Terms of Use

1. About Readmodel®

Readmodel® is a SaaS application provided by LOCAVERDI B.V. (KvK: 96035056, registered in the Netherlands) for GDPR-focused data flow mapping, risk assessment, and compliance documentation. The NLdigital Terms 2025, filed with the District Court Midden-Nederland, location Utrecht, apply to all agreements between LOCAVERDI B.V. and the client. These Terms of Use supplement the NLdigital Terms with product-specific provisions for Readmodel®.

2. Documentation tool — not legal advice

Readmodel® is a documentation and mapping tool. It is not a substitute for legal advice, Data Protection Officer (DPO) guidance, or supervisory authority consultation.

The application does not guarantee compliance with GDPR, the EU Data Act, NIS2, or any other regulation. Users are responsible for ensuring their own regulatory compliance. LOCAVERDI B.V. does not provide legal, tax, or compliance advisory services through Readmodel®.

3. AI-generated reports

Readmodel® offers AI-powered analysis reports generated by third-party AI providers (see our Sub-processor Notice). These reports are indicative assessments based on the data entered by the user.

• AI reports do not constitute legal advice, formal DPIA assessments, or official compliance certifications.
• AI outputs may contain inaccuracies, omissions, or outdated information.
• The user remains solely responsible for verifying the accuracy of generated reports and for seeking qualified professional advice before acting on them.
• LOCAVERDI B.V. is not liable for decisions made based on AI-generated content.

4. Data accuracy and user responsibility

All risk scores, compliance assessments, backup compliance checks, vendor lock-in ratings, DPIA flags, and other computed outputs are derived from data entered by the user. LOCAVERDI B.V. does not verify the accuracy, completeness, or currency of user-entered data.

The user is solely responsible for:

• The correctness and completeness of all data entered into the application.
• Decisions made based on the application's output, including risk assessments and action items.
• Keeping their data current and reviewing assessments when circumstances change.

5. Template data

Readmodel® provides pre-populated service templates with data such as vendor lock-in ratings, exit strategies, URLs, backup assessments, and service descriptions. This template data is provided for convenience and is based on publicly available information at the time of creation.

LOCAVERDI B.V. does not guarantee the accuracy or currency of template data. Third-party services may change their capabilities, terms, or features at any time. The user is responsible for verifying and updating template data for their specific situation.

6. Security and sensitive data

Users must not enter actual passwords, API keys, encryption keys, or other security credentials into Readmodel®. Use role descriptions (e.g. "HR Manager") rather than real names of individuals where possible. LOCAVERDI B.V. is not liable for any consequences arising from the entry of sensitive credentials into the application.

The breach notification register and DSAR tracker may require the entry of personal data of third parties (data subject names, email addresses) to fulfil the user's legal obligations under GDPR Art. 33 and Art. 15-22. The user is the data controller for this data and is responsible for ensuring a lawful basis for its processing. LOCAVERDI B.V. processes this data solely as data processor on behalf of the user, as described in the Data Processing Agreement.

7. Account security

Users are responsible for maintaining the confidentiality of their login credentials and for enabling two-factor authentication (2FA) where available. LOCAVERDI B.V. is not liable for unauthorized access resulting from compromised user credentials.

8. Bot protection

Readmodel® uses automated bot protection on public forms (login, registration, contact, password reset) to prevent abuse. This includes:

• Rate limiting on form submissions
• Honeypot fields to detect automated submissions
• A self-hosted proof-of-work challenge — no data is sent to third parties

By using the service, you consent to these bot protection measures. See our Privacy Policy for details.

9. Newsletter

Readmodel® offers a voluntary newsletter for product updates and articles about data risk management. The newsletter is delivered by Keila (Pentacent OÜ, Estonia), an EU-hosted open-source email marketing platform. By subscribing, you consent to your email address being processed by Keila for newsletter delivery. You can unsubscribe at any time via the link in every email. See our Privacy Policy for details.

10. Availability and backups

LOCAVERDI B.V. makes reasonable efforts to ensure the availability of Readmodel® but does not guarantee uninterrupted access. Scheduled and unscheduled maintenance may occur. In accordance with Art. 10.10 and Art. 38.7 of the NLdigital Terms, the user is responsible for maintaining their own backups unless explicitly agreed otherwise in writing.

11. Intellectual property

All intellectual property rights to Readmodel®, including software, designs, documentation, and template data, are owned by Sving Holding B.V. and licensed to LOCAVERDI B.V. for operation of the service, in accordance with Art. 7 of the NLdigital Terms. The user retains ownership of the data they enter into the application.

12. Liability

Supplier liability is governed by Art. 15 of the NLdigital Terms 2025, supplemented by the following product-specific provisions:

12.1 Free plan (Explore). The free plan is provided "as is" and "as available" without warranties of any kind, whether express or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, accuracy, or non-infringement. LOCAVERDI B.V.'s maximum aggregate liability to users on the free plan — regardless of the form of action — shall not exceed EUR 100.

12.2 Paid plans. For users on a paid subscription, LOCAVERDI B.V.'s maximum aggregate liability for direct damages shall not exceed the total fees actually paid by the user in the 12 months preceding the event giving rise to the claim, subject to the maximum of EUR 500,000 under Art. 15 of the NLdigital Terms.

12.3 General exclusions. Regardless of plan type:

• Indirect damage, consequential loss, lost profits, and lost savings are excluded.
• LOCAVERDI B.V. is not liable for damage resulting from user errors, incorrect data entry, reliance on AI-generated content, or decisions made based on the application's output.

12.4 Data protection obligations. The limitations in sections 12.1 and 12.2 do not apply to breaches of LOCAVERDI B.V.'s obligations as data processor under the Data Processing Agreement or applicable data protection law (GDPR). Processor liability for personal data breaches is governed by GDPR Art. 82 and the Data Processing Agreement.

13. Applicable law and disputes

Dutch law applies. Disputes are resolved in accordance with Art. 18 of the NLdigital Terms 2025 (arbitration via SGOA, Amsterdam).

14. Contact

LOCAVERDI B.V.
KvK: 96035056
BTW: NL867441264B01
Web: Contact form