Privacy Policy

Effective Date: October 10, 2026

1. Who We Are

Effati Consulting AB ("Effati", "we", "us", "our") is a Swedish company based in Stockholm. We are the data controller for the personal data described in this policy: data processed when you visit https://effati.se (the "Website"), use our consulting services, or use a product we build and operate (our "Products"), including Hejobb, TryggMap and Lyra. All our Products handle customer data in the same way, described in section 2, and this policy applies to every current and future Product unless a Product states otherwise.

We process personal data in accordance with the EU General Data Protection Regulation (GDPR) and Swedish data protection law. Questions and requests: info@effati.se.

2. How We Handle Data in Every Product

  • Hosted in the EU. Our applications, databases and backups run on Amazon Web Services (AWS) in European Union regions. Data is encrypted in transit (TLS) and at rest.
  • AI processing in the EU, never for training. Where a Product uses AI (for example to read a CV, answer a question or draft a text), the models run on Amazon Bedrock and Google Cloud Vertex AI configured for EU processing. Under our agreements with these providers, prompts and outputs are not used to train or improve their models and are not shared with model developers. We do not train models on customer data either. The one exception today is the Lyra pilot (see section 10).
  • AI assists, people decide. AI output in our Products is a suggestion or a recommendation. We make no decision with legal or similarly significant effects about you by automated means (GDPR Article 22).
  • No selling, no advertising. We never sell personal data and do not use it for third-party advertising or advertising profiles. Our Products contain no advertising or ad-tracking SDKs.
  • Analytics only with consent. Product analytics (Amplitude, EU data centre) run only after you opt in, and events never contain your name, email or the content you create. Website cookies are described in our Cookie Policy.
  • Minimal accounts, no passwords. Products that need an account use sign-in with Google, LinkedIn or a one-time email link, so we never store a password. Products that do not need an account (such as TryggMap) do not ask you to create one.
  • Payments by Stripe. Card details go directly to Stripe and never reach our servers; we keep only a customer reference and the subscription record.
  • Certified providers, limited access. Our hosting, AI, analytics and payment providers hold SOC 2 and ISO 27001 certifications and act under data processing agreements. Access to production data is limited to the few people who need it to operate the service.

3. Data We Collect

Which of these categories apply depends on the Product and on what you choose to use. We collect no more than the feature needs.

  • Contact and account data: name, email address and profile picture received from your sign-in provider or entered by you; phone number and company details when you contact us or buy consulting services.
  • Content you provide: what you put into a Product so it can work for you: a CV and the profile fields derived from it, uploaded documents, chat messages and questions, business details such as an organisation number, and safety reports (a status and a time). Content is processed only to provide the feature you used.
  • Location data: only in TryggMap, only with your consent and the iOS location permission, and only at the moment you make a report or view the map (see section 10).
  • Payment data: for paid plans, your Stripe customer reference, plan, status and paid period. Card numbers are held by Stripe, not by us.
  • Technical data: IP address, browser or device type, operating system and server logs, as every web service receives. A Product without accounts may use a random, pseudonymous installation identifier to limit abuse. It identifies the installation, not you by name, and is not your Apple ID, advertising identifier or device serial number; data from the same installation can be linked to each other through it.
  • Usage analytics: with your consent, sanitised page routes and coarse product actions.
  • Support messages: your name, email address and message when you write to us or use a support chat.

4. Purposes and Legal Bases

Every use of personal data rests on a legal basis under GDPR Article 6:

  • Providing the Product or service you use (accounts, matching, answering questions, drafting texts, building a shared map, sending the emails a feature needs): performance of a contract, Article 6(1)(b). Where a Product has no account, our legitimate interest in operating it, Article 6(1)(f).
  • Precise location in TryggMap: your consent, Article 6(1)(a), given in the app before any location is read and withdrawable at any time.
  • Selling and managing paid plans: performance of a contract, Article 6(1)(b); bookkeeping: legal obligation, Article 6(1)(c).
  • Answering your messages, keeping the service secure, preventing abuse and improving the Products: legitimate interest, Article 6(1)(f).
  • Analytics and marketing communications: your consent, Article 6(1)(a).
  • Complying with the law: legal obligation, Article 6(1)(c).

5. Service Providers We Share Data With

We share personal data only with providers that help us run the Website and Products, under data processing agreements, and only what each task requires:

  • Amazon Web Services (EU regions): hosting, databases, backups and AI inference through Amazon Bedrock.
  • Google Cloud (Vertex AI, EU endpoint): AI processing such as reading documents and answering questions.
  • Google Workspace: sending sign-in links, digests and replies, and receiving the messages you send us.
  • Google and LinkedIn: sign-in, as independent controllers for your account with them.
  • Stripe: checkout, payments and subscription billing.
  • Amplitude (EU data centre): opt-in product analytics.
  • Apple: App Store distribution of our iOS apps; Apple Maps and Apple's geocoding service, which iOS calls directly to display maps and addresses.
  • OpenAI and ElevenLabs (United States): only in the Lyra pilot, for answering questions and for voice input, under data processing agreements that exclude training on your data.

Beyond this, we disclose personal data only if the law requires it, or in connection with a corporate transaction such as a merger, in which case this policy continues to protect your data and we will notify you of any change of controller.

6. International Transfers

Storage stays in the EU, and so does AI processing outside the Lyra pilot. Some supporting services involve providers established outside the EU/EEA: sign-in with Google or LinkedIn, email sent and received through Google Workspace, payments through Stripe, which may transfer payment data to the United States, and, during the Lyra pilot, OpenAI and ElevenLabs in the United States. For every such transfer we rely on the safeguards in GDPR Chapter V: adequacy decisions (Article 45), including the EU–U.S. Data Privacy Framework for certified providers, and Standard Contractual Clauses (Article 46) with supplementary measures where needed. Only what the specific task requires is transferred. You can request a copy of the safeguards for a specific transfer at info@effati.se.

7. How Long We Keep Your Data

  • Account data and content you provide: while your account or the Product you use is active. When you delete your account or ask us to delete your data, it is erased and residual copies are removed from backups within 90 days.
  • Content in Products without accounts: for as long as the Product operates, or until you ask us to delete it.
  • Support messages: 12 months, then deleted.
  • Payment and accounting records: seven years, as the Swedish Bookkeeping Act (bokföringslagen) requires, even if your account is deleted.
  • Server logs: up to 30 days.
  • Analytics data: only while your consent is active.

8. Your Rights

Under the GDPR you have the right to:

  • access the personal data we hold about you and receive a copy;
  • have inaccurate data corrected;
  • have your data erased;
  • restrict processing while a question is resolved;
  • receive your data in a machine-readable format;
  • object to processing based on legitimate interest;
  • withdraw consent at any time, without affecting processing that took place before.

To exercise any of these rights, email info@effati.se (for Hejobb, you can also use privacy@hejobb.com). We answer within one month and the request is free of charge. If you believe we handle your data unlawfully, you can lodge a complaint with the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY, imy.se) or with the supervisory authority where you live or work in the EU.

9. Security and Children

All traffic to our Website and Products is encrypted with TLS, stored data is encrypted at rest, sign-in uses OAuth or single-use email links, and session tokens are stored only as cryptographic hashes. No system is perfectly secure; if a breach ever puts your rights at risk, we will notify you and IMY as the GDPR requires.

Our Products are not directed at children under 16 and we do not knowingly collect data from them. If you believe we have, contact us and we will delete it.

10. Product-Specific Notes

Everything above applies to every Product. The notes below add only what is particular to one Product.

Hejobb (hejobb.com)

Hejobb matches your CV with job openings from Swedish universities and Arbetsförmedlingen. You sign in with Google, LinkedIn or an email link. Your CV is converted to text and read by AI on Vertex AI and Amazon Bedrock in the EU to fill your profile, compute matches and, when you ask, draft cover letters; the original file is deleted as soon as processing finishes. Optional Pro plans are billed by Stripe. Hejobb publishes a detailed privacy policy at hejobb.com/privacy, which takes precedence for Hejobb where it is more specific than this policy. Privacy contact: privacy@hejobb.com.

TryggMap (iOS app)

TryggMap lets you report a place as safe or unsafe, from the app or from iOS lock screen controls, and shows a shared map built from all reports. It has no account. Report data is sent to our server only when you submit a report: the status you chose (safe or unsafe), the time, and, if you have consented in the app and allowed location access in iOS, the precise location and accuracy of your device at that moment. Submitting any report requires your consent in the app; without iOS location access, or when no position is available within five seconds, the report is sent without a location. A random, pseudonymous installation identifier created by the app is sent with reports to limit repeated submissions (at most five per place per 24 hours); it links reports from the same installation to each other, not to you by name.

The app asks for location access only "While Using the App", never "Always", and does not track you in the background; a lock screen control reads the location only at the moment you tap it. Withdraw consent at any time under Location in the app menu, and change the iOS permission in Settings → Privacy & Security → Location Services → TryggMap. Withdrawing consent stops all future location collection and disables reporting until you consent again.

The map shows reports only in aggregated form, as counts per map cell or street segment; it never shows individual reports, their times or identifiers. Viewing the map sends no report or location data to us, only a request for aggregated counts for the visible map area, which carries the technical data described in section 3. Your own position on the map is processed on your device. Reports are kept for as long as TryggMap operates, so the map reflects the history of a place, or until you ask us to delete them; a copy of your own reports stays on your device until you delete the app. To access or delete your reports, email us from About → Contact Effati about privacy in the app and include the report ids shown under Your reports, or the approximate places and times.

Lyra (tax assistant, in pilot)

Lyra answers questions about Swedish tax and accounting and is currently used by a limited number of pilot participants. It processes the questions you ask, the documents you upload, voice input when you use the microphone, and the business profile you enter, such as an organisation number and VAT period. During the pilot, questions and document text are processed by OpenAI and voice input by ElevenLabs, both in the United States, under data processing agreements and the safeguards in section 6; Lyra will move to the EU providers described in section 2 before it opens to the public. Lyra gives information, not tax advice, and files nothing on your behalf. Pilot participants are also covered by their pilot agreement. Before Lyra opens to the public, this policy will be updated with any details specific to the launched service.

11. Updates to This Policy

We update this policy when our services or the law change. The date at the top shows the current version. Before a material change takes effect, such as a new category of data or a new AI provider, we will notify you in the Product or by email.

12. Contact Us

  • Effati Consulting AB, Stockholm, Sweden
  • Email: info@effati.se
  • Phone: +46 73 222 66 27
  • Website: https://effati.se