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Privacy Policy

Last updated: 15 June 2026

Liveline is a Live Intent™ scoring product operated by Phishr Limited, trading as Everhold. This policy explains what personal information we collect, why we process it, who we share it with, and the rights you have under UK data protection law. We keep it in plain language on purpose.

On this page
  1. Who we are
  2. Controller and processor
  3. Information we process
  4. Why we process it & our legal basis
  5. Sharing & sub-processors
  6. International transfers
  7. How long we keep it
  8. How we keep it safe
  9. Your rights
  10. Cookies & analytics
  11. Children
  12. Changes to this policy
  13. Contact us

1. Who we are

Liveline is operated by Phishr Limited (trading as Everhold), a company registered in England and Wales. Where this policy says "we", "us", or "Liveline", it means Phishr Limited.

  • Legal entity: Phishr Limited (trading as Everhold)
  • Registered address: 71–75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
  • Data protection contact: support@everholdhq.com

2. Controller and processor

Liveline handles two very different kinds of personal information, and our role is different for each. This distinction matters, so we call it out clearly.

Account data — we are the controller. Information about you as a Liveline user (your name, email, billing details, and how you use the product) is something we decide the purposes for. This policy governs how we handle it.

List data you upload — we are the processor. When you upload prospect contacts and phone numbers to be scored, you (or your organisation) remain the controller of that data. Liveline only processes it on your documented instructions to deliver the scoring service. You are responsible for having a lawful basis to upload and process that data, and for your own compliance with telephone-marketing, do-not-call, and consent rules when you later dial it. Liveline scores numbers; it never places calls.

3. Information we process

Information about you (account data)

  • Identity & contact: name, work email address, company name, and job title.
  • Authentication: account credentials and session tokens (passwords are hashed and managed by our authentication provider; we never store them in plain text).
  • Billing: plan, credit balance, and transaction records. Card details are handled by our payment processor — we do not store full card numbers.
  • Usage & technical: product activity, log data, device and browser information, IP address, and approximate location derived from it.
  • Communications: messages you send us and your support history.

List data you upload (processed on your behalf)

  • Contact records you submit for scoring — typically names, phone numbers, company, and role — together with the enrichment attributes and Live / Maybe / Dead scores we return.
  • Dial outcomes you choose to log back to us (e.g. connected / no-answer) to improve scoring accuracy for your account.

4. Why we process it & our legal basis

Under UK GDPR we rely on the following legal bases for processing account data:

PurposeLegal basis
Creating your account and providing the scoring servicePerformance of a contract (Art. 6(1)(b))
Billing, credits, and fraud preventionContract (Art. 6(1)(b)) & legal obligation (Art. 6(1)(c))
Securing, maintaining, and improving the productLegitimate interests (Art. 6(1)(f))
Product and marketing emails to customersLegitimate interests, or consent where required (Art. 6(1)(a)/(f))
Meeting our legal and accounting obligationsLegal obligation (Art. 6(1)(c))

For list data you upload, your organisation is the controller and is responsible for establishing the lawful basis for that processing; we act only on your instructions as processor.

5. Sharing & sub-processors

We do not sell personal information. We share it only with the service providers needed to run Liveline, each under a data-processing agreement, and only as necessary. Our key sub-processors are:

ProviderPurpose
Amazon Web Services (AWS)Cloud hosting & database infrastructure
Phone-data enrichment vendorsWaterfall enrichment of the numbers you submit for scoring
StripePayment processing & billing
ClerkAuthentication & account management
Product analytics & email providersUsage analytics and transactional/product email

We may also disclose information where required by law, to enforce our terms, or to protect the rights, safety, and security of Liveline, our customers, or others. If our business is restructured or acquired, information may transfer as part of that transaction, subject to this policy.

6. International transfers

We host the core platform in the UK/EEA wherever practical. Where a provider processes data outside the UK or EEA, we rely on an adequacy decision or appropriate safeguards (such as the UK International Data Transfer Agreement or Standard Contractual Clauses) to protect it.

7. How long we keep it

We keep personal information only as long as necessary for the purposes above:

  • Account data is retained while your account is active and for a reasonable period afterwards to meet legal, tax, and accounting obligations.
  • List data you upload is retained to deliver and improve scoring for your account, and is deleted within 30 days of you deleting it or closing your account, except where we must retain a record by law.
  • Credentials and session tokens are purged promptly when an account is deleted.

8. How we keep it safe

We apply technical and organisational measures appropriate to the risk, including encryption in transit, access controls on a need-to-know basis, hardened cloud infrastructure, and regular review of our security practices. No system is perfectly secure, but we work to protect your information and to notify you and the regulator of any qualifying breach as the law requires.

9. Your rights

Under UK data protection law you have the right to:

  • Access the personal information we hold about you and details of how we process it.
  • Rectification of information that is inaccurate or incomplete.
  • Erasure of your information, where we are not required to keep it.
  • Restrict or object to certain processing.
  • Data portability — to receive your data in a structured, commonly used, machine-readable format.
  • Withdraw consent at any time, where processing is based on consent.

To exercise any of these, email support@everholdhq.com. If your request concerns list data we process on behalf of a customer, we will refer you to, or act on the instructions of, that customer as controller.

You also have the right to complain to the UK supervisory authority, the Information Commissioner's Office (ICO): www.ico.org.uk · 0303 123 1113 · Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. We'd appreciate the chance to resolve it with you first.

10. Cookies & analytics

We use strictly necessary cookies to keep you signed in and the service working, and a small set of analytics cookies to understand product usage so we can improve it. You can control non-essential cookies through your browser settings or any cookie controls we provide in-product.

11. Children

Liveline is a business tool and is not intended for anyone under 16. We do not knowingly collect personal information from children.

12. Changes to this policy

We may update this policy from time to time. When we do, we'll revise the "last updated" date above and, for material changes, take reasonable steps to let you know. Continued use of Liveline after an update means you accept the revised policy.

13. Contact us

For any privacy question or request, contact our data protection lead by email at support@everholdhq.com, or by post to: Data Protection Lead, Phishr Limited, 71–75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ.

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