Privacy Policy

Effective Date: January 1, 2024
Last Updated: January 1, 2024

At FrejFund, we take your privacy seriously. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI-powered investment matching platform.

1. Information We Collect

1.1 Information You Provide

• Account Information: Name, email address, password
• Business Information: Company name, industry, stage, business model, revenue, team size
• Financial Information: Revenue metrics, burn rate, runway (optional)
• Documents: Pitch decks, business plans, financial statements you choose to upload
• Communication Data: Messages with our AI coach, feedback, support inquiries

1.2 Information We Collect Automatically

• Usage Data: How you interact with our platform, features used, time spent
• Device Information: Browser type, operating system, IP address
• Cookies and Tracking: Session cookies, analytics cookies (with consent)
• Log Data: Access times, pages viewed, errors encountered

2. How We Use Your Information

We use your information to:

• Provide AI-powered business analysis and investment readiness scoring
• Match you with relevant investors based on your profile
• Improve our matching algorithms and AI models
• Communicate with you about our services and updates
• Ensure platform security and prevent fraud
• Comply with legal obligations
• Analyze platform usage to improve our services

3. How We Share Your Information

3.1 With Your Consent

We share your business information with investors only when you explicitly approve a match or introduction. You control what information investors can see.

3.2 Service Providers

We work with trusted third-party services for:

• Cloud hosting (AWS/Google Cloud)
• Email delivery (SendGrid)
• Analytics (privacy-focused tools)
• Payment processing (Stripe)

3.3 Legal Requirements

We may disclose information if required by law, court order, or government request.

4. Data Security

We implement industry-standard security measures including:

• Encryption of data in transit and at rest
• Regular security audits and penetration testing
• Access controls and authentication
• Secure data centers with 24/7 monitoring
• Employee training on data protection

5. Your Rights (GDPR Compliance)

Under GDPR and other privacy laws, you have the right to:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your data ("right to be forgotten")
• Portability: Receive your data in a machine-readable format
• Object: Opt-out of certain data processing
• Restrict: Limit how we process your data

6. Data Retention

We retain your data for as long as necessary to provide our services and comply with legal obligations:

• Active account data: Retained while account is active
• Deleted account data: Removed within 90 days
• Analytics data: Anonymized after 24 months
• Legal/tax records: Retained as required by law

7. International Data Transfers

Your data may be transferred to and processed in countries outside the European Economic Area (EEA). We ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission.

8. Children's Privacy

FrejFund is not intended for users under 18 years of age. We do not knowingly collect personal information from children.

9. AI and Machine Learning

We use AI to analyze your business and provide insights. Here's how:

• We process your inputs (including uploaded documents and scraped public data) via third-party AI providers (e.g., OpenAI) to generate assessments.
• We log token usage and estimated AI costs for transparency and abuse prevention.
• Analysis results are stored with your profile. You can request deletion or correction at any time.
• We do not use your private data to train public models. Provider-side policies may apply.
• You can request human review of AI-generated conclusions or actions.

10. Cookies Policy

We use cookies to:

• Essential cookies: Required for platform functionality
• Analytics cookies: Help us understand usage (with consent via cookie banner)
• Preference cookies: Remember your settings

You can manage cookie preferences via our cookie banner and/or in your browser settings.

11. Data Storage and Locations

Uploaded files are stored in cloud object storage (e.g., AWS S3) in regions configured by us. We process data in the EU and/or US depending on service provider. We use encryption in transit and at rest where available. For detailed processing locations and subprocessors, see our Data Processing Addendum (DPA).

12. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of significant changes via email or platform notification. Continued use after changes constitutes acceptance.

13. Contact Us

For privacy-related questions or to exercise your rights:

Data Protection Officer
FrejFund
Email: privacy@frejfund.com
Address: Stockholm, Sweden

Response time: Within 30 days of request

14. Supervisory Authority

If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority. In Sweden, this is the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten).