A. Name and Contact Information

The data controller (referred to as “we”, “us”, “our”) for the SundLøn app (web, iOS and Android) is Aescul.app ApS, CVR no. 38582879, Steen Billes Gade 7, 2100 Copenhagen Ø, Denmark, and can be contacted at [email protected] and through our website https://aescul.app.

B. Purpose of Processing

The overall purpose of the processing is to make the app work, to allow the user to create and use their account, and to enable us to provide, maintain and improve SundLøn.

We process information for the following purposes:

• account creation, login and secure access to the user profile
• calculation, display and synchronization of the user's own work, salary and employment information
• handling subscriptions, purchases, purchase restoration and subscription status
• technical operation, troubleshooting, crash reporting and security
• user feedback, when the user chooses to send feedback
• limited product analytics, so we can see whether central flows in the app work, for example sign-up, login, lost passkey, payment flow and use of the employment feature

Product analytics are not used for advertising, resale of data or tracking across other apps and websites.

The user enters personal data in the app themselves in the form of registrations of performed work, vacation and similar information, as well as salary conditions. The app processes the information, performs salary review and provides an overview of the entered data.

The processed data is stored in a database through our own server, and data is also stored locally in the app so the user can use it offline for shorter periods.

C. Categories of Data Subjects and Personal Data

The data subjects whose personal data is handled are registered users of the app.

The ordinary personal data that may be processed is:

• Contact information: first name, last name, profession, authorization ID and email
• Salary and financial information: salary rates and salary supplements
• Work and employment information: workplace, employment period, workdays and work periods
• Professional qualifications: special work functions
• Pension information
• Vacation
• Purchase information: subscription status and transaction metadata. We do not receive card information
• Technical information: app version, operating system, device type, technical errors, crash logs, performance information and similar diagnostic information
• Usage information: high-level events in the app, for example that a flow was started, completed or failed. We do not send names, email, authorization ID, workplace, employment dates, salary information, comments or free text as product analytics
• Feedback information: the text the user writes in the feedback form. If the user actively chooses it, a screenshot may also be attached. The screenshot may contain information visible in the app at the time the user sends feedback

Special categories of personal data:
We do not knowingly process special categories of personal data as part of product analytics, crash reporting or subscription management. However, the user may enter information in free-text fields or feedback, and this information may in some cases contain sensitive information. The user should therefore avoid writing sensitive information in feedback unless it is necessary for the inquiry.

D. Categories of Recipients and Data Processors

Personal data is stored and processed on our backend servers and in our database. To support offline functionality, a local copy is stored on the user's device through PowerSync/SQLite as well as local preferences.

We also use the following data processors and third-party providers:

• ZITADEL for identity and login
• RevenueCat for handling purchases, subscriptions, subscription status and purchase restoration
• Apple and Google as app stores and payment facilitators
• Sentry for crash reporting, error monitoring, technical diagnostics and user feedback
• PostHog for limited product analytics of central flows in the app

Sentry is configured not to send standard personal data by default. Feedback is only sent when the user chooses to send it. A screenshot with feedback is only sent when the user has actively chosen to attach it.

PostHog is used for minimal product events. Session replay and PostHog error tracking are disabled. We do not use PostHog for advertising or tracking across other apps and websites.

We enter into data processing agreements where required.

E. Transfers to Third Countries and International Organizations

We only use EU regions and EU-based processing. See also section D.

F. Deletion

We retain the user's information for as long as necessary to provide the service and comply with legal requirements. The user can delete their user profile in the app at any time, after which we delete or anonymize the user's personal data. Local copies on the device are deleted when the user uninstalls the app.

We may retain aggregated and anonymized data for statistics and service improvement.

As a general rule, data is retained until the user deletes it. If a user is inactive for more than 5 years, they will be contacted by email. Data is permanently deleted if the user does not indicate that they wish to keep it.

G. Technical and Organizational Measures

We use appropriate technical and organizational measures, including access control, logging, secure storage and encryption where relevant. We ensure that all administrators observe confidentiality and handle users' personal data responsibly.

H. Your Rights

You have the right to access, rectification, deletion, restriction, data portability and objection to processing. You may also lodge a complaint with the Danish Data Protection Agency. Contact us at [email protected] to exercise your rights.

I. Cookies, Local Storage and Technical Identifiers

The app uses necessary local storage for login, operation, offline functionality and user settings. The app may also use technical identifiers for subscriptions, troubleshooting, crash reporting and product analytics.

We do not use cookies or technical identifiers for marketing or advertising.

J. Changes

We may update this privacy policy. The latest version will always be available in the app.