Privacy Policy – Private Account

This Privacy Notice (“Notice”) describes how Stinto ApS, Strandvænget 41, 2960 Rungsted Kyst as incorporated in Denmark with company registration number 38 29 25 60 (“we”, “us”, “our”) processes your personal data when you create a private account with us and subscribe to our Stinto-platform (“Stinto Platform”). 

This Notice only covers the personal data we process about you in relation to your private account on the Stinto Platform. If you are also using the Stinto Platform via a business account created by your employer, your employer will be the data controller of your personal data processed in that connection. 

Please see your employer’s privacy notice for further information on its processing of your personal data. By using our Stinto Platform, you acknowledge and agree that your personal data may be processed in accordance with this Notice. Processing your personal data is, amongst others, necessary in order for us to be able to enter into and perform under a contract entered into with you and to communicate with you in relation to your subscription to the Stinto Platform. 


1.1. We are the data controller in respect of any personal data that we process about you under the User Agreement pursuant to the Danish Data Protection Act, Regulation (EU) 2016/679 of 27 April 2016 (“GDPR”) and all other applicable law from time to time relating to the processing of personal data. 

1.2. If you have any comments or enquires related to this Notice, please do not hesitate to contact us at: Stinto ApS Strandvænget 41 2960 Rungsted Kyst Denmark E-mail: info@stinto.com 


2.1. We collect and process certain personal data about you for the purposes specified in section 3.1 below. 

2.2. We collect the personal data that you provide to us directly, including when: a. you create a private account with us or subsequently if you update your details (such as name, postal address, email address, phone number, title, current and former workplaces, URL’s for Social Media, profile pictures), b. you use our Stinto Platform to send messages to other users, to take notes or otherwise, and c. you correspond with us. 

2.3. In addition, we automatically collect certain information about your use of our webpage and the Stinto Platform via cookies. Our cookie notice can be accessed on our webpage and via the Stinto app. 


3.1. We only use your personal data for the following purposes: a. To provide the services requested by you, including to manage your subscription to our Stinto Platform. b. To facilitate your communication with other users via our Stinto Platform. c. To provide you with customer service and to communicate with you about our services, including in respect of changes to our services or End User License Agreement. d. To generate statistics related to your usage of the Stinto Platform. e. To communicate with you about special offers, promotions, and other news about our services, including via email, telephone and/or text messages, but always subject to your explicit consent. f. To comply with our legal obligations and for establishing, exercising or defending our legal rights.  


4.1. We may share your personal data with the below categories of third parties: a. Your employer for the purpose of linking your private account to your business account (please note that only your private email address will be shared, not your collected business cards). b. Our advisors, including accounting firms and law firms. c. Public authorities such as the tax authorities, but only to the extent required by law, court order or if necessary to establish, exercise or defend our legal rights. d. Other third parties i) with your consent, ii) if they are involved in a merger, de-merger or a sale which involves all or part of our business or assets, or ii) if otherwise compatible with the purpose for which the personal data were initially collected. 

4.2. You can rest assured that any such transfer of your personal data will take place in accordance with applicable data protection legislation and subject to appropriate security measures. 


5.1. We do not transfer your personal data to countries outside of the EEA without your explicit consent. 


6.1. We will process your personal data in accordance with this Notice because it is necessary: a. for entering into or performing under a contract entered into with you, including in order to provide our services to you, register and process claims and to respond to enquires made by you, cf. GDPR, article 6(1)(b); b. for compliance with our legal obligations, cf. GDPR, article 6(1)(c); and c. for the purpose of furthering our legitimate interests, including in respect of i) correspondence with you, ii) improving or developing our services, our webpage and the Stinto Platform, iii) operating our services, our webpage and the Stinto Platform, and iv) establishing, exercising or defending our legal rights, cf. GDPR, article 6(1)(f). 

6.2. We will also process your personal data on the basis of any consents provided by you, for example to communicate with you about special offers, promotions, events and other news about our services or those offered by our selected partners (GDPR article 6(1)(a)). 


7.1. We take your privacy serious and will accordingly ensure that appropriate technical and organisational safeguards are in place at all times in order to protect your personal data against unauthorized or unlawful processing and against accidental loss, damage, destruction, alteration or disclosure. 

7.2. The personal data we collect about you will only be stored as stated below: Purpose of processing Retention period Entering into or performing under a contract entered into with you. Up to 3 years after your private account with us is deleted or as long as storage is required by applicable law Sending you newsletters and other marketing material. Until your consent is withdrawn or has not been used by us for 1 year. Corresponding with you (for example, in relation to enquiries about our services). Up to 3 months after your enquiry has been handled or until there is no reason to believe that further correspondence will be needed. 


8.1. Subject to certain conditions set out in data protection legislation, you have the following rights in respect of your personal data: a. The right to obtain a copy of the personal data we have collected about you in a commonly used electronic form and to transmit said copy to another data controller. b. The right to rectify or complete the personal data we have collected about you if it is inaccurate or incomplete, and (in special circumstances) to have the data deleted. c. The right to restrict the processing of the personal data we have collected about you. d. The right to object to the processing of the personal data we have collected about you, including in respect of direct marketing. e. The right to withdraw any consent you have provided in respect of our processing of your personal data. If you would like to exercise any of the above rights or have any questions regarding the processing of your personal data, please contact us by using the contact information in section 1.2 above. 


9.1. From time to time we may change this Notice. Any such changes will be published on our webpage at www.stinto.com and any material changes made will also be notified to you by email with a notice of 30 days to the end of a month. If upon receiving such notice you do not agree to the changes, you may terminate your subscription to the Stinto Platform at any time with effect from the effective date of the changes by notifying us at least ten working days prior to said date. If you do not terminate your subscription to the Stinto Platform in accordance with the foregoing, the changes shall be deemed accepted.

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