Privacy policy

1. Data controller

Klarlinje ASP, a Norwegian sole proprietorship, organisation number 936 712 940, Møllergata 6, 0179 Oslo, Norge, is the data controller for information about the people who use the service and the people who visit the website. Contact: hello@donoreye.com.

If you upload letters containing personal data about others (for example donors), you are the controller of that data and we are the processor. See the data processing terms below.

2. What we process, and why

• Your e-mail address: to log you in (code or link), and to send receipts and notices about the service. Basis: contract (GDPR art. 6(1)(b)). We store it encrypted and as a hash.
• The organisation and its profile (name, audience, the choices you make) and who belongs to the organisation: to provide the service. Basis: contract.
• The letters you upload (text, images, PDFs), assessments, variants, reports and videos: to give you feedback. Everything is stored encrypted. Basis: contract.
• Your answers on findings ("Agree" or "I know better"): to improve the service and the assessments. Basis: legitimate interest (art. 6(1)(f)).
• Usage data without content: which AI calls were made (time, purpose, number of tokens and cost), linked to the organisation and the letter, but not the text. To set usage limits, calculate costs and find errors. Basis: legitimate interest.
• Payment: Stripe handles your payment card. We receive a customer ID, plan, status and invoices, and keep accounting records for as long as the accounting act requires. Basis: contract and legal obligation (art. 6(1)(b) and (c)).
• The chat on the front page: your question is sent to our AI provider to get an answer. We do not store the conversation, only the number of tokens and the cost. Do not enter personal data. To prevent abuse we use the IP address briefly in memory, as a hash, to limit the number of questions. It is not stored. Basis: legitimate interest.
• The file you drop on the front page: it stays in your browser until you have confirmed your e-mail address. After that it is stored encrypted with us.
• E-mails you send us: we process them to reply. Basis: legitimate interest.
• Marketing to organisations: we may e-mail contact addresses that organisations have made public themselves about the service. Basis: legitimate interest (in Germany and Spain only after the basis has been confirmed). Every message has an unsubscribe link, and unsubscribing deletes the contact details. We send tips and news to customers only with consent.

3. Cookies

We use only necessary cookies, which do not require consent:

• giverblikk_okt: keeps you logged in. Expires after 60 days or when you log out.
• giverblikk_kode: remembers the login attempt while you enter the code. Expires after 15 minutes.
• giverblikk_sprak and giverblikk_sprak_valgt: remember the language you chose. Expire after one year.

We use no analytics, tracking or advertising cookies, and we load no scripts, fonts or images from third parties. Our web server keeps no access log.

4. Who we share information with

We use these processors. We never sell information, and we use no recipients other than these, apart from authorities when the law requires it.

• Hetzner Online GmbH (Falkenstein, Germany): the server where everything is stored.
• Anthropic (USA): the AI model that reads the letters and makes assessments, variants, the narration for the video and answers in the chat. Content is sent through the API and is not used to train the models.
• ElevenLabs (USA): makes the voice in the skimmer video. Only the short narration (about 25 words, which may quote short extracts from the letter) is sent, not the whole letter.
• Resend (USA): sends e-mail (login code and link, receipts, notices).
• Stripe (Ireland and USA): payment and calculation of value added tax.
• Domeneshop AS (Norway): the domain name and DNS.

5. Transfers outside the EEA

Anthropic, ElevenLabs, Resend and Stripe may process information in the USA. The transfer takes place on the basis of the EU–US Data Privacy Framework or the EU's standard contractual clauses (SCC), depending on the provider.

6. AI and your content

We do not use your content to train AI models, and our agreements with our AI providers do not allow them to train on what we send. The assessment of the letter is advice to you. No decisions about you are made automatically with legal effect.

Preferably upload an unaddressed sample without donors' names and addresses.

7. Security

Everything you write or upload is encrypted (AES-256-GCM) before it is stored, and so are files. E-mail addresses and login codes are stored as hashes. Traffic is encrypted (TLS). Each organisation sees only its own content. If we discover a security breach that concerns you, we notify you and the Norwegian Data Protection Authority when the law requires it.

8. How long we keep it

• Letters, assessments, variants, reports and videos: until you delete them or the account is deleted. When you delete a letter, its files and the narration and voice of the video are deleted too.
• Login codes: deleted after 2 days. Login sessions: expire after 60 days.
• Story checks: deleted automatically after 30 days.
• Account information: until you ask for deletion. We normally delete within 30 days.
• Accounting records (payments, invoices): for as long as the accounting act requires.
• Usage data without content (AI calls and costs): for as long as needed for costs, limits and troubleshooting.

9. Your rights

You have the right of access, rectification, erasure, restriction of processing and data portability, and the right to object to processing based on legitimate interest. Where processing is based on consent, you can withdraw it at any time. E-mail us at hello@donoreye.com. We reply within one month.

If you believe we process information in breach of the law, you can complain to the Norwegian Data Protection Authority (Datatilsynet).

10. Data processing terms

When you upload letters that contain personal data about others (for example the names of donors or recipients), you are the controller and we process the data on your behalf as processor. This section is our data processing agreement under GDPR art. 28 and forms part of the terms of service.

• Purpose and duration: to provide the service, for as long as you are a customer and until the data is deleted.
• Types of data and data subjects: the personal data in the letters you upload (for example names and addresses in examples), about donors and recipients in the letters.
• We process the data only on your documented instructions, which are your use of the service and the terms.
• Everyone with access on our side is bound by confidentiality.
• We have technical and organisational measures as described under "Security" (art. 32).
• Our sub-processors are those listed under "Who we share information with". We notify you by e-mail at least 30 days before we start using a new one, and you can cancel if you do not accept it.
• We help you answer requests from data subjects and deal with security breaches, and we notify you without undue delay if we discover a breach concerning your data.
• When the agreement ends, we delete the data (normally within 30 days) or return it if you ask.
• You can ask for documentation that we comply with this section, and we contribute to audits to a reasonable extent.

11. Changes

We update this policy when the service changes. The date at the top shows when it was last changed. We notify you of material changes.

12. Contact

Klarlinje ASP, Møllergata 6, 0179 Oslo, Norge, organisation number 936 712 940. E-mail: hello@donoreye.com.