Privacy Policy
Last updated: 2026-01-06
1. Introduction
Conshultocracy AB, org. no. 559419-4697 ("Conshultocracy", "we", "us"), is the data controller for the processing of your personal data in connection with the use of our services.
This privacy policy describes how we collect, use, store, and protect your personal data in accordance with the EU General Data Protection Regulation (GDPR) and other applicable data protection legislation.
By using our services, you consent to the processing of your personal data according to this policy.
2. What Personal Data Do We Collect?
2.1 Data you provide
- Account information: Name, email address, password (encrypted), organization name, organization number
- Billing information: Company address, contact person, payment information (handled by Stripe)
- Contact information: Information you provide via contact forms
2.2 Data we collect automatically
- Usage data: Information about how you use the service, including number of screenings, timestamps, and usage patterns
- Technical information: IP address, browser type, device information
- Login logs: Timestamp and status of login attempts
2.3 Screening data
Privacy by Design: We do not store screening results
Screening reports are generated in real-time and downloaded directly to your device. We do not store the results of your screenings on our servers. Only metadata about completed screenings (date, company name) is logged for usage statistics.
3. Nature of Screening Outputs
Important: Recommendations, Not Automated Decisions
Our screening services generate recommendations (such as GO, CAUTION, or STOP indicators) based on aggregated data from multiple sources. These outputs are:
- Initial recommendations only – They represent one input among many that you may consider in your decision-making process
- Not automated decisions – The application does not make any decisions on your behalf. All decisions rest solely with you, the user
- Indicative, not conclusive – Results should be verified through your own due diligence processes before any business decisions are made
- Supporting information – The recommendations are designed to support and inform your professional judgment, not replace it
You retain full control and responsibility for any decisions made based on information obtained through our services. We strongly recommend that screening results be reviewed by qualified personnel and supplemented with additional verification as appropriate for your specific use case.
4. Why Do We Process Your Personal Data?
| Purpose | Legal Basis |
|---|---|
| Provide and administer the service | Performance of contract |
| Manage subscriptions and billing | Performance of contract |
| Send service-related communications | Performance of contract |
| Track usage and prevent abuse | Legitimate interest |
| Improve and develop the service | Legitimate interest |
| Fulfill legal obligations (accounting, tax) | Legal obligation |
5. How Long Do We Keep Your Data?
We retain your personal data only for as long as necessary for the purposes described in this policy:
- Account information: As long as you have an active account, plus 12 months after termination
- Billing information: 7 years according to Swedish accounting law (Bokföringslagen)
- Usage logs: 24 months
- Screening metadata: 24 months (only date and company name)
- Contact inquiries: 12 months
6. Who Do We Share Data With?
We share your personal data with the following categories of recipients:
6.1 Service Providers (Data Processors)
| Provider | Purpose | Location |
|---|---|---|
| Supabase | Database hosting, authentication | EU |
| Stripe | Payment processing | EU/USA* |
| Vercel | Web hosting | EU/USA* |
| Resend | Email delivery | USA* |
* Transfer to USA is made pursuant to the EU-US Data Privacy Framework or Standard Contractual Clauses (SCC).
6.2 Data Sources for Screening
When you perform screenings, queries are sent to external data sources (sanctions lists, company registers, news databases). These services receive the search terms but not your personal data.
7. Your Rights
Under GDPR, you have the following rights regarding your personal data:
- Right of access: You have the right to receive information about what personal data we process about you and to obtain a copy of this data.
- Right to rectification: You have the right to request correction of inaccurate or incomplete data.
- Right to erasure: You have the right to request deletion of your personal data under certain circumstances ("right to be forgotten").
- Right to restriction: You have the right to request restriction of the processing of your data.
- Right to data portability: You have the right to receive your data in a structured, machine-readable format.
- Right to object: You have the right to object to processing based on legitimate interest.
- Right to withdraw consent: If processing is based on consent, you may withdraw it at any time.
To exercise your rights, contact us at conshultocracy@gmail.com.
8. Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, or destruction. This includes:
- Encryption of data in transit (HTTPS/TLS)
- Password encryption (bcrypt)
- Access controls and authentication
- Regular security reviews
- Row Level Security (RLS) in the database
9. Cookies
Our service uses only necessary cookies for the service to function:
- Session cookies: To manage login and authentication. These are deleted when you close your browser.
- Authentication cookies: To keep you logged in between sessions if you choose to stay logged in.
We do not use tracking cookies, analytics cookies, or marketing cookies.
10. Third-Party Screening and Legitimate Interests
Our service enables screening of third-party companies. If you use the service to screen other companies or individuals:
- You are responsible for having a legitimate purpose (e.g., due diligence, compliance, know your customer)
- Screening results are downloaded to your device and are not stored by us
- You are responsible for proper handling of the information you obtain
11. Changes to This Policy
We may update this privacy policy from time to time. For material changes, we will notify you via email or through a notice in the service.
The latest version of the privacy policy is always available on this page.
12. Supervisory Authority
If you believe that we process your personal data in violation of GDPR, you have the right to file a complaint with the supervisory authority:
13. Contact Information
For questions about this privacy policy or our handling of personal data, contact us:
Conshultocracy AB
Org. no: 559419-4697
Svartbäcksgatan 133
753 34 Uppsala
Email: conshultocracy@gmail.com