Privacy Policy

Last updated: March 2026

1. Introduction

This Privacy Policy explains how Holmen Innovative Solutions AS ("we", "us") collects, uses, and protects your personal data when you use Dinslekt.

2. Data We Collect

Account data: Name, email address, encrypted password
Technical data: IP address, browser type, device information
Usage data: Login times, feature usage statistics
Payment data: Handled by Stripe; we do not store card details
User content: Family tree data, photos, documents, notes

3. How We Use Data

To provide the genealogy service
To send service-related emails (password resets, notifications)
To send marketing emails (only if you opted in)
To improve the service
To prevent fraud and abuse

4. Legal Basis (GDPR)

Contract performance: Processing necessary to provide the service
Legitimate interests: Security, service improvements, fraud prevention
Consent: Marketing emails and optional analytics

5. Data Sharing

Stripe: Payment processing
AWS SES: Email delivery
We never sell your personal data
We may disclose data if legally required

6. Data Retention

Active accounts: data retained while account exists
Deleted accounts: data removed within 30 days
Backup retention: up to 90 days
Legal hold exceptions may apply

7. Your Rights (GDPR)

Under GDPR, you have the following rights:

Access your personal data
Correct inaccurate data
Delete your account and data
Export your data (GEDCOM format)
Object to certain processing
Withdraw marketing consent at any time

To exercise these rights, visit your Profile page or contact us.

8. Cookies

Essential cookies: Session management, security, login state
Analytics cookies: Only used if you consent via the cookie banner

9. International Data Transfers

Data is primarily processed in the EU/EEA
We use AWS data centers in the EU
Standard contractual clauses apply where necessary

10. Security Measures

All data transmitted via encrypted HTTPS connections
Passwords are hashed using bcrypt
Access controls and regular security reviews

11. Children's Privacy

Our service is not intended for users under 16 years of age. If we discover that a child has provided personal data, we will delete it promptly.

12. Changes to This Policy

We will notify you of material changes via email. The effective date is shown at the top of this policy.

13. Contact Information

For data protection inquiries, please contact us using the contact form.

Holmen Innovative Solutions AS
Contact Us

You have the right to lodge a complaint with a supervisory authority in your country of residence.