Bodanean Averholm product

Bodane does not claim EU-only sub-processors. Here is what it does claim.

Averholm’s other product processes your clients’ personal data, and every one of its sub-processors is in the EU. Bodane is a different product with a different shape: what it analyses is published law, and the analysis is done by a provider in the United States, because no EU processing region is available to us for it. Saying otherwise would be the easiest thing on this page and the only unforgivable one.

The boundary, in full.

Read the two columns against each other. Everything Bodane sends anywhere is on the left; everything that stays inside your deployment is on the right. There is no third category.

Leaves the deployment

Public legislative text, redacted

When the document-reading step ships, this — and only this — is what is sent out for analysis:

  • The text of Luxembourg bills and the documents filed with them — the exposé des motifs, the fiche d’évaluation d’impact, the commentaire des articles. All of it already published by the State.
  • With the direct contact details of named officials removed first. Explanatory documents routinely carry a civil servant’s desk telephone number and e-mail address; there is no reason for those to travel.
Sent toA commercial language-analysis provider in the United States.
Why thereIt offers no EU processing region for this. That is a real constraint, not a preference, and we would rather state it than dress it.
StatusIn build Not running against any customer’s account today.
Never leaves the deployment

Everything of yours

None of the following is sent to that provider, or to any other third party, in any form — not as a prompt, not as an example, not as training data:

  • Your topic definitions. The keywords, ministries and directives that describe your practice are the most commercially revealing thing in the system. They are matched locally, against text, inside your deployment.
  • Your verdicts. What you marked relevant, and what you did not.
  • Any client data. Bodane never asks for it. There is no place in the product to put a client name, and no reason to.
  • Your users. Names, e-mail addresses, sessions, what anyone looked at and when.
ConsequenceThe provider is sent public law and nothing that identifies who is interested in it. It cannot infer your book from what it sees.

The analysis is performed on the corpus, not per customer: a bill is read once and the result is available to every deployment. A firm’s topics are then matched against that reading locally. Which is both cheaper and the reason the topic definitions never need to travel.

Where it runs is a choice, not a tier.

Bodane runs on our infrastructure or on yours. Same product, same features, same price. Nothing is withheld from the self-hosted build to make the hosted one look better — that trick is how self-hosting usually gets sold, and it is why nobody trusts it.

On our infrastructure

Hosted in the EU

We run it, we keep it current, you log in. The deployment and its database are in the European Union.

You getNothing to operate. Updates as they land.
Trade-offYour topics and verdicts sit in a system we operate, under a processing agreement, rather than one you operate.
On yours

Inside your own walls

The same application, installed on infrastructure you control. We never see your topics, your verdicts or your users, because there is nowhere for them to reach us from.

You getFull control of the data, and the ability to switch the enrichment step off entirely — in which case nothing leaves your network at all and Bodane runs on titles, ministries, bill types and transpositions.
Trade-offYou operate it, and you apply the updates.

The legislative data is not ours, and the licence has terms.

Luxembourg publishes its legislative register as open data under the Creative Commons Attribution 4.0 licence. That licence permits everything Bodane does with it — copying, storing, analysing and showing it to you — on one condition: attribution.

So the attribution is not a courtesy line in a footer we hope you overlook. It appears next to legislative content wherever that content appears, on this site and in the product, and it names the source exactly as the licence requires.

Source: Légilux, Service central de législation, Ministère d’État, Grand Duchy of Luxembourg — licensed CC BY 4.0. the line the licence requireson every page showing legislative content

Bodane is not affiliated with, endorsed by, or acting for the Grand Duchy of Luxembourg. Reproducing the State’s published texts under an open licence does not make us a source of law; the register is.

And this website.

The easiest place to catch a compliance vendor contradicting itself is its own marketing site. Open the network tab while you read this one.

Bring your DPO to the conversation.

This page is the short version. If your firm needs the long one — the processing agreement, the retention rules, the exact redaction — ask, and we will go through it line by line rather than sending a brochure.

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