EU Data Act Switching and Portability Register
This page is the online register referenced in the Livion Master Service Agreement and is intended to provide the information required by Articles 26 and 28 of Regulation (EU) 2023/2854.
1. Switching procedure
A customer may request to switch to another provider, port exportable data and digital assets to on-premises ICT infrastructure, or erase them. Requests must be submitted in text form to [email protected] and should identify the affected property, the requested action, and any destination provider.
| Stage | Standard period | Notes |
|---|---|---|
| Notice period before initiation | Up to 30 calendar days | Starts after receipt of a complete switching request. |
| Transitional period | Up to 30 calendar days | Livion continues the contracted service and provides reasonable assistance. |
| Technically necessary alternative | Up to 7 months | Only where the 30-day transition is technically unfeasible; Livion will notify and justify within 14 working days. |
| Data retrieval | At least 30 calendar days | Starts after the agreed transitional period. |
2. Export methods and formats
Structured records are ordinarily supplied as JSON or CSV. Customer-uploaded attachments are supplied in their original format where reasonably available. Export may be delivered by secure download or another secure transfer method agreed for the individual switching process.
3. Exportable data structures
| Category | Typical data | Typical format |
|---|---|---|
| Master and reference data | Properties, departments, rooms, restaurant tables/seats, storage locations, categories, units, suppliers and contacts | JSON / CSV |
| User administration | User identity, account status, roles and property assignments; excludes passwords and security secrets | JSON / CSV |
| Warehouse | Items, balances, deliveries, transfers, picking lists, internal orders, returns, reorder thresholds and histories | JSON / CSV |
| Restaurant | Reservations, tables, covers, operational guest notes and related history | JSON / CSV |
| Maintenance | Tickets, comments, assignments, status history and asset/inventory links | JSON / CSV |
| Room Assets | Asset records, lifecycle and condition data, photographs and linked histories | JSON / CSV plus original files |
| MICE | Enquiries, events, spaces, setups, participants, readiness checks and handovers | JSON / CSV |
| Other modules | Bulletins, checklist definitions and executions, permitted HR administration, concierge requests and tasks | JSON / CSV plus original files |
| Customer configurations | Workflows, thresholds, categories, role settings, templates and report configurations where technically separable | JSON / CSV |
| Attachments | Customer-uploaded documents, images and files | Original format where available |
| Interpretive metadata | Identifiers, timestamps, status values and history needed to understand exported records | JSON / CSV |
4. Known restrictions and exclusions
Livion does not export source code, object code, model weights, system prompts, orchestration logic, infrastructure configuration, security rules or secrets, internal service telemetry unrelated to customer records, internal development records, anonymised portfolio analytics, or data belonging to other customers. Livion does not provide a live database copy or guarantee compatibility with a destination provider’s proprietary schema. These exclusions do not restrict the export of customer-generated input, output and metadata required for switching.
5. Interfaces and interoperability
Livion provides the export interfaces, downloadable exports and documentation ordinarily available for the relevant service. Where common specifications or harmonised standards applicable to Livion are published and become legally binding, this register will be updated. Livion is not required to develop new technology, disclose protected intellectual property or trade secrets, or compromise system security.
6. Fees
Livion imposes no switching charges for measures required by the EU Data Act. Standard service fees remain payable until the relevant contract ends. Proportionate early-termination compensation may apply as stated in Annex 5 of the applicable Master Service Agreement. Additional consulting or migration services beyond mandatory switching support are chargeable only if requested and agreed in advance.
7. Infrastructure jurisdictions
| Service / provider | Relevant jurisdiction or processing location |
|---|---|
| Hetzner hosting, compute, databases and backups | Germany / European Union |
| Cloudflare network and security services | Global network processing; contractual safeguards apply where required |
| Cloudflare R2 object storage for customer data | European Union jurisdictional restriction |
| Sentry event data | Germany / EU data region; limited support or operational processing may occur under the Sentry DPA |
| OpenAI API | EEA and other locations permitted under the OpenAI DPA |
| Mistral AI | European Union; any international processing subject to contractual safeguards |
| Resend transactional email | United States, subject to applicable DPF/SCC safeguards |
8. Measures concerning international governmental access to non-personal data
Livion uses EU-based core hosting and database infrastructure; restricts administrative access; uses role-based and least-privilege controls; protects external connections with TLS; maintains contractual data-processing and transfer safeguards with relevant suppliers; reviews legally binding disclosure demands where permitted; limits disclosure to what is legally required; and, where legally possible, challenges disproportionate or unlawful demands and informs affected customers.
9. Contact
Switching and portability enquiries: [email protected]