PRIVACY NOTICE – BUSINESS 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 business account with us and subscribe to our Stinto-platform (“Stinto Platform”).
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. ABOUT US
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. PERSONAL DATA COLLECTED
2.1 We collect and process certain personal data about you for the purposes specified in section 3.1 below.
2.2 We collect any personal information that you provide to us directly, including when you subscribe to the Stinto Platform, request other services, or engage in correspondence 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. HOW WE USE YOUR PERSONAL DATA
3.1 We may use your personal data for the following purposes:
a. To provide the services requested by you, including to manage your subscription to the Stinto Platform.
b. To provide you with customer service and to communicate with you about our services, including in respect of changes to our services or our User Agreement.
c. To generate statistics related to your usage of the Stinto Platform.
d. To communicate with you about special offers, promotions, and other news about our services or those offered by our selected partners, including via email, telephone and/or text messages, but always subject to your explicit consent.
e. To comply with our legal obligations and for establishing, exercising, or defending our legal rights.
4. SHARING OF YOUR PERSONAL DATA
4.1 We may share your personal data with the below categories of third parties:
a. Service providers assisting with our business activities such as our payment services providers, hosting providers, and providers of IT support.
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. TRANSFER OF YOUR PERSONAL DATA OUTSIDE OF THE EUROPEAN ECONOMIC AREA (EEA)
5.1 We do transfer your personal data to countries outside of the EEA
5.2 Consent for this transfer is outlined in the Standard Contractual Clauses made available to you when you sign-up to the Stinto Platform.
6. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
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, including in respect of section 5 of the Danish Bookkeeping Act, 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, cf. GDPR, article 6(1)(a).
7. PROTECTION AND STORAGE OF YOUR PERSONAL DATA
7.1 We take your privacy seriously and will accordingly ensure that appropriate technical and organizational 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:
8. YOUR RIGHTS
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.
8.2 You also have the right to lodge a complaint with the Danish Data Protection Agency (“Datatilsynet”).
9.0 CHANGES TO THIS NOTICE
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.