Terms for PinToMind

Content on this page

Summary
Terms of Service
Privacy Statement
Data Processing Agreement (DPA) for personal data in your uploaded Content

Summary

We, Favo AS (hereinafter referred to as “Favo”), run the web service PinToMind, which is a subscription service for displaying and managing content on digital screens.

Infoskjermen and PinToMind are two names for the same solution, which are used in Norway and the rest of the world, respectively. In this Agreement, PinToMind covers both names. If you prefer Norwegian, you may read the Norwegian version on the Infoskjermen website.

We hope you like and wish to use our solution. However, we ask you to be responsible in what you publish. In particular, make sure that you have obtained all necessary consents and permissions, and that none of the prohibited content listed below is shown or linked from your account.

Should you discover any PinToMind content that you believe violates our Terms of Service, we ask that you notify us by e-mail to support@pintomind.com.

Terms of Service

The following terms and conditions govern all use of PinToMind as well as all content, appurtenant products and services available at or through the website (the “Service”).

The Service is owned and operated by Favo. The Service is offered subject to your approval and acceptance, without reservations, of all the terms and conditions, as well as all other operating rules, laws, policies (including, without limitation, Favo’s Privacy Statement) and procedures that may be published from time to time on this website (collectively, the “Agreement”).

Please read the Agreement carefully before using the Service. By using any part of the Service, you agree to become bound by the terms and conditions of this Agreement. If you do not agree to all the terms and conditions of this Agreement, then you may not access the Service. These terms and conditions shall be considered an offer by Favo, and acceptance is expressly limited to these terms. The Service is available only to individuals who are at least 13 years old, and by accepting the Agreement, you vouch for being 13 years or older.

1. Your PinToMind account

You are responsible for maintaining the security of all the Content on your account. You are fully responsible for all activities that occur on your account. Favo will not be liable for any acts or omissions on your part, including, but not limited to, any damages of any kind incurred as a result of such acts or omissions.

2. Responsibility of contributors and users

If you operate an account, publish on the screens, or otherwise make, or allow a third party to make, material available by means of the Service (any such material, “Content”), you are entirely responsible for the Content of, and any damages and financial loss resulting from the Content, including, but not limited to, obtaining all necessary consents and permissions to process, publish and store the Content. This applies regardless of whether the Content in question is in the form of text, graphics, video, an audio file, or other content.

By making Content available, you warrant that:

Downloading, copying and using the Content will not infringe on any third parties’ intellectual property rights, including but not limited to, copyright, patent, trademark and/or trade secrets.
If your employer holds rights to the Content you use, you have either (i) received permission from your employer to post or make the Content available, including, but not limited to, any software, or (ii) secured from your employer a waiver pertaining to all rights in or to the Content.
You have complied with any third-party licenses relating to the Content, and have done all things necessary to successfully convey any required terms to end users.
The Content does not contain or install any viruses or other harmful and/or destructive Content.
The Content is neither spam, nor machine- or randomly generated, and does not contain unethical or unwanted commercial Content designed to drive traffic to third-party sites or boost the search engine rankings of third-party sites, or to further unlawful acts (such as phishing) or mislead recipients as to the source of the material (such as spoofing).
The Content is not pornographic, does not contain threats or incite violence, and does not violate the privacy or rights of any third party.
Your PinToMind account is not advertised via unwanted electronic messages such as spam, links on news groups, e-mail lists, blogs and websites, and similar unsolicited promotional methods.
The Content is not such that misleads your viewers into thinking that you are another person or company. For example, your account’s, screens’ and user’s URL or name is not the name of a person other than yourself or a company other than your own.
In cases where Content includes computer code, you will upon Favo’s request provide Favo with accurate categorizations and descriptions of the type, nature, uses and effects of such Content.

By submitting Content to Favo for inclusion on your PinToMind account, you grant Favo license to reproduce, modify, adapt and publish Content in accordance with this Agreement solely for the purpose of displaying and distributing it on PinToMind.

Without limiting any of the above representations or warranties, Favo has the right (though not the obligation) to, at Favos’ sole discretion (i) refuse or remove any Content that, in Favo’s reasonable opinion, violates any of Favo’s policies or is in any way harmful or objectionable, or (ii) terminate or deny access to, and use of, the Service to any individual or entity for the same reasons. Favo will have no obligation to refund any amounts previously paid to Favo and disclaims all liabilities for loss incurred in such cases.

In the event that the Content should include personal data in accordance with Norwegian data protection law, including EU regulation no. 2016/679 (GDPR) as incorporated under Norwegian law, Favo will process such personal data as a data processor on behalf of its customer as data controller. All processing of personal data included in the Content, is subject to the Data Processing Agreement.

3. Payment and renewal

General terms

You agree to pay Favo the monthly or annual fees indicated for the Service. Payments will be charged in advance on the day you sign up and will cover the use of this Service for a monthly or annual subscription period, as indicated. Fees are non-refundable.

Automatic renewal

Unless you notify Favo before expiry of the current invoice period that you wish to cancel your subscription, it will be automatically renewed. You then authorize us to collect the applicable annual or monthly subscription fee (as well as any taxes) using any credit card or other payment method we have on record for you.

In cases where the customer over time uses more than the subscription for which they pay, Favo is free to upgrade the account while informing the customer of this.

Cancellation and termination

Cancelling your PinToMind account requires that you click on the link marked “End account”. An e-mail or phone call to us is not considered an official cancellation.

Resale

Resale of administration of screens and functionality from accounts is not allowed. This applies for example in cases where a reseller has an account and sells access to screens to several smaller customers. All customers must have their own account, it is not allowed to collect several customers in one large reseller account or similar.

4. Responsibility for visitors and users

Favo has not reviewed, and cannot review, the material, including computer software, posted on all PinToMind accounts, and therefore cannot be responsible for the material’s Content, use or effects. You accept that by operating the Service, Favo has not controlled and does not endorse the posted material, nor believes such material to be accurate, useful, or harmless.

You are responsible for taking the necessary precautions to protect yourself and your computer systems from viruses and other harmful or destructive Content. The PinToMind account may, without the knowledge of Favo, contain Content that is in some way offensive or indecent, as well as Content containing technical inaccuracies, spelling errors, and other errors. The account may also contain material that violates personal privacy or freedom of speech, or infringes on the intellectual property and other proprietary rights of third parties, or the downloading, copying or use of said material is subject to additional terms and conditions, stated or implied. Favo disclaims any responsibility for any harm resulting from the use by visitors and users of PinToMind screens.

5. Content posted on other websites

We have not reviewed, and cannot review, any material, including computer software, made available through websites and webpages to which PinToMind links, and that link to PinToMind. Favo has no control over other websites and webpages than the PinToMind website and is not responsible for their Content or their use. You accept that when you link to a third-party website through PinToMind, Favo does not endorse or support such other websites. You are responsible for taking the necessary precautions to protect yourself and your computer systems from viruses and other harmful or destructive Content. Favo disclaims any liability for any harm resulting from your use of non-PinToMind websites and webpages.

6. Breach of intellectual property rights

As Favo asks others to respect its intellectual property rights, it also respects the intellectual property rights of others. If you believe that material located on or linked to by PinToMind violates your copyrights, we encourage you to notify Favo by e-mail to support@pintomind.com. Such notices will be handled in a manner Favo deems appropriate. This may include removing the infringing material or disabling all links to the infringing material. Favo will be able to terminate a user’s access to and use of the Service if there is reason to believe that it infringes any copyrights or other intellectual property rights of Favo or others, but Favo disclaims all liability if such termination is not carried out. In case of such termination, Favo will have no obligation to provide a refund of any amounts previously paid to Favo.

7. Intellectual property rights

This Agreement does not transfer from Favo to you, any intellectual property rights belonging to Favo or a third party. Such rights are owned and will remain solely with Favo. Favo, the Favo logo, Infoskjermen.no, the Infoskjermen.no logo, PinToMind.com, the PinToMind logo, and all other trademarks, service marks, graphics and logos used in connection with the Service are trademarks or registered trademarks of Favo or Favo’s licensors. Other trademarks, service marks, graphics or logos used in connection with the Service may be the trademarks of other third parties. Your use of the Service grants you no right or license to reproduce or otherwise use any of Favo’s or third parties’ trademarks.

8. Advertisements

Favo reserves the right to display the company’s own logo and attribution as “Delivered by PinToMind” on screens and displays unless you have purchased a subscription where this is exempt.

9. Attribution

Favo reserves the right to display attribution links and font attribution on screens and displays, to the extent necessary to credit third party content providers.

10. Changes

Favo reserves the right, at its sole discretion, to modify or replace any part of this Agreement. Significant changes will be notified. You are responsible for staying up to date on changes to this Agreement. Your continued use of or access to the Service following notification of any changes to this Agreement shall constitute acceptance of those changes. Favo may also in the future, offer new services and/or features through the Service including the release of new tools and resources). Such new features and/or services shall be subject to the terms and conditions of this Agreement.

11. Termination

In case of any breach of the terms of this Agreement, Favo may, with immediate effect, with or without notification, cancel all or any part of the Service, including terminating the user’s account.

If you wish to terminate this Agreement or your PinToMind account (if you have one), you simply click “End account” under settings. All provisions of this Agreement which by their nature should survive termination, shall survive termination of the Agreement, including, but not limited to, ownership provisions, warranty disclaimers, indemnity and limitations of liability.

12. Disclaimer of warranties

The Service Is provided on an “as is” basis. Favo, its suppliers and licensors hereby disclaim all warranties of any kind, express or implied, with regards to quality, merchantability, or attainment of a specific purpose. Neither Favo nor its suppliers and licensors make any warranties for the Service being error free, or that access to the Service will be continuous or uninterrupted. You understand that you download from, or otherwise obtain Content through the Service at your own discretion and risk.

13. Limitation of liability

You accept that Favo, its suppliers or licensors shall in no event be liable for: (i) any indirect loss, including, but not limited to, incidental or consequential loss or damages; (ii) cost for procurement of substitute products or services; (iii) any cost incurred due to loss or corruption of data, and (iv) that the liability of Favo, its suppliers and licensors for direct loss is upwards limited to an amount equivalent to your fees paid to Favo under this Agreement during a period of twelve (12) months immediately preceding such claim. Favo shall have no liability for any failure or delay due to matters beyond our reasonable control. The foregoing shall not apply to the extent where otherwise is required by law.

14. User warranty

You represent and warrant that (i) your use of the Service will be in accordance with Favo’s Privacy Statement, with this Agreement and with all applicable laws and regulations (including, without limitation, any local laws and regulations in your country, state, municipality etc. regarding conduct and acceptable Content, and all applicable laws regarding the transmission and export of technical data exported from the United States, the EU or the country in which you reside) and (ii) your use of the Service will not infringe or misappropriate any third-party intellectual property rights.

15. Indemnification

You agree to defend, indemnify and hold Favo, its suppliers and licensors, harmless from and against all claims and expenses, including attorney’s fees, arising out of your use of the Service, including, but not limited to, violation of this Agreement.

16. Miscellaneous

This Agreement constitutes the entire agreement between you and Favo governing the subject matter hereof. Any access to or use of the Service shall be governed by the laws of Norway excluding its conflict of law provisions, and the exclusive legal venue for any disputes arising out of or relating to the Agreement shall be the courts of Haugesund, Norway. If any part of this Agreement is held invalid or unenforceable, that part will be interpreted to reflect the parties’ original intent, and the remaining parts shall remain in full force and effect. A waiver by either party of any term or condition in this Agreement or any breach thereof, will in no case entail a release of the term in question or any following breach of said term. You may assign your rights under this Agreement to any party that consents and agrees to be bound by its terms; Favo may assign its rights under this Agreement without condition.

Privacy Statement

Your privacy is important to us. At Favo, we have a few fundamental principles:

We do not ask you for personal information unless we truly need it.
We do not share your personal information except to comply with the law, deliver the service, develop our products, or protect our rights.
We do not store personal information on our servers unless required for the ongoing operation of one of our services.
In our products and services, we aim to make it as simple as possible for you to control what is visible to the public, kept private, and permanently deleted.
All our processing shall be in accordance with Norwegian law, including EU regulation 2016/679 (GDPR).

Below is our privacy policy for achieving these goals. Favo operates several websites, including favo.no, pintomind.com, inforskjemen.no, and we are the data controller of the information we collect about you as described in this policy.

However, for any personal data included in the Content you upload through our services, you will be considered the data controller, and Favo will process such personal data on your behalf as data processor, in line with the Data Processing Agreement and the Agreement.

It is Favo’s intention to respect your privacy regarding all information we may collect while operating our services. If you have questions about deleting or correcting your personal data, please send an e-mail to support@pintomind.com.

The basis for our processing of personal data regarding users of our services is primarily that it is necessary for entering into contract with the business which you are part of, and you as a user of our services, cf. GDPR article 6 no. 1 (b).

In addition, some of our processing is based on your consent as described below, cf. GDPR article 6 no. 1 (a). You may at any time withdraw your consent as described below or on our web service.

1. Personal data collected through our Web service

Like most website operators, Favo collects non-personally identifying information of the sort that web browsers and servers typically make available, such as browser type, language settings, referring website, and the date and time of each visitor request. Favo’s purpose in collecting non-personally identifying information is to better understand how Favo’s visitors or users use its website. From time to time, Favo may release a collection of non-personally identifying information, e.g. by publishing a report on trends in the usage of the website.

Favo also collects personally identifying information like Internet Protocol (IP) addresses for logged-in users of PinToMind accounts. User addresses will be visible to account administrators.

2. Collection of personally identifying information upon registration

Certain visitors to Favo’s websites choose to interact with Favo in ways that require Favo to collect personally identifying information. The amount and type of information that Favo collects depends on the nature of the interaction. For example, we ask visitors who sign up for an account at PinToMind to provide a username and e-mail address. Those who engage in transactions with Favo, for example by setting up an account, are asked to provide certain additional information, including as necessary, the personal and financial information required to process such transactions. In each case, Favo collects such information only to the extent necessary or appropriate to fulfill the purpose of the user’s interaction with Favo. Favo does not disclose personally identifying information other than as described below.

If you register an account on our websites on behalf of your business, we will collect data on you as a contact person for that business, such as name, e-mail, preferred language, and the country from which you operate.

If you register an account on our websites as an individual user, we may collect data about you such as your name, e-mail, time of registration, change of information, access and receipt of system warnings, preferred language and time zone in the service, settings for applications provided by us, whether the user receives e-mail from us, accounts and role in the different accounts in our service, what posts the user has made and is responsible for, accounts/other users that the user has enlisted, if any, and tokens on any posts that require authentication from third parties, such as Instagram.

For accounts using credit cards, we use the Stripe service. Their terms can be found here: stripe.com/legal. If you use our Go service, we store the information that is made available from a mobile or a tablet when you download the applications, such as identification for the device, name and version on the device, language for use of the services and what screens the user is subscribing for.

3. Newsletter

If you are a registered user of a PinToMind account and have supplied your e-mail address, Favo may occasionally send you an e-mail to inform you of new features, solicit your feedback, or just keep you up to date with what is going on with Favo and our products. We primarily use our various products, webpages and blogs to communicate this type of information, so we expect to keep this type of e-mails to a minimum. By accepting this policy, you consent to this use of your personal data, and you may withdraw that consent by opting out of our newsletter through our opt-out solution on the e-mails we send.

4. Use of your requests and feedback to us

If you send us a request (for example via a support e-mail or via one of our feedback mechanisms), we reserve the right to publish the Content (in anonymized form) in order to help us clarify or respond to your request or to help us support other users. We will not publish such Content that includes your personal data unless you have explicitly consented to this.

5. Aggregated statistics

Favo may collect statistics about the behavior of users of and visitors to its websites. Favo may display this information publicly or provide it to others. However, Favo does not disclose personally identifying information other than as described in this Agreement.

6. Transfer to third parties

Favo only provides personal data to suppliers and collaborating partners who (i) need the information in order to process it on Favo’s behalf, or to provide services available at Favo’s websites, and (ii) that have agreed or are obliged to not disclose it to others, such as public bodies, lawyers and auditors.

Some of Favo’s collaborating partners and suppliers may be located outside of your home country, and by using Favo’s services you consent to the transfer of such information to them. We may also transfer personal data outside the EU/EEA as part of our hosting service. When transferring personal data to a country outside the EU/EEA, we do so only on approved basis for transfer, such as EU’s approved standard clauses (SCC), in addition to any further security measures necessary for ensuring a level of security equivalent to the level of the EU/EEA.

Favo will not rent or sell your personal data to anyone. Other than to its suppliers and collaborating partners as described above, Favo provides access to personal data only in response to a subpoena, court order or other governmental requests, or when Favo believes in good faith that disclosure is reasonably necessary to protect the property or rights of Favo, third parties or the public at large. Favo takes all measures necessary to protect against unauthorized access, use, alteration or destruction of potentially personally identifying and personally identifying information.

7. Regulation of personal data in Content that you can upload through the use of our services

Our services enable users to publish and upload Content. Such Content may include personal data, depending on what Content the user uploads. For this data, the user or the user’s business will be the data controller under the relevant data protection law in relation to Favo, and Favo will only process such data on your behalf as a data processor. Separate data processing terms govern such processing of personal data, and such processing of personal data is not covered by this policy.

8. Ads

Ads appearing on any of our websites may be delivered to users by advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This privacy statement covers the use of cookies by Favo and does not cover the use of cookies by any advertisers.

9. Third party links

Favo may include or offer third-party service products on our site. These third-party sites and services have independent privacy policies. We therefore have no responsibility or liability for the Content and activities on these sites. Nonetheless, we seek to protect the integrity of our services and welcome any feedback about these sites.

10. Storing and deletion of personal data

We only store your personal information as long as it is necessary to provide our services to you or the business to which you are connected, or as long as it is necessary to fulfill our legal obligations. Thereafter, we will delete your data.

For example, we delete all your Content when an account is deleted, while information on the contact person for the account and invoicing material is stored for 5 years for us to be able to handle future requests and comply with applicable legislation. When a user is removed from an account, the user information is deleted. For security reasons we regularly make backups.

11. Your rights

As an individual user of our services, you are entitled, upon request, to disclosure regarding your personal data that we are storing or are otherwise processing. You are also entitled to have any incorrect personal data corrected and the right to block or delete any of your personal data. Under certain conditions, you have the right to object to processing of your personal data, and may, according to the terms of the EU Regulation 2016/679 (GDPR), ask to receive your personal data in a structured and commonly used format so that it can easily be transferred to you or another data processor you appoint (this is known as “data portability”).

If you have any complaints regarding the processing of your personal data, we encourage you to contact us. Please address any requests in such matters as described above in this privacy statement. We also inform you that you are entitled by law to file a complaint with the Norwegian Data Protection Authority.

12. Privacy policy changes

Although most changes are likely to be minor, Favo may change its privacy policy from time to time at Favo’s sole discretion, and will make notice of such changes 2 weeks in advance. Favo encourages visitors to frequently check this page for any changes to its privacy policy. If you have a PinToMind-account, you should also check your dashboard for alerts regarding these changes. Your continued use of this site after any change in the privacy policy will constitute your acceptance of such change.

13. Your consent

By using our sites, and all related services, you consent to our terms of service and privacy policy. Any changes to these terms of service and privacy policy will be announced with two weeks’ notice.

14. Contact information

Any enquiries regarding this Privacy Statement can be directed to Favo’s data protection officer on e-mail to support@pintomind.com.

Data processing agreement (DPA) for personal data in your uploaded Content

1. Background and purpose

This personal data processing agreement (“Data Processing Agreement”) regulates the processing of personal data included in Content uploaded by Favo’s customers while using the PinToMind web service. All words and expressions used herein shall have the same meaning as defined in the Terms of Service.

The purpose of the Data Processing Agreement is to regulate rights and obligations under the Act of 15 June 2018 no. 38 relating to the processing of personal data, and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).

When you as a customer of Favo upload Content that includes personal data, you will be considered the data controller for such personal data under the relevant data protection law, and you or the company you sign up for are therefore referred to as the “Data Controller” in the following.

In so far as Content includes personal data, i) Favo will be data processor of such data; (ii) the Data Controller will comply with its obligations as a data controller under the relevant data protection legislation; and iii) Favo will comply with its obligations as a processor under these terms. The Data Processing Agreement only applies as far as Favo actually processes personal data as part of the Content. Other data Included in the Content that Favo may process is not regulated by these terms.

Favo will only process the type of personal data that a Data Controller provides to Favo via the PinToMind web service, and regarding the types of individuals that the Data Controller provides to Favo.

The Data Controller shall ensure that there is adequate basis for processing the personal data, including obtaining consent from the data subject to the extent required by applicable privacy regulations.

2. Favo’s general obligations

Favo shall only process personal data it may access as part of fulfilling its contractual obligations to the Data Controller. Favo has no right to hand over personal data to unauthorized third parties.

Favo shall follow the procedures and instructions for the processing of personal data that the Data Controller has laid out, and to the extent necessary to comply with applicable law. This includes but is not limited to instructions provided by the Data Controller as part of operating the PinToMind service.

The Data Controller shall only provide Favo with instructions that are in accordance with current applicable law. Favo is obliged to inform the Data Controller if Favo believes that a given instruction is not in accordance with applicable law. Favo will in accordance with GDPR article 28 (h) make available to the Data Controller all information necessary to demonstrate compliance with the obligations laid down in said article and allow for and contribute to audits, including inspections, conducted by the Data Controller or another auditor mandated by the Data Controller.

Upon a Data Controller’s request, Favo is obliged to provide necessary assistance for the Data Controller to access the data processed on behalf of the Data Controller.

Favo has a duty of confidentiality regarding personal data that it has access to in accordance with the Data Processing Agreement. This also applies after the Agreement with the Data Controller is terminated. Favo shall ensure that persons authorized to process personal data on behalf of Favo are subject to confidentiality by law or contract.

Favo shall, considering the nature of the processing, as far as possible and with appropriate technical and organizational means, assist the Data Controller in answering the data subject’s requests for fulfillment of the data subject’s rights under the applicable data protection law.

Favo shall, to the extent to which it is relevant to the contractual relationship, considering which personal data is available to it and the nature of the processing, assist the Data Controller in complying with the information security requirements, requirements for notifications to the Norwegian Data Protection Authority and the data subjects, as well as impact assessments, pursuant to Articles 32-36 of the GDPR.

Favo will comply with the requirements for security measures under the Personal Data Act and the Personal Data Regulation, including particularly the Personal Data Act Section 13-15 with regulations, as well as Article 32 of the GDPR.

Any assistance from Favo required by a Data Controller under this Section 2, or corresponding legislation regarding personal data, shall be compensated according to the applicable hourly rates agreed between the parties, or, if no hourly rates are agreed upon, by the current regular and reasonable fees for such services.

3. Location of personal data

Favo is based in Norway and will mainly access your data in Norway from our regular place of business. Favo uses sub-processors located outside of Norway and the EU/EEA, listed in the next section.

The Content may be made available for our employees in countries outside the EU/EEA, and temporarily stored in a country where employees, sub-processors or their agents are located or have facilities, including in countries outside the EU/EEA.

If personal data is transferred outside the EU/EEA, we only do so based on approved basis for transfer, such as EU’s approved standard clauses (SCC), in addition to any further security measures necessary for ensuring a level of security equivalent to the level of the EU/EEA.

4. Use of sub-processors

Favo uses the following sub-contractors and data processors (“Sub-processors”) for processing your Content:

Brightbox Systems Ltd (“Brightbox”), where we store our servers and databases. Most of the contents of the solution are stored here; such as information regarding accounts, screens, displays, users, screen contents, as well as images uploaded by users. External content, such as calendar data, is stored temporarily and processed for screen displays. Data is processed and stored in the United Kingdom. The United Kingdom is subject to the Commission’s adequacy decision of 28 June 2021, which ensures an equivalent level of protection to that guaranteed in the EU/EEA. Favo has a data processing agreement with Brightbox through the standard terms.
PowerOffice AS (“PowerOffice”), which we use for invoicing and accounting. Here we store company information, invoice information and any information regarding the customer’s contact person(s). This service is not used for customers who opt for card payments. Data is processed and stored in Europe. Favo has a data processing agreement with PowerOffice through the standard terms, as well as a separate privacy and security agreement.
Stripe, Inc. (“Stripe”), which we use for card payments. Information on cards, card holders, invoicing and transactions is stored here. The service is only used for customers who choose card payments. Stripe is an American company, and data is processed and stored in the US. Favo has entered into a data processing agreement with Stripe and ensured adequate basis for the data transfer (SCC). Stripe has provided documentation showing implementation of several organizational and technical security measures, including encryption and appendices which explicitly address the American intelligence legislation. Stripe writes that it is highly unlikely that they will be instructed by the American government to reveal information. If the Data Controller does not wish to approve Stripe as a sub-processor, this may be solved by not opting for card payments.
Peaberry Software, Inc. (“Customer.io”), which we use for distribution of information and newsletters by e-mail. Here we store users’ contact information, language and which roles they have in the solution. Customer.io is an American company which processes and stores data in Europe. Favo has entered into a data processing agreement with Customer.io and ensured adequate basis for the data transfer (SCC). The personal data processed by Customer.io is limited to contact information and account information and is therefore not very sensitive. In addition, Customer.io has implemented a number of security measures, including encryption.
Sveve AS (“Sveve”), which we use to send SMS with a code for two-factor authentication, for users who have activated this. Mobile number and current message are transferred to Sveve. Data is processed and stored in Europe. Favo has a data processing agreement with Sveve.
Microsoft Ireland Operations, Ltd. (“Microsoft Azure”), which we use for storage of images, videos, display backgrounds, logos etc. This is primarily data which does not include any personal information. Microsoft Azure is an American company with a subsidiary in Ireland and server location in Norway. Favo has entered into a data processing agreement with Microsoft Azure and ensured adequate basis for the data transfer (SCC). The data processing agreement states that Microsoft Azure may inn certain cases process data outside the EU. Based on the nature of the processed information and the implemented security measures, we view the risk of any significant privacy protection consequences resulting from sporadic data processing in the US to be extremely low.
AppSignal B.V. (“AppSignal”), which we use for performance and error analysis. Data which is described as stored and processed by other services, will be logged and analysed by AppSignal. Favo has entered into a data processing agreement with AppSignal. Data is stored and processed in Europe.

Favo shall only use Sub-processors for processing personal data that are authorized by the Data Controller. The Data Controller hereby authorizes appointment of the above-mentioned Sub-processors, the terms of use or the privacy statement, and accepts that Favo may change its Sub-processors at its own discretion. The Data Controller shall be notified of such changes of Sub-processors through e-mail and the updating of these terms. The Data Controller may object to such appointment by written notice to Favo, and Favo may in such case choose to terminate the Data Processing Agreement upon written notice to the Data Controller if the Data Controller does not accept the new Sub-processor.

Anyone who, on behalf of Favo, carries out assignments in which the personal data in question is processed, shall be subject to the same obligations to Favo, pursuant to this Data Processing Agreement.

5. Data correction and deletion

Through the services Favo delivers, the Data Controller will be provided with the ability to correct, block, export and delete Content in a manner consistent with the functionality of the PinToMind web service and the Agreement.

During the Term, Favo will make available to the Data Controller the Content in a manner consistent with the functionality of the PinToMind web service and in accordance with this Data Processing Agreement. To the extent the Data Controller, in its use and administration of the PinToMind web service does not have the ability to amend or delete Content (as required by applicable law), or migrate Content to another system or service provider, Favo will, at the Data Controller’s reasonable expense, comply with any reasonable requests from the Data Controller to assist in facilitating such actions to the extent Favo is legally permitted to do so and has reasonable access to the relevant Content. Content that is deleted by the Data Controller shall be deleted by Favo within reasonable time, and no later than 2 months.

6. Term

This Data Processing Agreement applies between the parties as long as Favo processes personal data as a data processor on behalf of the Data Controller.

In case of breach of this Data Processing Agreement or the Personal Data Act, the Data Controller may request that Favo stop further processing of the data with immediate effect.

7. Termination

Upon termination of the Data Processing Agreement, Favo shall upon instruction from the Data Controller delete or properly destroy all documents, data, floppy disks, CDs, etc. containing personal data covered by this Data Processing Agreement as laid out in section 6 above.

The above applies only if nothing else follows from an explicit agreement between the parties or applicable law, such as an obligation to store data for specific purposes.

8. Breach of contract

Upon breach of this Data Processing Agreement, the regulation on indemnification, liability and limitation of liability in the Agreement shall apply.

9. Contact information

Any communication regarding this Data Processing Agreement can be directed at Favo’s data protection officer by e-mail to support@pintomind.com.

If you’re a customer and would like to sign our DPA, you can download it here, sign it, and send it back to Favo via e-mail to support@pintomind.com.

Last updated May 7, 2024.