Privacy Policy

This says what happens to your personal data when you use Ollinter. It is written to be read, not to be survived.

The company responsible for it is:

Write to that address with any question about your data, to ask for a copy, or to ask us to correct or delete something.

We do not sell personal data. We have advertising and statistics tags from other companies ready. No advertising or statistics tag runs until we switch them on, and we will update this policy when we do. After that, in the EU, the EEA, the UK and Switzerland they load only if you say yes to the cookie banner; everywhere else they load without asking. The cookie policy names every one of them.

What we hold

Depending on how you use the platform:

• Your name, email address, and a telephone number if you give us one.
• Your date of birth, which we ask once to check you are an adult.
• Your language and time zone.
• Your account and profile, and for a professional the public profile: photo, introduction video, description, qualifications, experience, prices, availability.
• For a professional, identity documents, a selfie, proof of address and proof of qualifications.
• Bookings, sessions, payments, refunds and payouts.
• Messages, files shared in a session, and what is drawn on the board.
• Recordings, transcripts and translated captions, where everyone in the room agreed to them.
• Reviews you write and replies to them.
• For a professional, the private note and rating they may keep about a learner they teach, which the learner does not see.
• Which profiles you looked at recently.
• Support requests, complaints, appeals and disputes.
• Technical data needed to keep the platform safe: sign-in and session records, the address a request came from, a device identifier we generate, and a log of what our staff did.

Card numbers and bank details never reach our servers. Our payment company holds them.

Why we may hold it, in law

• To give you the service you asked for and to perform our agreement with you (Article 6(1)(b) of the GDPR).
• To meet a legal obligation, such as tax and accounting records (Article 6(1)(c)).
• For our legitimate interests in keeping the platform safe and free of fraud (Article 6(1)(f)).
• With your consent, for anything you are asked about separately, such as recording a session (Article 6(1)(a)).

Your account

We use your name, email address, telephone number, date of birth, language and time zone to create and run your account, to check you are an adult, to show the site in your language, and to let you book.

The platform is for adults. If the date of birth you give says otherwise, the account is held and the date is kept as the record of why.

Signing in

We do not store passwords. You sign in with a six-digit code sent to your email, with a connected Google account, or with a passkey. Our sign-in provider, Stytch, handles it, and we store your email address once they confirm the sign-in.

After that you have a session that lasts seven days from your last visit.

Booking and payment

To run a booking we hold the professional, the service, the date, the length, the price, the state of the booking, the payment, and the messages that go with it.

We use Stripe for payments and payouts. Card numbers do not reach us. A professional's bank details are given to Stripe, not to us. We keep the amounts, the booking, the status, who paid whom, refunds and any card dispute, along with the payment company's own reference for each movement.

For a card dispute we send the card network what it asks for: the name and email address on the account, what the booking was, when the session was, and whether each side joined the room.

Public profiles

A professional's profile is public: photo, introduction video, description, qualifications, experience, services, prices and availability. That is the point of it. What they publish is theirs to get right.

Checking who a professional is

Before a professional can be paid, we check who they are. We may process an identity document, a selfie, proof of address and certificates.

Those files are encrypted before they are stored. A person reviews them. We run no face recognition and no automated biometric comparison anywhere.

From the machine-readable strip of an identity document we keep the issuing country, the document type, the nationality and the expiry date. The name, the document number and the date of birth from that strip are not stored as text. We do keep a one-way fingerprint made from them, which lets us notice the same document on two accounts and cannot be turned back into the document.

Identity documents are deleted five years after the professional relationship ends or after a rejection. An open case delays that until it is closed.

Messages and sessions

We process the messages and files you exchange here, and what is drawn on the board, so that the service works and so there is a record either side can point to.

Before a paid booking exists between two people, the system hides contact details such as phone numbers and email addresses in messages and profile text. It is a measure against fraud and against taking the work off the platform.

The video and audio run on our own servers, using the open-source LiveKit. Your browser gets a short-lived key to enter a room, and it stops working when the session ends or you leave.

Recording, transcripts and AI

A session is not recorded automatically. Before anyone joins, each person answers four separate questions: recording, a written transcript, AI help, and translated captions.

A feature is only switched on if the answers allow it. One refusal keeps it off for that room, except in a lecture, where the audience is not on stage and the rule covers the people speaking.

You can withdraw an answer at any point up to the end of the session. Withdrawing the transcript deletes that session's transcript at once. Withdrawing the recording stops it there; what was already recorded is deleted on the ordinary schedule.

Where you have agreed in a session, text from that session may be sent to Google to translate captions and to help with flashcards.

Some features send text to Google without a separate question, to make these features work:

• Messages, room chat, homework and answers in live activities, to translate them for the person reading.
• Profiles and reviews, to show them in other languages.
• What a professional writes in their profile, and what you type in the search box, to find professionals by meaning.
• A word you save as a flashcard, to add its meaning in your language.
• Messages, room chat, homework and answers in live activities, to work out which language they are written in.

Before we send text, we try to take out email addresses, phone numbers, links and messenger handles, and we put them back in the translation. We do not take out names. Google says it processes the text in the European Union, and its terms say it does not train its models on our data without our permission. If Google's safety checks flag a request as possible abuse, Google may keep a copy of that request for up to 90 days, in the European Union, so a person can check it. Google does not use that copy to train its models. There is a daily limit on how much we translate.

Recently viewed profiles

We keep the list of professionals you looked at recently, so you can find them again. Only you see it, you can clear it, it expires after 30 days, and it is part of your export and your erasure.

Statistics

We count how the platform is used: how many searches lead to a profile, a message, a booking. Those tables cannot hold a user, a session, an address or a device, and a test fails if anyone tries to add a column that could.

One list keeps typed words: the searches that found nothing, which tells us which professionals to look for. It holds no trace of who typed them and is deleted after 180 days.

Keeping the platform safe

We process technical data to spot fake accounts, stop automated attacks, limit sign-in attempts, keep requests under control, and detect abuse. The basis is our legitimate interest in running a platform that is not overrun by it.

Server logs are kept for 90 days.

Who inside the company can see what

Our staff hold one or more roles: identity checks, finance, moderation, support, translation, audit, and administration. Each role opens only what its work needs, and identity documents open only for the roles that review them.

Every administrative change and every look at sensitive data, such as opening an identity document, is written to a record the database itself refuses to alter or delete. It holds who acted, when, on what, from which address and from which device. We keep it for seven years.

How we protect it

• Encrypted connections, and the servers refuse outdated encryption.
• Identity documents and tax numbers encrypted before storage.
• Access by role, with a separate sign-in for the staff tools.
• Limits on requests and on upload sizes.
• Every incoming field checked before it is used.
• Answers built from a fixed list of fields, never a raw database row.
• Encrypted backups.
• Automated checks for known holes in the software we use.
• Separate administrative and user access to the servers.

Where the data lives

The database, the application and the video run on two servers we rent from Hetzner in Helsinki, Finland, inside the EU. Our error tracker is our own and sends nothing outside.

Uploaded files and recordings live in Cloudflare's storage, in its EU region. Identity documents arrive there already encrypted.

We make a backup every night, encrypted before it leaves the server. Daily copies are kept for 30 days and weekly copies for 90.

Companies that help us

Each one receives only what its job needs:

• Hetzner (Germany, servers in Finland): the servers and the backup storage.
• Cloudflare (United States): file storage, protection against attacks, and the gate in front of our staff tools.
• Stytch (United States): sign-in, including Google sign-in and passkeys.
• Stripe (United States, Irish company for Europe), including its own wallet Stripe Link: payments and payouts.
• Brevo (France): sending our email.
• Google Cloud (United States), which runs Vertex AI in the European Union: translation, search by meaning and the AI features you agreed to.
• Google Firebase (United States): push notifications.
• Google (United States): sign-in, and reading when you are busy if you connect a calendar. We never see the titles or details of your events.
• ntfy.sh: alerts about our own servers, such as disk space and backups. No personal data.

Where one of the companies listed above is outside the EU, the transfer rests on the European Commission's standard contractual clauses, on the EU-US Data Privacy Framework where the company is listed under it, or on another basis allowed by Articles 44 to 49 of the GDPR. We have a written agreement with each of them under Article 28.

Statistics and advertising tags

Four tags from other companies are ready. None of them runs until we switch them on, and we will update this policy when we do. They are Google Analytics and Google Ads from Google, the Meta Pixel from Meta, and the TikTok Pixel from TikTok. The Google in the list above is there for sign-in and calendars. These two Google tags are a separate matter, and this section covers them.

Once the tags are on, they send the pages you visit here, whether you signed up, and whether you paid and how much, so we can measure our ads. They never send your name, your email or your messages from us. In the EU, the EEA, the UK and Switzerland this happens only if you said yes to the cookie banner, and a no stops all of it. Everywhere else we do not ask. The cookie policy lists each tag.

Each company has a different role:

• Google Analytics counts visits for us. Google handles that data on our behalf and only as we tell it to.
• Google Ads tells Google which ad brought you here. Google decides for itself how it uses that data, under Google's privacy policy.
• Meta and TikTok. We and the company are joint controllers for one step: collecting the data on our site and sending it to them. Once it arrives, the company decides on its own what it does with it, under its own privacy policy.

For Meta and TikTok, the joint arrangement works like this:

• Each company's business terms, which we accept before we switch its tag on, say who does what under the GDPR for that one step.
• We tell you about it, here and in the cookie policy, and where the law needs your yes, we ask for it.
• The company handles your requests to see, correct, delete or move the data it keeps once it has received it.
• You can use your rights with us or with the company, as you prefer. If you write to us about data the company holds, we send your request on to them.

Meta's side is Meta Platforms Ireland. Its privacy policy is at facebook.com/privacy/policy and the arrangement itself at facebook.com/legal/controller_addendum. TikTok's privacy policy is at tiktok.com/legal/page/eea/privacy-policy.

Google, Meta and TikTok may move this data outside the EU. Google and Meta are listed under the EU-US Data Privacy Framework. TikTok says it relies on the European Commission's standard contractual clauses.

Cookies

Most of what we store on your device is needed for the service: signing you in, keeping you signed in, remembering your language, and spotting batches of fake accounts. Once we switch on the tags above, Google, Meta and TikTok also set cookies for statistics and advertising. In the EU, the EEA, the UK and Switzerland we ask before any of them loads, and a no keeps them off; everywhere else they load without asking. Every cookie is listed in the cookie policy, which also says how to change your answer.

How long we keep things

• A guest in a practice room: 1 day.
• Recently viewed profiles: 30 days.
• Recordings of sessions: 30 days.
• A closed account before it is erased: 30 days.
• Server logs: 90 days.
• Transcripts and translated captions: 6 months.
• Notifications, announcements and support requests: 12 months.
• Messages: 18 months.
• Files shared in a session: 24 months.
• Identity documents: 5 years after the relationship ends.
• The staff action record, suspensions and appeals: 7 years.
• Payment, booking and tax records: 10 years.

A nightly job enforces these. The law can require us to keep something longer, and an open dispute holds it until it is settled.

Getting a copy of your data

Ask for it in your settings and the system builds one file, in JSON, with the data we hold about you. It stays available for three days and is then removed, because a full copy of a person's data should not sit around.

Closing your account

You can close your account in your settings. Access stops at once.

For 30 days nothing is erased, so a closure by mistake can still be undone. After that we erase the identity behind the account: the name, the email address, the telephone number, the photo, the date of birth and the profile text. The email address is replaced by a meaningless value rather than removed, because records the law makes us keep, such as payment records and our own log of staff actions, cannot be edited once written.

Private messages you sent are deleted. Messages in a lesson room or a group chat are a shared record of that session, so they stay without your name against them and are deleted on the ordinary schedule for messages.

If a dispute is open or a paid session has not happened yet, erasure waits until the money is settled. The page tells you so.

Your rights

Under the GDPR you can:

• Ask what we hold about you, and get a copy (Articles 15 and 20).
• Correct what is wrong (Article 16). Much of it you can edit yourself.
• Have your data erased (Article 17), unless the law makes us keep it.
• Restrict or object to processing based on our legitimate interests (Articles 18 and 21).
• Withdraw consent at any time, for anything given by consent (Article 7). What was done before you withdrew stays lawful.

Write to legal@ollinter.com and we answer within the month the law allows.

Complaining to the authority

You can complain to a data protection authority: the one where you live, the one where you work, or the one where you think something went wrong. Because we are established in Estonia, the authority that supervises us is:

Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate)

Tatari 39, 10134 Tallinn, Estonia

Email: info@aki.ee

Telephone: +372 627 4135

You can complain whether or not you have written to us first.

If something goes wrong

We take measures to prevent, detect and limit a breach of personal data. If one happens, we tell the authority without undue delay and within 72 hours of becoming aware of it where the law requires, and we tell the people affected where the risk to them is high.

When the law asks us for data

We hand over personal data when a legal obligation, a court decision or a binding order from a competent authority requires it, and only as far as it requires.

Changes to this policy

We update this policy when the law, the platform, the companies we work with or the purposes change. The current version is always here, and when a change matters to you we tell you.