SetLinn Privacy Policy
1. Introduction
Welcome to SetLinn. This Privacy Policy describes our approach and commitment to protecting your personal data when you visit or use the SetLinn website, applications and related services.
SetLinn provides features that enable users to discover information, participate in communities, connect with Service Providers, book services and access information and recommendations through the platform.
Some parts of SetLinn may be used without providing personal data. However, certain features, such as account registration, service bookings, payments and third-party integrations, require us to process personal data to provide the requested services.
Personal data is processed in accordance with applicable data protection laws, including Regulation (EU) 2016/679, the General Data Protection Regulation (GDPR), where applicable.
We take reasonable technical and organizational measures to protect personal data and to ensure that our employees and external service providers handle it in accordance with applicable legal requirements. Internet-based services may be susceptible to security vulnerabilities, and absolute protection cannot be guaranteed. We take reasonable steps to address security issues when they become known.
If you have questions about how your personal data is processed, you may contact us using the contact details provided in this policy.
2. Definitions
For the purposes of this Privacy Policy, the following terms have the meanings assigned to them under the GDPR and applicable data protection laws.
- Personal Data: Any information relating to an identified or identifiable natural person. An identifiable person is someone who can be identified directly or indirectly, for example through a name, identification number, location data, online identifier or other information relating to their identity.
- Processing: Any operation performed on personal data, whether by automated means or otherwise, including collection, recording, organization, storage, adaptation, retrieval, use, disclosure, transmission, restriction, erasure or destruction.
- Restriction of Processing: The marking of stored personal data with the aim of limiting its processing in the future.
- Profiling: Any form of automated processing of personal data used to evaluate personal aspects of an individual, including interests, preferences, behavior, location or other relevant characteristics.
- Pseudonymization: The processing of personal data in such a way that it can no longer be attributed to a specific person without additional information, provided that the additional information is kept separately and protected by appropriate technical and organizational measures.
- Controller: The natural or legal person, public authority, agency or other body that determines the purposes and means of processing personal data.
- Processor: A natural or legal person, public authority, agency or other body that processes personal data on behalf of a controller.
- Data Subject: The individual whose personal data is being processed.
- Third Party: A person or organization other than the data subject, controller, processor or persons authorized to process personal data under the direct authority of the controller or processor.
- Consent: A freely given, specific, informed and unambiguous indication of an individual's wishes by which they agree, through a statement or clear affirmative action, to the processing of their personal data.
- Service Provider: A user or business offering services through SetLinn.
- Google Calendar Integration: The optional connection between SetLinn and a user's Google account for calendar and meeting-related functionality.
2. Definitions
For the purposes of this Privacy Policy, the following terms have the meanings assigned to them under the GDPR and applicable data protection laws.
- Personal Data: Any information relating to an identified or identifiable natural person. An identifiable person is someone who can be identified directly or indirectly, for example through a name, identification number, location data, online identifier or other information relating to their identity.
- Processing: Any operation performed on personal data, whether by automated means or otherwise, including collection, recording, organization, storage, adaptation, retrieval, use, disclosure, transmission, restriction, erasure or destruction.
- Restriction of Processing: The marking of stored personal data with the aim of limiting its processing in the future.
- Profiling: Any form of automated processing of personal data used to evaluate personal aspects of an individual, including interests, preferences, behavior, location or other relevant characteristics.
- Pseudonymization: The processing of personal data in such a way that it can no longer be attributed to a specific person without additional information, provided that the additional information is kept separately and protected by appropriate technical and organizational measures.
- Controller: The natural or legal person, public authority, agency or other body that determines the purposes and means of processing personal data.
- Processor: A natural or legal person, public authority, agency or other body that processes personal data on behalf of a controller.
- Data Subject: The individual whose personal data is being processed.
- Third Party: A person or organization other than the data subject, controller, processor or persons authorized to process personal data under the direct authority of the controller or processor.
- Consent: A freely given, specific, informed and unambiguous indication of an individual's wishes by which they agree, through a statement or clear affirmative action, to the processing of their personal data.
- Service Provider: A user or business offering services through SetLinn.
3. Name and Address of the Data Controller
The company responsible for the operation of SetLinn and the processing of personal data through the platform is:
OJIRA Soft UG (haftungsbeschränkt)
Belßstr. 78B
12249 Berlin, Germany
Registered with: Amtsgericht Berlin-Charlottenburg
Registration Number: HRB 226144 B
VAT Identification Number: DE 341838128
Email: info@ojirasoft.com
Phone: +49 162 984 3200
Website: https://ojirasoft.com/
Where a Data Protection Officer has been formally appointed, their contact details will be made available to data subjects as required by applicable law.
Your trust and the protection of your personal data are important to us. If you require further information about how your data is protected or used, please contact us using the details above.
4. Rights of Data Subjects
Subject to applicable legal conditions and exceptions, you have the following rights regarding your personal data.
- Right to Be Informed: You have the right to be informed about whether your personal data is being processed and to receive information about the purposes of processing, categories of data, recipients, retention periods, the source of data not collected directly from you, and the existence of relevant automated decision-making.
- Right to Erasure: You may request the deletion of your personal data where the applicable legal conditions are met.
- Right to Data Portability: Where the legal requirements are met, you have the right to receive personal data that you provided to us in a structured, commonly used and machine-readable format.
- Right to Object: You have the right to object to certain processing of your personal data where the conditions provided by applicable law are met.
- Right to Restriction of Processing: Under certain circumstances, you may request that we restrict the processing of your personal data.
- Right to Rectification: You have the right to request the correction of inaccurate personal data and the completion of incomplete personal data concerning you.
- Right to Withdraw Consent: Where we process your personal data on the basis of consent, you may withdraw that consent at any time.
- Right to Lodge a Complaint: You may lodge a complaint with the competent data protection supervisory authority if you believe that your personal data has been processed in violation of applicable data protection law.
5. Legal Basis for Processing
We process personal data only where an appropriate legal basis applies.
5.1 Consent
Where required, we obtain your consent before processing personal data for a specified purpose. In such cases, the legal basis is Article 6(1)(a) GDPR.
Examples may include optional integrations or certain cookies and marketing activities where consent is required.
5.2 Performance of a Contract
Processing may be necessary to provide SetLinn services or to take steps at your request before entering into a contract. In such cases, the legal basis is Article 6(1)(b) GDPR.
This may include account registration, providing requested platform features, arranging bookings, managing appointments and processing transactions.
5.3 Legal Obligations
Where we are required by law to process or retain personal data, including certain accounting, tax or regulatory records, the legal basis is Article 6(1)(c) GDPR.
5.4 Vital Interests
In limited circumstances, processing may be necessary to protect the vital interests of you or another natural person, as provided under Article 6(1)(d) GDPR.
5.5 Legitimate Interests
We may process personal data where necessary for our legitimate interests or those of a third party, provided that these interests are not overridden by your fundamental rights and freedoms.
Such interests may include maintaining platform security, preventing fraud and abuse, troubleshooting technical problems, protecting our legal rights and improving the reliability of SetLinn.
Where required, we assess the appropriateness of relying on legitimate interests and respect your applicable rights to object.
6. Categories of Personal Data We Collect
The personal data we collect depends on how you use SetLinn and the features you choose to access.
6.1 Account and Registration Data
When you register for or maintain a SetLinn account, we may process:
- Name;
- Email address;
- Account identifier;
- Authentication information;
- Profile photo;
- Country or location information you provide;
- Profile details and preferences;
- Onboarding responses; and
- Other information you voluntarily provide.
6.2 Profile and Community Data
When you use SetLinn's community features, we may process information contained in your profile, posts, comments, documents, group participation, messages and other content you create or share.
Information published in public or community areas may be visible to other users depending on the relevant feature and its settings.
6.3 Service Provider and Booking Data
Where you offer or book services through SetLinn, we may process:
- Service-provider profile information;
- Service descriptions and pricing;
- Availability information;
- Customer and Service Provider contact details;
- Booking references and status;
- Appointment dates, times and time zones;
- Relevant communications;
- Information needed to fulfil a booking; and
- Related transaction information.
We use this information to facilitate bookings, communicate relevant details and provide the requested services.
6.4 Payment and Transaction Data
Where payments are made through SetLinn, we may process information such as transaction references, amounts, currencies, payment status, refunds, payout information and information necessary to address payment disputes or suspected fraud.
Payment details may be processed directly by a third-party payment provider such as Stripe. The information collected by that provider depends on the payment method and transaction.
6.5 Technical and Access Data
When you visit or use SetLinn, technical information may be collected, including IP address, date and time of access, browser type, operating system, device information, requested pages or functions, referring URL, error information and security-related logs.
This information is used for the operation, security, troubleshooting and improvement of the platform.
6.6 Third-Party Account Data
If you choose to connect a third-party account, such as a Google account, we may receive information permitted by the permissions you authorize. The specific data and purposes are explained in the relevant integration sections below.
7. Google Sign-In
SetLinn may allow you to create or access your account using Google Sign-In.
If you choose this option, Google may provide us with information associated with your Google account, subject to the permissions you authorize. This may include your Google account identifier, name, email address and profile photo URL.
We use this information to authenticate your account, facilitate registration and sign-in, identify your account and display relevant profile information.
Google Sign-In is optional where alternative registration or login methods are available.
8. Google Calendar and Google Meet Integration
SetLinn may allow Service Providers to connect their Google Calendar account to manage appointments associated with bookings made through SetLinn and to generate Google Meet links for those appointments.
The integration is optional and is intended to support appointment scheduling and meeting functionality.
8.1 Google Authorization
To provide this functionality, SetLinn may request permission to access and manage Google Calendar events through the Google Calendar API, including the scope:
`https://www.googleapis.com/auth/calendar.events`
The permission granted by Google may technically allow an authorized application to access and manage events on calendars the user can access. SetLinn's intended use of this permission is to provide calendar and meeting functionality associated with SetLinn bookings.
8.2 Information Processed
Depending on the implementation and the booking, information processed through this integration may include:
- Google account email address;
- Authorization credentials or tokens necessary to maintain the connection;
- Calendar event identifiers;
- Booking references;
- Appointment titles and descriptions;
- Appointment dates, times and time zones;
- Attendee email addresses;
- Relevant participant or service information; and
- Google Meet conference information or meeting links.
8.3 Purposes of Processing
We use Google Calendar data to support the calendar and meeting functionality authorized by the user. Depending on the features available, this may include:
- Creating calendar events for confirmed SetLinn bookings;
- Adding relevant appointment information;
- Generating or attaching Google Meet links;
- Updating events when bookings are rescheduled; and
- Deleting or cancelling events when bookings are cancelled, where supported.
Where attendee email addresses are included in an event, that information may be transmitted to Google for appointment coordination.
8.4 Use and Sharing of Google User Data
Google user data obtained through the integration is used only for the purposes disclosed in this policy and to provide the functionality authorized by the user.
We do not sell Google user data, use it for advertising, or use Google Calendar data for general-purpose AI or machine-learning model training.
Any access, use or sharing of Google user data must be limited to what is necessary to provide the authorized functionality or otherwise permitted by applicable law and Google's policies.
Our handling of Google user data is intended to comply with the Google API Services User Data Policy, including its Limited Use requirements.
8.5 Disconnecting the Integration
You may disconnect Google Calendar through SetLinn where the option is available or revoke SetLinn's access through your Google Account settings.
Once authorization is revoked, SetLinn will no longer be able to perform actions requiring that authorization.
Events previously created through SetLinn may remain in your Google Calendar unless they are separately deleted. Revoking access does not automatically remove information already shared with Google or other participants.
8.6 Third-Party Service Limitations
Google controls its own services and may apply its own terms and privacy policies. SetLinn cannot guarantee the availability or delivery of Google Calendar notifications, invitations, reminders or meeting links.
9. Service Providers, Bookings and Transactions
SetLinn enables users to discover services and connect with Service Providers.
To arrange and fulfil bookings, relevant information may be shared between the customer and Service Provider. This may include names, contact details, booking references, service information, appointment dates and times, and other information necessary to provide the booked service.
We may also process booking status, transaction information, payment status, refunds and payout information to administer transactions, address disputes and maintain appropriate records.
Users should only provide personal information that is necessary for the relevant booking and should ensure that they have an appropriate lawful basis for sharing another person's personal data.
10. Payments and Payment Service Providers
SetLinn may use Stripe or another payment service provider to process transactions, facilitate payouts, help prevent fraud and manage payment disputes.
Where a third-party payment provider processes personal data, that provider may process the information in accordance with its own privacy policy, contractual obligations and applicable law.
The specific information processed depends on the payment method and transaction. It may include contact information, transaction identifiers, amounts, currency, payment status, refund details and payout-related information.
SetLinn's platform fees, payment processing arrangements, cancellations and refunds are described in the applicable Terms and Conditions and other transaction information provided to users.
11. Collection of User Data
We collect personal data when you register for an account, complete your profile, use platform features, submit forms, publish content, contact us, book or provide services, or otherwise interact with SetLinn.
We seek to collect information that is relevant to the purpose for which it is needed.
The information collected may include your name, email address, profile information, country or location information you provide, service and booking details, community content, transaction information and other information you voluntarily submit.
12. Direct Marketing
Where SetLinn sends marketing communications, we will process personal data for that purpose in accordance with applicable law.
Where prior consent is required, we will obtain it before sending marketing communications. You may withdraw your consent or opt out of marketing communications at any time using the available unsubscribe mechanism or by contacting us.
Withdrawing consent to marketing does not affect service-related communications that are necessary to administer your account, bookings, transactions or security.
We will not use personal data for direct marketing purposes where doing so would violate applicable law.
13. Analysis, Market Research and Platform Improvement
We may analyze information about the use of SetLinn to understand user needs, identify technical problems, assess platform performance and improve our services.
This may involve processing account, usage, technical, transaction or communication information where relevant and lawful.
Where possible and appropriate, we use aggregated or anonymized information for statistical analysis. We do not disclose identifiable analysis results to third parties for their independent use unless there is an appropriate legal basis.
Where analytics tools process personal data, the processing must comply with applicable data protection requirements, including consent requirements where relevant.
14. Contacting Us Through SetLinn
When you contact us through a contact form, email or another communication channel, we may process the information you provide, including your contact details and the contents of your enquiry.
We use this information to respond to your request, provide assistance, investigate issues and handle any necessary follow-up.
We may retain relevant correspondence for as long as reasonably necessary to handle the enquiry, maintain appropriate records or establish, exercise or defend legal claims.
Where disclosure to a third party is necessary to resolve your enquiry, we will ensure that the disclosure has an appropriate legal basis.
15. Cookies and Similar Technologies
SetLinn may use cookies and similar technologies to support the operation of the website and platform.
Depending on their purpose, these technologies may be used to:
- Maintain necessary website and account functionality;
- Keep users signed in;
- Remember preferences;
- Support security;
- Understand platform usage;
- Measure performance; and
- Improve the user experience.
Cookies may be set by SetLinn or, where applicable, by third-party services integrated into the platform.
Where applicable law requires consent for non-essential cookies or similar technologies, we will seek consent before using them.
16. Access Data and Server Logs
When you visit SetLinn, our systems or hosting providers may record technical access information for operational, security and troubleshooting purposes.
Depending on the system configuration, this information may include:
- IP address;
- Date and time of the request;
- Requested page, file or function;
- Browser and device information;
- Referring URL;
- Technical request information;
- Server response or access status; and
- Data volume transferred.
We process such information where necessary to maintain the proper functioning and security of our IT systems, investigate errors, detect unauthorized access and protect against cyberattacks.
17. SetLinn AI and Automated Features
SetLinn may provide AI-powered features to help users discover and understand information, services, opportunities, communities and other resources available through the platform.
SetLinn AI may generate responses or recommendations based primarily on content available through SetLinn, including content published by SetLinn, Service Providers, users, groups and communities.
The processing of relevant information is intended to provide the requested AI feature, help users navigate available content and improve the usefulness of platform information.
AI-generated information may be incomplete, outdated or inaccurate and should not be treated as professional advice. Users should independently verify important information before relying on it, especially for decisions involving immigration, education, employment, finance or other significant matters.
Google Calendar data obtained through the calendar integration is not used for general-purpose AI or machine-learning model training.
Where SetLinn introduces automated processing that is subject to specific transparency or individual-rights requirements under applicable law, we will provide the relevant information and safeguards.
18. Social Media Presence
SetLinn or OJIRA Soft may maintain social media pages to communicate with users, share updates and provide information about services.
When you interact with these pages, the relevant social media provider may process personal data under its own privacy policy. Depending on the platform and your interactions, this may include profile information, comments, messages, engagement information and technical usage data.
Social media providers may process information in countries outside the European Economic Area, subject to their own arrangements and applicable law.
We may receive information that you voluntarily provide through comments, messages or other interactions. We use that information to communicate with you and respond to relevant enquiries.
For details about the processing carried out by a particular social media provider, please consult that provider's privacy policy and available privacy settings.
19. Integration of Third-Party Services and Content
SetLinn may integrate third-party services and content to support platform functionality, authentication, payments, calendar scheduling, analytics, hosting and other features.
These integrations may include Google services, payment providers such as Stripe, hosting providers and other technology services actually used to operate SetLinn.
Depending on the integration, certain information may be transmitted to the third-party provider, such as account information, technical identifiers, booking details, payment information or information necessary to deliver the requested feature.
Third-party services may process personal data in accordance with their own privacy policies and applicable contractual and legal obligations.
Where a third party processes personal data on our behalf, we will seek to ensure that appropriate data protection arrangements are in place where required. Where a third party processes information as an independent controller, its own privacy practices and responsibilities may apply.
We do not authorize third parties to use personal data obtained through SetLinn for purposes that are incompatible with the relevant legal basis, contractual arrangements or applicable data protection requirements.
20. Cooperation with External Data Processors and Third Parties
In the course of operating SetLinn, personal data may be disclosed, transferred or made available to other persons or organizations where there is an appropriate legal basis.
These recipients may include:
- Hosting and infrastructure providers;
- Authentication and integration providers;
- Payment service providers;
- Technical support and maintenance providers;
- Analytics providers where used;
- Service Providers involved in a user's booking; and
- Public authorities where disclosure is legally required.
Where an organization processes personal data on our behalf, we will put appropriate contractual and organizational safeguards in place as required by applicable law, including Article 28 GDPR where applicable.
21. Transfer to Third Countries
Personal data may be processed in countries outside the European Economic Area, including where we use third-party services or where a provider's infrastructure operates internationally.
Where a transfer is subject to the GDPR's international data transfer requirements, we will seek to ensure that an appropriate transfer mechanism is in place, such as an applicable adequacy decision, appropriate contractual safeguards or another lawful mechanism.
Information about a specific third-party provider's international processing may also be available in that provider's privacy documentation.
22. Deletion, Blocking and Retention of Personal Data
We process and retain personal data only for as long as reasonably necessary for the purposes described in this policy, including providing SetLinn services, administering accounts, managing bookings and transactions, maintaining security, resolving disputes and complying with legal obligations.
Retention periods vary depending on the type of information, the reason it was collected and the applicable legal requirements.
For example, certain accounting, tax or transaction records may need to be retained after an account has been closed. Other information may be deleted or anonymized when it is no longer required.
Where you request deletion of your account or personal data, we will assess and process the request in accordance with applicable law. We may retain information where a legal obligation or another lawful exception applies.
You can submit a data deletion request through the relevant functionality available on SetLinn or, where available, through:
https://setlinn.com/legal/data-deletion
Deleting a SetLinn account does not necessarily delete information already shared with other users or information held by third-party services. For example, calendar events previously created in Google Calendar may remain in that account unless separately deleted.
23. Data Security
We take reasonable technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, alteration or disclosure.
The measures applied depend on the nature of the data, the systems involved and the risks associated with processing. They may include access restrictions, authentication controls, secure transmission mechanisms, system monitoring and other appropriate safeguards.
We review and improve our security practices as reasonably necessary. However, no internet-based service can guarantee absolute security.
You are responsible for protecting your account credentials and should contact us if you suspect unauthorized access to your SetLinn account.
24. Children's Privacy
SetLinn is not intended to knowingly collect personal data from children in circumstances where such collection is prohibited by applicable law.
Where parental or guardian authorization is required, we will take appropriate steps to comply with the relevant legal requirements.
If you believe that a child has provided personal data to SetLinn in circumstances that are not permitted, please contact us so that we can assess the matter and take appropriate action.
25. Third-Party Websites and Services
SetLinn may contain links to third-party websites or services that are not operated by us.
If you follow such links or use those services, the third party may collect and process personal data under its own privacy policy and terms.
We are not responsible for the independent privacy practices of third-party websites or services. We encourage you to review their privacy information before providing personal data to them.
26. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to SetLinn, the services we provide, our data processing practices, third-party integrations or applicable legal requirements.
Where material changes are made, we will take reasonable steps to inform users where required by applicable law.
The updated policy will be published on SetLinn with a revised “Last Updated” date.
27. Complaints and Supervisory Authorities
If you have concerns about the processing of your personal data, you may contact us using the details below.
We will review relevant requests and complaints and respond in accordance with applicable law.
You also have the right, where provided by applicable law, to lodge a complaint with the competent data protection supervisory authority.
28. Google API Services – Limited Use Disclosure
SetLinn's use and transfer of information received from Google APIs will comply with the Google API Services User Data Policy, including the Limited Use requirements.
Google user data is used only for the purposes described in this Privacy Policy and to provide the functionality authorized by the user.
In particular:
- Google user data is not sold.
- Google user data is not used for advertising.
- Google Calendar data is not used for general-purpose AI or machine-learning model training.
- Google Calendar data is used for the calendar and meeting functionality described in this policy.
- Access to Google user data is intended to be limited to what is necessary to provide the relevant authorized functionality.
- Google user data is not shared except as necessary to provide the authorized functionality, comply with applicable law or as otherwise permitted under applicable Google policies.
- Users may revoke Google access through the available Setlinn controls or their Google Account settings.
Setlinn will not use or transfer Google user data for purposes inconsistent with the permissions granted by the user or the Google API Services User Data Policy.
29. Contact Information
For questions about this Privacy Policy, requests concerning your personal data, or other privacy-related matters, please contact:
OJIRA Soft UG (haftungsbeschränkt)
Belßstr. 78B
12249 Berlin, Germany
Registration Number: HRB 226144 B
VAT Identification Number: DE 341838128
Email: info@ojirasoft.com
Phone: +49 162 984 3200
Website: https://ojirasoft.com/
When making a request concerning your personal data, please describe your request clearly and provide enough information for us to identify the relevant account where necessary.
We may need to verify your identity before completing certain requests.
