Raptor Services A/S
Privacy Policy
1. Privacy Policy at Raptor Services A/S
At Raptor Services A/S (“Raptor”, “we”, “us”, “our”), we are committed to protecting the personal data of our clients, suppliers, website visitors, applicants, and other individuals. This Privacy Policy outlines how we collect, use, store, and disclose personal data in accordance with the General Data Protection Regulation (GDPR) and the ePrivacy Directive.
We process personal data lawfully, fairly, and transparently, with respect for individual privacy and in line with applicable data protection regulations.
2. Data Controller
Raptor Services A/S is the data controller responsible for processing your personal data. We ensure that all processing is compliant with applicable data protection laws.
Contact Information:
Raptor Services A/S
VAT-ID: 35 05 59 75
Åboulevarden 37, 4th floor
DK – 8000 Aarhus C.
Compliance Officer:
Kirsten Düsterdich
E-mail: [email protected]
Phone: +45 2040 8020
3. Purpose and Legal Bases of processing
We process personal data for the following purposes:
|
Purpose of Processing |
Legal Basis (GDPR Article 6) |
|
To deliver requested products and services |
Art. 6(1)(b) – Performance of a contract |
|
To respond to inquiries or requests |
Art. 6(1)(f) – Legitimate interest, balanced against your privacy rights. |
|
To process and manage supplier and partner relationships |
Art. 6(1)(b) – Performance of a contract |
|
To improve our website, services, and user experience |
Art. 6(1)(f) – Legitimate interest, balanced against your privacy rights. |
|
To manage subscriptions to newsletters and marketing communications |
Art. 6(1)(a) – Consent |
|
To organize and promote events, including use of event images or recordings |
Art. 6(1)(a) – Consent |
|
To recruit candidates and evaluate applications |
Art. 6(1)(b) – Steps prior to entering a contract |
|
Art. 6(1)(a) – Consent (for extended retention) |
|
|
To comply with legal obligations (e.g., tax, accounting, AML regulations) |
Art. 6(1)(c) – Compliance with a legal obligation |
|
To secure IT systems and prevent misuse or fraud |
Art. 6(1)(f) – Legitimate interest, balanced against your privacy rights. |
4. Data Retention Periods and Types of Personal Data
Personal data is retained:
- As long as necessary to fulfill contractual obligations;
- For up to 5 years after a customer/supplier relationship ends, in compliance with bookkeeping and anti-money laundering legislation;
- Until you withdraw consent, for marketing or potential leads.
Overview of which personal data is used for which purposes and how long:
|
Types of Personal Data |
Purpose of Processing |
Legal Basis (GDPR) |
Retention Period |
|
Name, email, company name, phone number |
– Managing customer/supplier relationships |
Art. 6(1)(b) – Contract |
While the business relationship is active |
|
Job title, company affiliation |
– Processing contact/lead forms |
Art. 6(1)(b) – Contract |
While the business relationship is active or until request for deletion |
|
IP address, browser data (via cookies) |
– Website optimization |
Art. 6(1)(a) – Consent |
Until the data is anonymized or deleted by user request; dependent on cookie duration |
|
Login credentials (cookies) |
– Providing secure access to customer areas |
Art. 6(1)(f) – Legitimate interest |
Session-based or as per cookie consent settings |
|
Images, videos from events |
– Promoting events |
Art. 6(1)(a) – Consent |
Until consent is withdrawn or deemed no longer relevant |
|
Resume, cover letter, application details |
– Recruitment |
Art. 6(1)(b) – Contract Art. 6(1)(a) – Consent (extended storage) |
6 months (standard) Up to 12 months if consent is given |
|
Consent status, consent ID, timestamp |
– Demonstrating compliance with consent requirements |
Art. 6(1)(c) – Legal obligation |
Retained as long as necessary to demonstrate lawful processing |
|
Customer website usage data (as processor) |
– Delivering services to customers |
Art. 6(1)(b) – Contract (processor role) |
As specified in Data Processing Agreement (DPA) with customer |
|
Technical identifiers (e.g., CRM user IDs) |
– CRM tracking |
Art. 6(1)(f) – Legitimate interest |
While business relationship is active or upon deletion request |
|
Financial and transactional data |
– Invoicing and regulatory compliance (e.g., accounting, AML) |
Art. 6(1)(c) – Legal obligation |
5 years after the end of the customer/supplier relationship (per accounting/AML laws) |
5. Cookie Data in relation to visits on the website www.raptorservices.com
When visiting www.raptorservices.com, cookies are used. Cookies are small text files that are stored through your browser on your device, used by websites to make a user’s experience more efficient. The data is used to optimize the website in relation to the visitors’ needs.
The login to the customer area on the website requires cookies to remember your choices.
Selected employees at Raptor Services A/S have access to the collected data. The data is used for and disclosed in the form of statistics, etc., without specifying individual IP addresses. The purpose of processing statistics obtained from cookies is to provide a better website.
This site uses different types of cookies. Some cookies are placed by third party services that appear on our pages.
You can at any time change or withdraw your consent from the Cookie Declaration right here.
Please state your consent ID and date when you contact us regarding your consent.
If you want to learn more about what cookies we use, you can check out our cookie information.
6. Data Access and Disclosure
Access to personal data is restricted to employees and subcontractors who require it to perform specific tasks, based on the principle of least privilege. All third-party processors operate under legally binding Data Processing Agreements.
Our primary hosting and data storage provider is Microsoft, with additional services from:
- Adobe Creative Suite
- Arcade*
- Arrows.to*
- Asana
- Codetwo
- Contractbook*
- Cookiebot
- Copilot (Microsoft)*
- Crossbeam
- Demio
- E-conomic
- Meta (Facebook/Instagram) (note: shared data controllership)*
- Figma*
- Google Ads*
- Google Analytics*
- HubSpot*
- Klaviyo*
- LinkedIn*
- Loom*
- Medium*
- Microsoft Business Premium
- Notion*
- Plecto*
- SQL Server*
- Shopify*
- Slack*
- Sleeknote*
- Zapier*
Certain data transfers may occur to processors based in the United States, under mechanisms such as the Data Privacy Framework (DPF) and/or Standard Contractual Clauses or other lawful transfer tools compliant with Chapter V of the GDPR.
For a full list of data processors, contact our Compliance Officer.
* Note that these third-party processors offer AI services in their main services. We therefore refer to the Annex I to this Privacy Policy, “AI-Enabled Service Providers and Compliance Measures”.
7. Data Security
We maintain appropriate technical and organizational measures (TOMs) to protect personal data, including:
- Encryption (in transit and at rest)
- Role-based access controls
- Regular data backups
- Employee confidentiality protocols
In the event of a data breach likely to result in high risk to individuals, we will notify affected parties and supervisory authorities without undue delay, as required by GDPR Art. 33 and 34.
8. Your rights under the GDPR
You have the right to:
- Access your personal data (Art. 15)
- Rectify inaccurate data (Art. 16)
- Erase data (aka “right to be forgotten”, Art. 17)
- Restrict processing (Art. 18)
- Data portability (Art. 20)
- Object to processing (Art. 21)
- Withdraw consent at any time (Art. 7(3))
To exercise your rights, contact our Compliance Officer (see Section 2). We will respond within one month, or within two months for complex requests. Unfounded or excessive requests may be refused or subject to a fee.
Note that due to the nature of our services, some of the above-mentioned rights are either irrelevant or impossible. For those cases, we have relevant measures to ensure that your rights are respected to the greatest possible extent.
9. Complaints
You may send a complaint to the Danish Data Protection Authority (Datatilsynet):
Email: [email protected]
Website: www.datatilsynet.dk
Address: Carl Jacobsens Vej 35, 2500 Valby, Denmark
Phone: +45 33 19 32 00
10. Change of privacy policy
This Privacy Policy may be updated to reflect legal or operational changes. Significant changes will be communicated through our website or by email. The current version is always available at www.raptorservices.com/privacy-policy
Annex I
Annex I to Raptor Services’ Privacy Policy: AI-Enabled Service Providers and Compliance Measures
This annex provides detailed information regarding the AI-powered services used by Raptor Services A/S, including their functions, data handling practices, and the safeguards in place to ensure compliance with the General Data Protection Regulation (GDPR), ePrivacy Directive, and the EU Artificial Intelligence Act (AI Act).
- Overview of AI-Enabled Vendors
Note that those third-party vendors take the role of processors.
| Service Provider | Function | Type of AI | Categories of Data Processed | Legal Basis (GDPR Art. 6(1) | Location |
| Arcade | Interactive training tool – user data | Generative-product creation AI | PII (name, email, IP), usage data, screenshots, screen recordings | (a) Consent; (b) Contract; (f) Legitimate interests; (c) Legal obligation | USA (SCCs) |
| Arrows.to | Customer onboarding tool – typical personal data | NLP (workflow insights) | PII, employer/company info, user settings, usage metadata | (b) Contract; (f) Legitimate interests; (a) Consent (marketing) | EU/EEA |
| Contractbook AI Import | AI-assisted document import and classification of legal contracts | NLP, supervised learning | Contract metadata, party names, contract terms | (b) Contract; (f) Legitimate interests | Denmark/EU |
| Copilot (Microsoft) | AI-based assistant in Microsoft environment | NLP + Code generation (LLM, supervised) | Code, telemetry, usage data, possible PII from IDE logs | (a) Consent; (b) Contract; (f) Legitimate interests | Global (US/EU) |
| Facebook (META) | Advertising and remarketing | Predictive analytics + NLP | PII, sensitive interest data, social graph, images, video, text | (a) Consent; (f) Legitimate interests; (c) Legal obligation | Global (US/EU) |
| Figma | Design platform owned by Adobe – collaboration data | Generative AI (design suggestions) | Design content, uploaded assets, project metadata | (b) Contract; (f) Legitimate interests; (a) Consent | USA (SCCs) |
| Google Ads | Ad data, visitor data, lead tracking | Predictive analytics + Reinforcement learning | PII (IP, cookie IDs), browsing data, conversion metrics | (a) Consent; (f) Legitimate interests; (b) Contract | Global (US/EU) |
| Google Analytics | Visitor data, even if IP anonymisation is enabled | Predictive analytics | Anonymized PII (IP), behavior, device/browser details | (a) Consent; (f) Legitimate interests | Global (US/EU) |
| HubSpot Breeze AI | Marketing automation, email personalization, lead scoring | Predictive analytics / NLP | Name, email, behavior data, marketing interactions | (b) Contract; (f) Legitimate interests; (a) Consent | USA (SCCs) |
| Klaviyo | Email marketing – consents, leads, customer data | Predictive analytics + NLP (marketing) | PII, purchase history, interaction and email usage metrics | (a) Consent; (b) Contract; (f) Legitimate interests | USA (SCCs) |
| Advertising and lead forms | Predictive analytics + NLP | PII, profile info, interaction data | (a) Consent; (b) Contract; (f) Legitimate interests | USA (SCCs/DPF) | |
| Loom | Video recordings may include personal data | NLP (transcription) + Audio/Video AI | Screen recordings, voice/video, transcripts (PII) | (a) Consent; (b) Contract; (f) Legitimate interests | USA (SCCs) |
| Medium | Content platform, depends on usage | NLP (transcription) + Audio/Video AI | User profile, reading behavior, text metadata | (a) Consent; (f) Legitimate interests | USA (SCCs) |
| Notion | Work and knowledge platform – team data | NLP + Summarization + Semantic search | Notes (could include PII), usage data | (a) Consent; (b) Contract; (f) Legitimate interests | USA (SCCs) |
| Plecto | Danish dashboard platform – sales data, users | Predictive analytics | Performance data, metrics, user account info | (b) Contract; (f) Legitimate interests | Denmark (EU) |
| Shopify | Webshop and customer data | Predictive analytics (product suggestions, fraud detection) | Store data, customer PII, purchase data | (b) Contract; (f) Legitimate interests; (a) Consent | Canada/US (SCCs/DPF) |
| Slack | Communication platform – metadata, possible AI analysis | NLP (message summary, search, automation) | Messages (PII), attachments, usage logs | (b) Contract; (f) Legitimate interests | USA (SCCs/DPF) |
| Sleeknote | Pop-up on website | Predictive analytics | PII, device/browser data, behavior analytics | (a) Consent; (f) Legitimate interests | Denmark (EU) |
| SQL Server | Databases – local or cloud-hosted, depends on setup | ML platform (customizable; no native AI) | User-defined: potentially PII, business data | (b) Contract; (f) Legitimate interests | Onprem / Azure region (EU) |
| Zapier | Integrations – relay personal data between systems | NLP + Predictive (task automation) | PII, app data from user workflows | (a) Consent; (b) Contract; (f) Legitimate interests | USA (SCCs) |
- Risk Classification Under the EU AI Act
In line with the AI Act risk categorization:
|
Supplier / Tool |
AI Risk Level |
Justification |
|
Arcade |
Nohighrisk |
Generative demo creation for marketing. Does not fall in any Annex III highrisk domain (employment, credit, critical infrastructure, etc.). |
|
Arrows.to |
Nohighrisk |
Workflow/helpdesk assistance; does not make legally or economically significant decisions about individuals. |
|
Contractbook AI Import |
Nohighrisk |
Pure document parsing; supports lawyers but does not decide legal outcomes or access to justice. |
|
Copilot (Microsoft) |
Nohighrisk |
Codegeneration assistant; not used in any Annex III critical sector. |
|
Facebook Ads / META |
Nohighrisk |
General adtargeting is outside Annex III. (Politicalcampaign microtargeting could be highrisk/prohibited, but the core advertising AI is not automatically so.) |
|
Figma |
Nohighrisk |
Designassist AI; creative support only. |
|
Google Ads |
Nohighrisk |
Marketing optimisation—outside the AI Act’s listed highrisk areas. |
|
Google Analytics |
Nohighrisk |
Analytics/insights; does not autonomously decide on people’s rights. |
|
HubSpot Breeze AI |
Nohighrisk |
CRM/email drafting; no sensitive, highimpact decisionmaking. |
|
Klaviyo |
Nohighrisk |
Ecommerce marketing predictions; does not make highrisk decisions. |
|
LinkedIn (advertising and leads) |
No-highrisk |
AI is not used for filtering candidates and therefore doesn’t fall Annex III(4) “employment, worker management & access to selfemployment,”. |
|
Loom |
Nohighrisk |
Transcription & video summarisation; no decisionmaking impact. |
|
Medium |
Nohighrisk |
Content recommendation; limited effect on fundamental rights. |
|
Notion AI |
Nohighrisk |
Writing aid/summariser; not in a regulated highrisk domain. |
|
Plecto |
Nohighrisk |
Dashboards & KPIs; advisory analytics only. |
|
Shopify AI |
Nohighrisk |
Product suggestions & fraud rules; commerce, but not creditscoring or safetycritical. |
|
Slack AI |
Nohighrisk |
Message summarisation & search—auxiliary, no Annex III category. |
|
Sleeknote |
Nohighrisk |
Onsite engagement popups; marketing context only. |
|
SQL Server (platform) |
Nohighrisk |
Infrastructure; risk depends on user’s application, not the DBMS itself. |
|
Zapier AI |
Nohighrisk |
Workflow automation suggestions; no direct highrisk decision authority. |
- Data Protection and AI Governance Measures
The following controls have been implemented to ensure compliant use of AI services:
Transparency and Accountability
- AI involvement is clearly disclosed in relevant interactions (e.g., newsletters or auto-generated content).
- Human oversight is maintained over all automated outputs.
- Users can request explanations about automated processing and decisions.
Data Minimization and Purpose Limitation
- Only personal data necessary for the AI system’s defined purpose is processed.
- AI tools are restricted contractually from training on client data for generalized model improvement.
Data Processing Agreements and Safeguards
- Signed Data Processing Agreements (DPAs) with all relevant data processors.
- Data Privacy Framework or entered in EU Standard Contractual Clauses supported by Transfer Impact Assessments and supplemental security measures, if relevant, is the transfer tool for transfers to third countries.
- Internal DPIAs are conducted when AI use introduces higher risks to data subjects.
Security and Integrity
- AI models used by processors are secured against unauthorized access and model drift.
- Logging and audit trails are maintained to monitor AI decisions and system performance.
Feel free to contact us
Any Questions?
Call on phone: +45 20 40 80 20 or find alternative contact details below.