording it — the Lounge accepts a typed transcript everywhere it accepts a spoken one.

We will update this list before adding anyone to it. We have never sold personal data, and we do not share it for advertising.

We may also disclose data where the law requires it, to our professional advisers under duty of confidence, or to a successor if our business is transferred — in which case we will tell you.

6. Sending data outside the EEA

Where a sub-processor in section 5 is outside the EEA or the UK, the transfer is covered by the European Commission's Standard Contractual Clauses (and the UK Addendum or the UK IDTA where UK data is involved), together with technical measures — encryption in transit and at rest, and content stripped from diagnostics before they leave.

Our transfers to Fathom are covered by the data processing agreement we have with them, together with the mechanism above.

Ask us at [email protected] and we will tell you which mechanism covers a particular transfer.

7. How long we keep it

When a retention period ends we delete the data or irreversibly anonymise it. Some records survive a deletion request because the law requires us to keep them; section 10 says what that means for an erasure request.

8. How it is protected

• Your vault is encrypted in your browser. The key never leaves your device, we never see your passphrase, and we cannot decrypt those documents. It also means we cannot recover them if you forget it — see section 5 of the Terms.
• Voice notes and their transcripts are encrypted at rest on our servers. This encryption is ours rather than yours, so unlike the vault, our servers can read them — they have to, to transcribe them.
• Two-factor authentication is available on every account, and we recommend it.
• Everything travels over TLS. Passwords are hashed and never stored in the clear.
• Access by our staff is limited to what a role needs, and administrative access to a client's Lounge is recorded.
• Diagnostics are stripped: request bodies, headers, cookies and query strings never leave our servers with an error report.

No system is perfectly secure. If a breach affects your rights we will tell you and the relevant supervisory authority, within the time the law sets.

9. Cookies and similar

We set exactly one cookie, and it is the one that keeps you signed in. Without it the Lounge cannot work at all.

Everything else we keep is in your browser's own storage, never sent to us, and falls into two kinds:

Every one of them is strictly necessary for something you asked for. None follows you to another website, none identifies you to anyone else, and none is used for advertising or profiling.

Three third parties set their own inside the boxes they draw on our pages, under their own policies, and we cannot read them: Stripe on the payment form (for fraud prevention), Typeform on the form after a purchase, and GoHighLevel on a booking calendar where a page offers one.

There is no cookie banner because there is nothing to consent to — strictly necessary storage is the one category that does not require consent. If we ever add analytics, we will ask first.

10. Your rights

Under GDPR you can ask us to:

• give you a copy of what we hold about you (access);
• correct anything inaccurate (rectification);
• delete it (erasure);
• restrict what we do with it while a dispute is resolved;
• give you a portable copy, in a machine-readable format, or send it to someone else (portability);
• stop processing based on our legitimate interests (objection); and
• withdraw consent where consent is the basis — without affecting what we did before you withdrew it.

Ask at [email protected]. We answer within one month, and will tell you if we need longer because a request is complex. It is free, unless a request is repetitive or excessive.

We may need to verify who you are first — which, for a service holding identity documents, is a protection rather than an obstacle.

Two honest limits on erasure. Accounting records we are legally required to keep will survive it, for the periods in section 7. And a document encrypted with a passphrase we do not have is deleted as ciphertext — we can destroy it, but we could never have read it.

You can complain to a supervisory authority. If you are in the EEA, that is the data protection authority where you live or work. In the UK it is the Information Commissioner's Office, ico.org.uk. Please tell us first if you can — we would rather fix it.

11. If you are in the United States

Depending on your state — California, Colorado, Connecticut, Virginia, Texas and others — you may have the right to know what we collect, to get a copy, to correct it, to delete it, to opt out of its sale or of targeted advertising, and not to be treated worse for asking.

We do not sell personal information and we do not use it for targeted advertising or profiling, so there is nothing to opt out of. The other rights work exactly as section 10 describes; use the same address, and we will answer within the time your state sets.

You may use an authorised agent, and we may ask them for proof.

12. Children

The Lounge is not for anyone under 18, and we do not knowingly collect their data. If you believe a child's data has reached us, write to [email protected] and we will delete it.

Where you upload a document about a family member, including a child, you are confirming you are entitled to give it to us.

13. Changes to this policy

The date at the top says when this policy last changed. If a change materially affects how we use your data, we will tell you — by email or in the Lounge — before it takes effect.

14. Contact and complaints

Savoir Faire Society LLC
1200 Brickell Avenue
Miami, Florida 33131
United States

Privacy and data: [email protected]
Everything else: [email protected]