Privacy Policy
Effective Date: April 30, 2025
Darwyn ApS ("Darwyn," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you visit our website, use our services, or otherwise interact with us.
This Privacy Policy applies when Darwyn acts as a data controller, including on our website and during use of our software-as-a-service (SaaS) platform for AI-powered software maintenance. When we process data on behalf of a customer, we do so as a data processor under a separate Data Processing Agreement (DPA), which includes Standard Contractual Clauses (SCCs) for international data transfers.
1. Who We Are
Darwyn ApS
CVR: 12345678
Ravnsborggade 12C 1. tv, 2200 København N, Denmark
Email: ap@darwyn.ai
2. Personal Data We Collect
We may collect and process the following types of personal data:
- Identity and Contact Data: name, email address, job title
- Account Data: login credentials, user ID
- Technical Data: IP address, browser type, operating system, device identifiers
- Usage Data: how you use our website and SaaS platform
- Communication Data: support requests, feedback, survey responses
- Payment Data: billing address, transaction metadata (if applicable)
3. How We Use Your Data
We process your personal data for the following purposes:
- To operate and improve our website and SaaS services
- To respond to inquiries and support requests
- To provide access to and ensure the security of our platform
- To monitor platform performance and usage
- To comply with legal obligations
- To prevent fraud or abuse
Legal bases under GDPR may include consent, contractual necessity, legal obligation, and legitimate interest.
4. Cookies
We currently do not use cookies for tracking or analytics. Should that change, we will update this policy and provide users with clear options to manage cookie preferences.
5. Subprocessors and International Transfers
We use third-party service providers (subprocessors) to deliver parts of our service. These subprocessors may process data outside the EU/EEA. In such cases, we rely on Standard Contractual Clauses (SCCs) and implement additional safeguards such as encryption and access controls.
Our authorized subprocessors include:
- Microsoft (Azure)
- Google (Cloud APIs)
- OpenAI (AI API)
- Anthropic (AI API)
- Okta/Auth0 (Authentication)
- Stripe (Payment processing)
For more information, see our Data Processing Agreement (available on request).
Business customers are responsible for reviewing our Data Processing Agreement and SCCs to ensure they meet their own compliance and legal requirements. By signing up or using our services, you accept the terms therein.
6. Data Retention
We retain personal data only as long as necessary to fulfill the purposes for which it was collected or to comply with legal obligations. Users may request deletion of their data by contacting us at privacy@darwyn.ai.
7. Your Rights
Under the GDPR, you have the right to:
- Access the personal data we hold about you
- Request correction or deletion of your data
- Object to or restrict processing
- Data portability
- Withdraw consent (where applicable)
To exercise your rights, contact us at privacy@darwyn.ai.
8. Security Measures
We implement appropriate technical and organizational measures to protect personal data, including:
- Encryption in transit and at rest
- Access control and authentication
- Regular system monitoring and logging
- Secure development practices
9. Supervisory Authority
If you are based in the EU, you have the right to lodge a complaint with your local data protection authority. In Denmark, this is Datatilsynet:
Datatilsynet
Carl Jacobsens Vej 35, 2500 Valby, Denmark
www.datatilsynet.dk
10. Changes to This Policy
We may update this Privacy Policy from time to time. The latest version will always be posted on our website with the effective date.
Contact Us
If you have questions or concerns about this Privacy Policy or how we handle personal data, please contact us at privacy@darwyn.ai.