Estravon — Privacy Notice (DRAFT)
DRAFT v0.1 — prepared 2026-06-12. NOT legal advice. This is a working draft to be reviewed by a qualified data-protection adviser before publication. Items in
[BRACKETS]are placeholders that must be confirmed. The international-transfer safeguards for Datalab and Replicate are not yet finalised (see the transfer-basis register) and are marked accordingly. Do not publish until the ICO registration number is added and the transfer safeguards are confirmed.
Last updated: [DATE OF PUBLICATION]
1. Who we are
This service is provided by Tiberavon Ltd, a private limited company registered in England and Wales, trading as Estravon.
- Registered company number: 17234096
- Registered office: Henleaze House Business Centre, Bristol, United Kingdom
- Contact for privacy matters: privacy@estravon.com
- ICO registration number:
[TO BE ADDED ONCE REGISTERED]
Tiberavon Ltd is the data controller for the personal data described in this notice. We have not appointed a statutory Data Protection Officer, as we are not required to; the contact above reaches the person responsible for data protection.
2. What this notice covers
This notice explains what personal data we collect when you use the Estravon hosted service (the website at estravon.com, account registration, credit purchases, and the cloud extraction service used by the Estravon Zotero plugin), how we use it, who we share it with, how long we keep it, and the rights you have.
It does not cover the open-source "vanilla" backend you run yourself: when you self-host, your PDFs and API keys never reach our servers, and Tiberavon Ltd processes no personal data about your extractions.
3. The personal data we collect
Account and registration data. Your email address, the API key we issue to you, and the date you registered. We need this to create your account, deliver your key, and let you use the service.
Purchase and billing data. When you buy a credit pack, payment is handled by Stripe. We do not see or store your full card details — Stripe processes those. We retain a record of the transaction (amount, credit pack, date, Stripe session identifier) and your consent record (the version of these terms you accepted and when).
Usage and cost data. For each extraction job we log operational metadata: a reference to your key, the number of pages, which extraction backend ran, processing time, computed cost, and status. We use this to bill credits accurately, prevent abuse, and keep the service running. This metadata does not include the content of your documents.
Correspondence. If you email us, we keep that correspondence to respond and for our records.
4. The documents you upload (your content)
When you run an extraction through the hosted service, your PDF is sent to our backend and to our extraction processor solely to produce the Markdown you requested. We treat this content with deliberately short retention:
- The source PDF is deleted immediately after the extraction job completes.
- The result files are deleted after a short retention window (
CONTENT_RETENTION_HOURS, default 1 hour), by which time the plugin has downloaded them to your Zotero library. - We do not use your content to train any model. Where our extraction processor offers a training/improvement option, we keep it opted out.
- We do not inspect, index, or retain the substance of your documents.
You are responsible for ensuring you have the right to upload and process the content you submit (see the Terms of Service). We act as a processor of your document content for the brief duration of the job and as controller only for the operational metadata above.
5. How we use your data, and our legal bases
| Purpose | Legal basis (UK GDPR Art 6) |
|---|---|
| Create your account, issue your key, run extractions you request | Performance of a contract |
| Take payment and deliver purchased credits | Performance of a contract |
| Send service emails (key delivery, low-credit and maintenance-fee notices) | Performance of a contract |
| Prevent fraud and abuse; keep the service secure and reliable | Legitimate interests |
| Keep accounting and tax records of purchases | Legal obligation |
| Send optional product news, if you ask for it | Consent (withdrawable any time) |
Where we rely on legitimate interests, we have balanced those interests against your rights; you may object at any time (see Section 8).
6. Who we share your data with, and international transfers
We use the processors below to run the service. Several are based in the United States, so using Estravon involves transfers of personal data outside the UK. Each such transfer relies on a safeguard under Chapter V of the UK GDPR, shown in the table.
| Processor | Purpose | Location | Transfer safeguard |
|---|---|---|---|
| Stripe, Inc. | Payment processing | USA | UK Extension to the EU-US Data Privacy Framework; Standard Contractual Clauses / UK IDTA as fallback |
| Resend | Transactional email delivery | USA | UK Extension to the EU-US Data Privacy Framework; EU SCCs + UK Addendum as fallback |
| Endless Labs, Inc. (DBA Datalab) | PDF-to-Markdown extraction (primary) | USA | [SAFEGUARD TO CONFIRM — Standard Contractual Clauses / UK IDTA via Data Processing Agreement; pending execution] |
| Replicate, LLC | PDF-to-Markdown extraction (fallback) | USA | [SAFEGUARD TO CONFIRM — or this processor is disabled for UK/EU traffic at launch] |
| Hetzner Online GmbH | Server hosting | Germany (EU) | Within EU/EEA; UK adequacy applies |
| Cloudflare | DNS and content delivery | USA / global | [SCCs / DPF — to confirm] |
| Zoho Corporation | Corporate email (handling messages you send us) | EU/[region to confirm] |
[to confirm] |
We do not sell your personal data, and we do not share it for advertising. We may disclose data where required by law.
You can ask us for more information about the safeguards above, including a copy of the relevant clauses, by emailing privacy@estravon.com.
7. How long we keep your data
- Document content: minutes to one hour, as described in Section 4.
- Account and usage data: for as long as your account is active, and for a reasonable
period afterwards to handle queries and disputes (
[e.g. 12 months]). - Purchase and accounting records: retained for 6 years to meet UK tax and company-law obligations.
- Operational logs: kept for a short rolling period for security and debugging.
8. Your rights
Under UK data protection law you have the right to: access the personal data we hold about you; have inaccurate data corrected; have data erased; restrict or object to processing; data portability; and to withdraw consent where we rely on it. Exercising these rights will not disadvantage you.
To exercise any of these, email privacy@estravon.com. We will respond within one month.
You also have the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority, at ico.org.uk, or by calling 0303 123 1113. We would, however, appreciate the chance to address your concern first.
9. Cookies and analytics
The Estravon site uses only the cookies strictly necessary to operate (for example, to keep
you signed in during registration). [If any analytics are added, disclose the provider and
basis here, and add a cookie banner. Default position at launch: essential cookies only, no
third-party analytics.]
10. Children
Estravon is intended for researchers and professionals and is not directed at children. We do not knowingly collect personal data from anyone under 18. If you believe a child has provided us with data, contact privacy@estravon.com and we will delete it.
11. Changes to this notice
We may update this notice from time to time. The "last updated" date at the top shows when. Material changes affecting how we use your data will be notified to registered users by email.
12. Contact
Questions about this notice or your data: privacy@estravon.com, or write to Tiberavon Ltd at the registered office in Section 1.