Privacy Policy

1. Data Controller

The data controller for personal data processed through the Beekeeper platform is:

• Risan Solutions (enkeltpersonforetak)
• Org.nr: 937 137 273
• Registered address: Valenvegen 49, 3802 Bø i Telemark, Norway
• Country: Norway
• Contact: privacy@beekeeper.bz

This Privacy Policy explains how we collect, use, and safeguard personal data when you use the Beekeeper platform ("Service"). The Service is designed around the principle of data minimization — we collect only what is necessary for the functionality of the platform.

2. Scope

This policy applies to all users of the Beekeeper platform, including Merchants and Creators with registered accounts, as well as coupon recipients (end consumers) who interact with Coupon Tokens. The Service is intended for use by businesses and professionals in a commercial capacity. For details on the terms governing use, see our Terms of Service.

3. Information We Collect

Merchant & Creator Accounts

When you register an account, we collect and process:

• Email address and display name
• Hashed password (passwords are not stored in plaintext)
• Business name and details (Merchants)
• Two-factor authentication secrets (stored encrypted)
• Stripe account identifiers (for billing and payouts)
• Layout and interface preferences — your chosen sidebar position (left, right, top, or bottom), sidebar color theme, navigation item order, dashboard panel order, and dashboard shortcut configuration. By default these are stored server-side so your workspace stays consistent across devices. You may opt out at any time via Settings → Privacy & Data → “Store Layout Preferences Locally Only” — enabling this deletes server-stored preferences immediately and stores future changes only in your browser's local storage.

Direct Messages and Voice Calls

The platform includes a direct messaging inbox and voice calling feature for communication between Merchants and Creators. When you use these features, we collect and process:

• Message content: The text of direct messages you send or receive, including timestamps, sender identity, read status, and edit or deletion history.
• Voice call metadata: Call session identifiers, the conversation the call is associated with, call initiator, and call start and end timestamps (used to calculate and display call duration in the conversation history).
• Call summary markers: Short system-generated messages appended to the conversation (e.g., “📞 Call ended · 1:23” or “☎️ Tried to call you”) to create a readable call log. These are stored as regular messages.

Voice audio is never recorded or stored. All voice calls are transmitted peer-to-peer using WebRTC with Secure Real-time Transport Protocol (SRTP) encryption. Our voice call infrastructure (LiveKit) is self-hosted on our own servers — no audio data is sent to any third-party cloud service. Only the call metadata described above is retained.

The legal basis for processing messaging and call data is contract performance (Art. 6(1)(b)) — these communications are a core feature of the platform that you have signed up to use. Message content is private to the participants; Beekeeper does not read or analyse message content for advertising or profiling purposes.

Coupon Recipients (End Consumers)

We apply data minimization for coupon recipients. When a consumer receives or uses a Coupon Token, we do not collect their name or email address. We process only:

• Truncated, hashed IP addresses (for rate limiting and abuse prevention only — full IP addresses are not stored)
• Coupon Token interaction data (issuance, validation, redemption timestamps)

Automatically Collected Data

• Truncated IP addresses (/24 for IPv4, /64 for IPv6) for rate limiting
• Hashed user agent strings for session security
• Timestamps of activity

4. Legal Basis for Processing

We process personal data under the following legal bases as defined in Article 6 of the GDPR:

• Contract performance (Art. 6(1)(b)): Processing necessary to provide the Service, including account management, coupon issuance and redemption, billing, and creator payouts.
• Legitimate interest (Art. 6(1)(f)): Processing necessary for fraud prevention, abuse detection, rate limiting, platform security, and service improvement. Our legitimate interest in preventing abuse and ensuring platform integrity is balanced against the minimal nature of the data processed (truncated IPs, hashed identifiers).
• Legal obligation (Art. 6(1)(c)): Processing required to comply with applicable laws, including financial record-keeping, tax compliance, and responding to lawful requests from authorities.
• Consent (Art. 6(1)(a)): Where you have opted in to marketing communications. You may withdraw consent at any time through your account Settings → Privacy & Data tab, or by contacting privacy@beekeeper.bz. Withdrawal of consent does not affect the lawfulness of any processing carried out before withdrawal.

5. How We Use Your Information

• Service delivery: Process coupon issuance, validation, and redemption
• Billing: Calculate and charge platform fees via Stripe
• Payouts: Process creator commission payments via Stripe Connect
• Security: Detect abuse, prevent fraud, enforce rate limits
• Transactional communication: Send account verification, password resets, and essential service notifications via email
• Marketing communication: Send promotional or informational emails where you have given consent (you may withdraw consent at any time)
• Analytics: Provide merchants and creators with aggregated, non-identifying campaign performance metrics
• Direct messaging: Store and deliver text messages exchanged between Merchants and Creators through the platform inbox. Messages are retained to provide persistent conversation history. Legal basis: contract performance (Art. 6(1)(b)).
• Voice calling: Facilitate real-time encrypted voice calls between Merchants and Creators. Call metadata (duration, timestamps) is retained and displayed in the conversation history as call summary markers. Voice audio is never recorded. Legal basis: contract performance (Art. 6(1)(b)).
• Interface personalization: Store and apply your dashboard layout preferences (sidebar position, color theme, panel order, and shortcut configuration) across devices and sessions. Legal basis: contract performance (Art. 6(1)(b)). You control where this data lives: by default it is stored in your account (server-side); you may switch to browser-local storage only at any time via Settings → Privacy & Data, which immediately deletes the server copy. You can also reset all preferences to default via the “Customize Layout” button in your dashboard sidebar → Reset to Default.

6. Data Processors and Sharing

We engage the following third-party data processors under written data processing agreements (DPAs) or equivalent contractual arrangements where required by Art. 28 GDPR:

We also share data in the following circumstances:

• Merchants: Aggregated redemption data for their own campaigns (no end-consumer personal data is shared).
• Creators: Commission and performance data for campaigns they participate in.
• Legal authorities: When required by applicable law, court order, or to protect our legal rights.

We do not sell, rent, or trade personal information to third parties for marketing or advertising purposes.

7. International Data Transfers

Some of our service processors, including Stripe and Google, process personal data outside the European Economic Area (EEA), including in the United States. Where data is transferred outside the EEA, we ensure appropriate safeguards are in place, including:

• EU-US Data Privacy Framework (DPF): Both Stripe, Inc. and Google LLC are certified under the EU-US Data Privacy Framework, providing an adequacy basis for transfers to the USA.
• Standard Contractual Clauses (SCCs): Where DPF certification alone is not sufficient, transfers are additionally covered by SCCs approved by the European Commission.
• Adequacy decisions: Transfers to countries covered by an adequacy decision of the European Commission require no additional safeguards.

8. Data Security

We implement appropriate technical and organizational measures to protect personal data, including:

• Passwords hashed with bcrypt
• All connections encrypted with TLS/HTTPS
• Session tokens with HttpOnly, Secure, and SameSite attributes
• Two-factor authentication (TOTP)
• IP-based rate limiting with privacy-preserving truncation
• Automated abuse detection mechanisms
• Role-based access control for platform operations
• End-to-end encrypted voice calls using WebRTC SRTP (audio never recorded or stored)

While we take reasonable measures to protect your data, no system is completely secure. We cannot guarantee absolute security of data transmitted or stored through the Service.

9. Data Retention

We retain personal data only as long as necessary for the purposes described in this policy:

• Account data: Retained while your account is active. Deleted upon account deletion request, subject to legal retention obligations.
• Transaction and billing records: Retained for 7 years as required by Norwegian bookkeeping law (bokføringsloven).
• Direct messages: Retained while your account is active. When your account is deleted, the content of messages you sent is permanently anonymised (replaced with a deletion notice) and your authorship is disassociated. Conversation thread structures may be retained to preserve continuity for other participants.
• Voice call metadata: Retained alongside the associated conversation while both participants' accounts are active.
• Rate limiting data (truncated IPs): Purged within 24 hours.
• Session data: Expires after 7 days of inactivity.
• Audit logs: Retained for 1 year for security and compliance purposes.

10. Cookies and Local Storage

Beekeeper uses only essential and functional cookies. We do not use tracking cookies, marketing cookies, or advertising cookies. For full details, see our Cookie Policy.

Essential Cookies

• beekeeper_session — Authentication session cookie. HttpOnly, Secure, SameSite=Lax. Expires after 7 days. Required for platform login functionality.

Functional Cookies

• googtrans — Language preference cookie set when you activate the language selector. When this feature is used, page content is transmitted to and processed by Google LLC (via Google Translate) to perform the translation. By using the language selector, you consent to this processing by Google. Google's Privacy Policy applies to Google's processing of your data. The language preference cookie persists for 1 year.

The essential session cookie is strictly necessary for platform functionality and is exempt from consent requirements under the ePrivacy Directive. The functional translation cookie is set only when you explicitly use the language selector, which constitutes your consent to that specific feature.

11. Your Rights Under GDPR

Under the General Data Protection Regulation and Norwegian data protection law, you have the following rights:

• Right of access (Art. 15): Request a copy of the personal data we hold about you.
• Right to rectification (Art. 16): Request correction of inaccurate or incomplete data.
• Right to erasure (Art. 17): Request deletion of your personal data, subject to legal retention obligations.
• Right to restriction (Art. 18): Request restriction of processing in certain circumstances.
• Right to data portability (Art. 20): Request your data in a structured, machine-readable format.
• Right to object (Art. 21): Object to processing based on legitimate interest.
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

Exercising Your Rights

Many of these rights can be exercised directly from your account — no need to contact us:

• Download your data, restrict processing, object to processing, manage marketing consent (Art. 15, 18, 20, 21): Settings → Privacy & Data tab. The export includes: profile, privacy settings, merchant/creator data, redemptions, billing events, payouts, campaign invitations, direct messages sent, conversations, creator video logs, layout preferences, and notifications.
• Correct your profile information (Art. 16): Settings → Profile tab
• Delete your account (Art. 17): Settings → Danger Zone tab

For rights not covered by in-app tools, or for requests relating to data not accessible through your account, contact us at privacy@beekeeper.bz. We will respond within 30 days as required by GDPR (extendable by a further 2 months for complex requests, with notice).

12. Data Breach Notification

In the event of a personal data breach, we will, where required by Article 33 GDPR, notify the Norwegian Data Protection Authority (Datatilsynet) within 72 hours of becoming aware of the breach. Where the breach is likely to result in a high risk to your rights and freedoms, we will, in accordance with Article 34 GDPR, notify affected data subjects without undue delay via the email address on your account.

Notifications will describe the nature of the breach, the data categories and approximate number of individuals affected, the likely consequences, and the measures taken or proposed to address it.

To report a suspected security vulnerability or incident, please contact security@beekeeper.bz immediately.

13. Right to Lodge a Complaint

If you believe that our processing of your personal data violates data protection law, you have the right to lodge a complaint with the relevant supervisory authority. For Norway, the supervisory authority is:

• Datatilsynet (Norwegian Data Protection Authority)
• Website: www.datatilsynet.no
• Email: postkasse@datatilsynet.no

We encourage you to contact us first at privacy@beekeeper.bz so that we can try to resolve your concern directly.

14. Children's Privacy

The Service is intended for use by businesses and professionals and is not directed at individuals under 18 years of age. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child under 18, we will delete it promptly.

15. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify registered users of material changes via email at least 30 days before the changes take effect. Continued use of the Service after the effective date constitutes acceptance of the updated policy.

16. Marketing Communications

Beekeeper may send you marketing or promotional emails only where you have given explicit opt-in consent (GDPR Art. 6(1)(a)). Marketing consent is off by default — we do not pre-tick consent boxes or treat registration as consent to marketing.

• Transactional emails (account verification, password resets, payout notifications, billing alerts, creator invitations) are sent on the basis of contract performance (Art. 6(1)(b)) and do not require separate marketing consent. These are service-critical communications.
• Marketing emails (newsletters, product updates, promotional offers) are sent only if you have affirmatively opted in. You can manage this at any time via Settings → Privacy & Data → Marketing consent toggle, or by contacting privacy@beekeeper.bz.
• Consent withdrawal is effective immediately upon request and does not affect any processing lawfully carried out before withdrawal. You will continue to receive transactional emails after withdrawing marketing consent.
• Consent records are stored as a field on your user account (timestamp and current state). We do not retain a separate consent history log for marketing at this time; withdrawal is irreversible in the sense that the opt-in must be re-given actively.
• No third-party marketing: We do not share your contact details with third parties for their marketing purposes, and we do not purchase marketing lists.

Creator invitation emails sent by the platform on behalf of Merchants to potential Creators constitute commercial communications under the Norwegian Marketing Control Act (markedsføringsloven). These emails include sender identification, a clear opt-out mechanism, and the operator's postal address as required by §15 of that Act.

17. Performance Analytics and Profiling

Beekeeper provides merchants and creators with internal performance analytics — aggregated, campaign-level statistics about coupon issuance, redemption rates, conversion funnels, and creator commission performance. This processing is described below.

What analytics we process

• Merchant analytics: Redemption counts, revenue attributed, campaign performance over time, creator leaderboard (ranked by redemptions / commissions within that merchant's own program). Data is isolated per merchant — no cross-merchant data sharing.
• Creator analytics: Coupon issuance counts, redemption counts, earnings, and conversion rates for campaigns the creator participates in. Creators only see their own performance data.
• No cross-platform profiling: We do not combine your data with third-party sources, build behavioral profiles for advertising, or share analytics data with advertising networks.

Is this profiling under GDPR?

The internal analytics described above constitute limited profiling of merchant and creator accounts in the sense of GDPR Art. 4(4) — we generate performance metrics about each account. However, this profiling:

• Is based solely on activity within the Beekeeper platform (no external data sources)
• Is used only to provide you with performance insights about your own account
• Does not produce legal or similarly significant effects on you
• Is not used for automated decision-making (Art. 22 GDPR) — no decisions are made solely by automated means without human review

The legal basis for this analytics processing is contract performance (Art. 6(1)(b)) — performance metrics are a core feature of the Service that you signed up to receive.

Risk scoring

The platform applies automated risk scoring to coupon tokens for fraud and abuse prevention (e.g., detecting bot-generated token requests). This is processed on the basis of legitimate interest (Art. 6(1)(f)). Risk scores are used internally; they do not result in automated account decisions without human review.

No third-party analytics tools

Beekeeper does not use Google Analytics, Mixpanel, Hotjar, Meta Pixel, or any other third-party analytics or advertising SDKs. All performance metrics are generated from first-party platform data, processed internally, and never shared with advertising technology companies.

Your right to object

You may object to profiling based on legitimate interest at any time via Settings → Privacy & Data → "Object to processing". Note that objecting to internal analytics may limit the functionality of your merchant or creator dashboard.

18. Contact

For privacy-related questions, data subject requests, or complaints:

• Data Controller: Risan Solutions (Org.nr 937 137 273)
• Address: Valenvegen 49, 3802 Bø i Telemark, Norway
• Privacy email: privacy@beekeeper.bz
• General: hello@beekeeper.bz