Privacy Policy

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Privacy Policy

Last updated May 2018

This column is a quick guide to Spiir's Privacy Policy. The guide is not part of the policy itself. The grey boxes are a quick guide to Spiir's Privacy Policy. The guide is not part of the policy itself.

1. In general

  • Spiir has two services: The Spiir App and Spiir Web.
  • Spiir processes your information to deliver a good app and web service to you. The information is processed in accordance with the current regulations.
1.1 In this Privacy Policy, "Spiir", "we", "us", and "our" refers to Spiir A/S, with registered address at Mejlgade 48b, 2. th., DK-8000 Aarhus C, Denmark. When using Spiir's website (hereinafter "the Web") or Spiir's app (hereinafter "the App") (collectively "Services"), your personal data is processed in accordance with this policy.
1.2 Data processed by Spiir’s Services will be processed in accordance with applicable legislation and the valid guidelines issued by the Data Protection Agency.

2. Data Controller

  • Spiir is the data controller of the information you provide or that is obtained when you use our services.
  • Spiir is responsible for your information is processed in accordance with the current regulations.
2.1 Spiir is the data controller of personal data used in connection with the following activities and services on the Services:
  • User Profile
  • Consumer Overview
  • Spending Service
  • Voucher Service
  • Account Summary
  • Budget Service
  • Assistant Service
  • Offer Service
  • Quiz Service
  • Benchmarking and statistics

3. What processing is performed?

3.1 User Profile

  • When you create a profile in the app or on web, you must enter your email and a password as a minimum.
  • Spiir needs your information to identify you and to provide its services and customer service to you.
3.1.1 Data

When creating a profile at Spiir, you must enter your email and password.

In addition, Spiir collects, depending on the services you use, other information you provide to Spiir. This can be, for example, your address, number of people in your household, age and gender, as well as other data. Spiir collects this information only if you provide it to Spiir, which is voluntary, but for some functions some of this information is required.

3.1.2 Purpose

Spiir collects your personal data to register and identify you as a user and to provide Spiir’s Services to you. Spiir will also collect the personal data to be able to contact you if it is necessary to confirm your information, answer your questions, and provide customer service to you.

Spiir also collects personal data in order to comply with applicable legislation, comply with governmental requirements, comply with Spiir's internal policies, and to enforce Spiir's Terms of Use.

Finally, Spiir collects your personal data in order to pursue available legal remedies and limit liability in case of any disputes.

3.1.3 Legal basis

Spiir’s legal basis to process said personal data is, that the processing of the data is required for Spiir to provide its services to you. Some information is processed by Spiir because Spiir has a legitimate interest in such processing.

3.2 Account information via financial institution

  • Spiir collects data from your bank to provide our various services to you.
  • You must consent to Spiir’s processing of your username and the PIN to your online bank for Spiir to provide its services to you.
  • If you do not consent, certain features in Spiir’s services will be inaccessible to you.
3.2.1 Data

When you add a bank account to Spiir using the "Add Accounts" feature, you must enter your username (which often is your CPR-number) to your online bank and your service code or online bank PIN. In some cases, depending on your financial institution, this may be other information – however, it is always the same information your bank requires for you to log in.

Only information about account name, balances and transactions is retrieved.

3.2.2 Purpose

Spiir asks for your username (which may be your CPR-number) and code to retrieve information about your accounts, balances and transactions with your bank so that Spiir can provide an overview of your spending and deliver Spiir’s other services to you.

Entering your username for your online bank is thus a prerequisite for using Spiir's account summary, budget service, assistant service, quiz service, and offer service.

Spiir collects your data for the following purposes:

  • Account Summary: Spiir's Account Summary gives you a complete overview of your spending and transactions.
  • Budget Service: Spiir's Budget Service gives you access to set up spending targets and gives you an overview of your spending relative to your budget (Web only).
  • Assistant Service: Spiir's Assistant Service monitors your spending and transactions on your behalf so that you are updated at all times and have an overview of the movements in your account. You will be able to enable notifications, which will notify you when changes occur in your spending.
  • Quiz Service: Spiir’s Quiz Service lets you test your knowledge of your own spending.
  • Spending Service: Spiir’s Spending Service lets you categorize your various spending items.
  • Offer Service: In some cases, based on your information about your spending Spiir's Offer Service gives you access to special offers regarding goods and services that you often purchase.
  • Benchmarking: Using your spending, data Spiir calculates statistics and performs benchmarking. Spiir ensures your personal data’s anonymity, so that statistical data does not contain personal information and thus cannot be traced back to you. The statistics make it possible for you as Spiir user to compare your own spending to a particular group in society.
3.2.3 Legal basis

You can consent to Spiir using your User Name (CPR-no.) or other log in information for your online bank so that Spiir can retrieve data about your accounts, balances, and transactions. By your consent, you confirm that Spiir may use your account data in accordance with this Privacy Policy.

3.2.4 If you do not consent

If you do not consent to Spiir using your account information to access your spending data, you will not be able to use certain features in Spiir’s Services, including account history, quiz service, assistant service, budget service, offer service, etc. However, you may be able to manually upload your data, see below.

3.3 Account Information - Manual Upload - Only Web

  • On the Web service your transaction information may be uploaded manually.
  • By supplying your transaction information, you can use Spiir's various services on both App and Web – subject to certain restrictions.
3.3.1 Data

You can manually upload your transaction data to Spiir via the Web.

3.3.2 Purpose

Once you have manually uploaded your transaction data, you have the option to use Spiir's various services. For manual upload, there may be restrictions to the services:

  • Account Summary: Spiir's Account Summary gives you a complete overview of your spending and transactions.
  • Budget Service: Spiir's Budget Service gives you access to set up spending targets and gives you an overview of your spending relative to your budget (Web only).
  • Assistant Service: Spiir's Assistant Service monitors your spending and transactions on your behalf so that you are updated at all times and have an overview of the movements in your account. You will be able to enable notifications, which will notify you when changes occur in your spending.
  • Quiz Service: Spiir’s Quiz Service lets you test your knowledge of your own spending.
  • Spending Service: Spiir’s Spending Service lets you categorize your various spending items.
  • Offer Service: In some cases, based on your information about your spending Spiir's Offer Service gives you access to special offers regarding goods and services that you often purchase.
  • Benchmarking: Using your spending, data Spiir calculates statistics and performs benchmarking. Spiir ensures your personal data’s anonymity, so that statistical data does not contain personal information and thus cannot be traced back to you. The statistics make it possible for you as Spiir user to compare your own spending to a particular group in society.
3.3.3 Legal basis

When you manually upload your account information, you must also agree to Spiir using your account information in accordance with this Privacy Policy.

3.3.4 If you do not consent

When manually uploading your account information, if you do not consent to Spiir using said data, you will not be able to use certain features of Spiir’s Services, including account history, quiz service, assistant service, budget service, offer service, etc.

3.4 Offer Service

  • With your consent, Spiir can send you great offers based on your profile and/or overall spending information.
  • Spiir processes some of your information on an overall level to provide you with great offers.
  • The purpose of processing your data is to be able to target relevant offers to you.
3.4.1 In general

If you want Spiir to provide you with relevant and targeted offers based on your spending information on the Web or in the App, you must give Spiir consent hereto.

Spiir only provides you with a few, relevant, and targeted offers. As the offers will be based on overall information about your spending, there will often be special offers on goods and services that you already purchase.

Spiir never gives sellers access to your information without your specific and explicit consent.

3.4.2 Data

If you consent to Spiir using your data for Spiir's Offer Service, Spiir will process the following data:

  • Email address
  • Profile information (personal information)
  • Overall spending data

Your overall spending data is used solely for placing you in a consumer category.

3.4.3 Purpose

The purpose of using your information in the Offer Service is to be able to target relevant offers from Spiir and Spiir’s partners to you.

3.4.4 Legal basis

Processing is based on your consent.

3.5 Voucher Service

  • You can use Spiir's Voucher Service to save receipts and documents and associate them with transactions.
  • Spiir processes your receipts and documents and information provided on these.
  • The processing is performed for you to be able to find them again.
3.5.1 In general

You can upload electronic copies of your vouchers and receipts via the Web and the App.

Spiir stores these so you can always retrieve vouchers and receipts and, to the extent possible, Spiir will make your vouchers and receipts searchable.

You can attach vouchers and receipts to certain transactions to improve your overview.

3.5.2 Data

In the Voucher Service, the electronic copies of your vouchers and receipts is processed.

When the voucher or receipt is made searchable, the data on the voucher or receipt is processed.

3.5.3 Purpose

The purpose of the processing is to enable you to retrieve your vouchers and receipts and associate them with payment transactions.

3.5.4 Legal basis

The processing is required for Spiir to provide its Voucher Service.

3.6 Technical Information

  • Spiir registers several technical data when you use Spiir’s Services and other services.
  • The purpose of the collection is to optimize Spiir’s Services and track any potential abuse.
3.6.1 In general

Spiir registers several technical data when you use Spiir’s services.

3.6.2 Data

Spiir registers your IP address, operating system, and device information when using Spiir’s Services, and browser information and settings when using the Web.

3.6.3 Purpose

Spiir collects the technical data for the purpose of making technical improvements and optimization of its Services and other services

In addition, IP address, device Information, and browser information is collected by Spiir to track any illegal activities and track abuse of its Services.

3.6.4 Legal basis

Spiir has a legitimate interest in obtaining your technical information in order to improve and optimize its Services and to prevent and pursue abuse of its Services.

3.7 Cookies etc.

  • Spiir uses cookies and other technical measures in our services.
  • Cookies, etc. are used for various purposes. Some are required, others help remember your preferences, and others are used for analytical purposes. Some are used for marketing purposes.
  • You can always delete or block cookies, but the use of Spiir’s services may be restricted by doing so.
3.7.1 In general

By using Spiir’s Services, you agree that Spiir uses cookies and so-called widgets on the Web, and so-called tracking identifiers on the App for various purposes.

You can read more about Spiir’s use of cookies, widgets, and tracking identifiers here.

3.7.2 Purpose

The cookies, etc., which Spiir uses on its Services have various purposes.

On the Web:

  • Required cookies. These are cookies that are necessary for you to use the Web, for example, remember that you are logged in to the Web.
  • Preference cookies. These are cookies that remember your settings, for example, your login may be remembered if you have requested this.
  • Analytical cookies. These are cookies that are used to measure and analyse how the Web is used.
  • Widgets. On the web, so-called widgets from Facebook and Twitter are used, so Spiir can display the latest Spiir activities from Facebook and/or Twitter. If you are logged into Facebook or Twitter, the overview is personal.

In the App:

  • Required tracking identifiers. These are used to distinguish between different mobile devices and to send push messages.
  • Analytical tracking identifiers. These are used to analyse how the App is used and to optimize the App.
  • Marketing tracking identifiers. These are used to measure and enhance the effect of Spiir's marketing for Spiir’s Services.
3.7.3 Withdrawal of consent/deletion of cookies

You may at any time withdraw your consent for Spiir to use cookies on the Web. In your browser, you can delete and block the use of cookies. How you do this depends on which browser you are using. If you use more than one internet browser, you must delete and block the use of cookies in all of them. You can find instructions on how to do this at youronlinechoices.eu.

3.7.4 If you do not accept cookies, etc.

If you do not agree that cookies are used on Spiir’s the Web, you can either choose to stop using Spiir or delete cookies and block the use of cookies. Blocking cookies may lead to some functionality not being accessible on the Web.

In the App, it is not possible to delete or deselect the use of tracking identifiers. Therefore, if you do not accept the use of tracking identifiers, please do not use the App and uninstall it.

3.8 Support

  • If Spiir is to provide support for you, Spiir may process personal data so we can help you.
  • Spiirs support can only access your transactions if you give explicit consent to it. The consent can always be recalled and expires after 7 days.
3.8.1 In general

Based on your inquiry, Spiir provides support in connection with your use of Spiir’s Services.

When providing support, Spiir may access restricted personal data that is registered about you. However, only data that is required will be accessed. Spiir will only access your transaction data with your prior consent.

3.8.2 Data

When you contact Spiir support, Spiir's employees can access restricted data about your user:

  • Your e-mail address
  • Names of the banks and accounts you have added to Spiir
  • Information about which features in Spiir you use and to what extent
  • Logs of events, such as when you have logged on or errors have occurred during the use of our Services, etc.

Spiir’s employees cannot access your detailed information such as your accounts’ balances, your transaction information, and your vouchers, unless you give your explicit consent.

3.8.3 Purpose

The purpose of Spiir's access to your information is to provide support and resolve any challenges you may have encountered using Spiir’s Services.

3.8.4 Legal basis

Spiir accesses your information in connection with support to fulfil its agreement with you, including meeting your need for assistance.

Spiir will only access your detailed data in connection with support, if you on Spiir’s request or your own accord explicitly consent hereto.

3.8.5 Withdrawal of consent

You may withdraw your consent at any time for Spiir to access your detailed data. After this, Spiir's support cannot be accessed for support purposes. Your consent will automatically expire after 7 days.

3.8.6 If you do not consent

If you do not consent to Spiir accessing your detailed data when providing support, there may be issues that Spiir cannot provide support for.

4. Recipients/data disclosure

  • Spiir only transfers your personal data with your consent, or where it is statutory, or to process legal claims.
  • You can allow others, such as your spouse or partner, to see your information in Spiir. You can always change this again.

4.1 The personal data held by Spiir will not be disclosed to third parties without your consent, unless Spiir under the legislation is required to disclose the data, or if disclosure is required for Spiir to protect itself or to enforce legal claims.

4.2 You can give other Spiir users access to view your information in Spiir. For example, it may be a spouse or partner. If you choose to do this, you simultaneously agree that Spiir, in order to comply with this agreement with you, must disclose your information to the person concerned. You can always change this on the Web and in the App.

5. Storage Period

  • Spiir stores your personal information as long as you are a user of Spiir. However, if it is statutory or needed to handle legal claims, personal data is stored for a longer period.
  • Spiir can anonymize your information instead of deleting it.

5.1 Spiir stores your personal data until you delete your Spiir user. However, Spiir may store data for a longer period, if required to comply with legal requirements or to protect Spiir's legal interests.

5.2 In some cases, instead of deleting your personal data, Spiir will anonymize these so that the data can no longer be attributed to you.

6. Privacy Rights

  • You have several rights when Spiir processes your personal data.
  • You are entitled to insight into how Spiir's processes your personal data.
  • You have the right to have incorrect information corrected.
  • You are entitled to delete your information in some cases, and you can always delete your profile.
  • You have the right to so-called data portability.
  • You can always object to Spiir's processing of your personal data.
  • You always have the right to object with Spiir's use of your personal data for direct marketing.

6.1 At any time, you have the right to know what personal data Spiir processes about you, the purpose of the processing, where Spiir has obtained your personal data, and the identity of any recipient of your personal information.

6.2 At any time, you have the right to rectify incorrect or misleading personal data that Spiir is processing about you. You can correct personal information, such as your name, e-mail address, etc. via your personal profile. Spiir would like to hear from you if we can help you correct your information.

6.3 In certain cases, you may require that the data Spiir processes about you is deleted. At any time, if you do not want to use Spiir’s Services any more, you can delete your personal profile via the Web or via the App. All the data registered with your profile will then be deleted or anonymized and will not be recoverable.

6.4 At any time, you are entitled to receive the personal data you have provided Spiir with in a commonly used and machine-readable format. You can always retrieve your personal data via the Web.

6.5 You may at any time object to Spiir's processing of your personal data due to your particular circumstances.

6.6 At any time, you may object to Spiir's use of your personal data for direct marketing purposes. Spiir will then discontinue such use.

7. Transfer of personal data outside the EU

  • Spiir may transfer your data to certain data processors in countries outside the EU.
7.1 Spiir uses certain data processors located outside the EU. Below are the entities and legal bases for the transfer.
Apple, Inc. USA Standard Contractual Clauses
Slack Technologies, Inc. USA Privacy Shield
The Rocket Science Group LLC. USA Privacy Shield
SendGrid, Inc. USA Privacy Shield
Google, Inc. USA Privacy Shield
Branch Metrics, Inc. USA Privacy Shield
Functional Software, Inc. USA Privacy Shield
Help Scout, Inc. USA Privacy Shield
7.2 Upon request, Spiir may refer you to where you can obtain a copy of the applicable legal transfer basis.

8. Confidentiality

  • Spiir handles your data confidentially. However, data can be accessed if necessary to resolve technical issues or to provide support to you, and Spiir asks for permission.
8.1 Spiir always handles your personal data confidentially. Appointed employees with Spiir have the authority to access data where it is necessary to solve operational or technical issues. In connection with support for you, Spiir employees may, with your consent, access your transaction data. All Spiir's employees are subject to strict confidentiality requirements when processing personal data.

9. Withdrawal of consent

  • You can always withdraw all or some of your consents to Spiir.
9.1 At any time, you can withdraw your consent on the Web or in the App by deleting your profile at Spiir or by contacting Spiir.
9.2 If you withdraw one or more of your consent(s) you may no longer be able to use Spiir’s Services in whole or in part.

10. Changes to the policy

  • Spiir may change this privacy policy at any time. You will be informed of any changes.
10.1 Spiir reserves the right to change this policy at any time without prior notice. Changes to the policy will come into effect upon publication of the policy in Spiir’s Services.
10.2 Spiir also informs you of changes to the policy by contacting you at the email address you provided when setting up your profile or by push message.

11. Data Protection Officer

  • If you have questions about Spiir's processing of your personal data, you can always contact dpo@spiir.dk.
11.1 Spiir has appointed a data protection officer who advises Spiir regarding the processing of personal data and can guide you on how to exercise your rights. You can contact Spiir’s Data Protection Officer by contacting Spiir A/S, Att .: DPO, Mejlgade 48b, 2. th., DK-8000 Aarhus C, Denmark or dpo@spiir.dk.
11.2 If you have questions about the Privacy Policy or Spiir's processing of your personal data, please contact Spiir’s Data Protection Officer.

12. Complaints

  • If you want to complain about Spiir's personal data processing you may contact Spiir directly or contact the Danish Data Protection Agency (Datatilsynet).
12.2 If you wish to file a complaint regarding the processing of your personal data, we would love to hear from you. Spiir’s contact information can be found in section. 11.1. You can also file a complaint with Datatilsynet, Borgergade 28, 5. 1300 København K, Denmark or www.datatilsynet.dk.

13. Version

  • The Privacy Policy was last updated in May 2018.
13.1 This Privacy Policy has been updated in May 2018.
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