Lovex

Data Protection Impact Assessment summary

Lovex AB’s GDPR Article 35 process, the assessment outcomes for every processing activity in our Record of Processing Activities, and the voluntary light-touch DPIA we maintain for AI inference. Companion to /privacy and /dpa.

Last reviewed: 2026-05-17.

This page summarizes our internal DPIA register. The full register lives in our engineering repository and is available to enterprise customers and EU supervisory authorities under a confidentiality undertaking at privacy@lovex.dev.

1. What a DPIA is, and when one is required

A Data Protection Impact Assessment (DPIA) is a structured way to evaluate whether a new processing activity creates risk to the rights and freedoms of natural persons, and what to do about it. GDPR Article 35(3) makes a DPIA mandatory when processing involves:

The Swedish supervisory authority (IMY) maintains an additional Article 35(4) list (biometric identification, genetic data, multi-source combinations, innovative new technology). The European Data Protection Board (EDPB) publishes nine criteria under WP248 — meeting two or more is a strong signal to perform a DPIA voluntarily.

2. Assessment of our current processing activities

We assessed every row of our Record of Processing Activities (Article 30) against the criteria above. None of our processing activities strictly requirea DPIA under Article 35(3). For one activity — AI inference — we maintain a voluntary light-touch DPIA because the “innovative use of new technology” criterion applies and EU regulator guidance on LLM use in productivity software is still evolving.

ActivityDescriptionDPIA status
CA-1Account identity and authenticationNot required
CA-2Account profile and preferencesNot required
CA-3Billing (paid customers)Not required
CA-4Product analyticsNot required
CA-5Transactional emailNot required
CA-6Operational telemetry and error monitoringNot required
CA-7Support requestsNot required
CA-8Outbound marketing and prospect research (Saga)Not required
CA-9AI inferenceVoluntary light-touch — see §3
CA-10Audit logging (Lova)Not required
PA-1Customer workspace content (processor)Customer obligation — see §4
PA-2Customer-initiated AI features (processor)Customer obligation — see §4

Full activity descriptions and Article 30 register summary at /ropa.

3. Voluntary light-touch DPIA for AI inference (CA-9)

AI inference is the activity most likely to attract EU regulator scrutiny. We voluntarily completed a light-touch DPIA documenting the assessment trail.

Description of processing. User prompts and workspace content are transmitted over TLS to a third-party AI inference sub-processor under a written DPA with zero-retention-for-training. The provider returns generated text which is displayed to the user as a draft. The provider may retain prompt and response for up to 30 days in abuse-monitoring logs, then deletes.

Necessity and proportionality.AI features are the core product value (Lova: “chat-first AI project management”), so the processing is necessary for service delivery under Article 6(1)(b). It is proportionate because (i) no special-category data is permitted, (ii) customer instructions govern processing per the DPA, (iii) no training on customer content, (iv) provider-side retention is the minimum the provider offers.

Risks to data subjects.

Residual risk after mitigations: low.No “high risk to rights and freedoms” remains.

Conclusion. No Article 36 prior consultation with IMY is required. No additional safeguards beyond those already in place.

4. Processor activities — customer responsibility

When the customer organization uses Lovex services to process Personal Data, the customer organization is the controller and bears the DPIA obligation, not us. Our role is to provide the technical and contractual basis for the customer to complete their own DPIA. We do that through /subprocessors, /dpa, /trust, the security questionnaire at /trust/security-questionnaire, and the full DPIA register on request under NDA.

5. When we re-evaluate

The DPIA register is reviewed:

6. Contact

Full DPIA register on request under NDA: privacy@lovex.dev. Article 35 process questions and supervisory-authority inquiries: same address.