At Trailed AB ("Deem", "we", "us"), we are committed to handling personal data with care and transparency. This Privacy Policy explains how we process personal data when we act as controller in connection with our website, customer relationships, user accounts, communications, support, security, administration and related business activities.
1 Who We Are
Trailed AB, reg. no. 559573-4194, Nordenskiöldsgatan 11A, 211 19 Malmö, Sweden, is the controller for the processing described in this Privacy Policy. You can contact us at privacy [at] deem.inc.
2 When This Privacy Policy Applies
This Privacy Policy applies where Deem determines the purposes and means of processing personal data, for example when we process personal data about users of the Service, customer representatives, prospects, website visitors, support contacts, suppliers, partners and job applicants.
Deem provides an AI-powered customer success service to business customers (the “Service”). When our customers use the Service to process data from their own systems, Connected Accounts, CRM records, communications, support records, product usage data or generated outputs, the customer is the controller and Deem acts as processor under the applicable Data Processing Agreement (“DPA”). This Privacy Policy does not replace that customer’s privacy notice or the DPA.
If you are a customer, contact, employee or user of one of our customers, please contact that customer for information about how it uses your personal data and how to exercise your rights. If you contact us about such processing, we will refer the request to the relevant customer and assist the customer as required by the DPA.
3 Personal Data We Process as Controller
The personal data we process depends on your relationship with us and how you interact with Deem.
| Registered category | Examples of personal data |
|---|---|
| Customer representatives and Service users | Name, work email, role, employer/customer organization, user ID, account ID, workspace/team information, authentication and access-rights information, admin settings, approval history, service communications, support communications and activity, audit, diagnostic and security logs. |
| Prospects and business contacts | Name, work email, phone number, role, employer, communication history, meeting/demo information, CRM notes, preferences, lead source and other information you or your organization provide to us. |
| Website visitors | IP address, browser and device information, cookie identifiers, pages visited, referrers, approximate location derived from technical data, cookie choices and information submitted through website forms. |
| Support contacts | Contact details, account or organization information, support request content, screenshots or other material you choose to provide, troubleshooting information and related communications. |
| Suppliers, partners and advisors | Business contact details, role, organization, contractual and communication information, invoicing and payment administration information. |
| Job applicants | Contact details, CV, application materials, interview notes, references and other information provided during a recruitment process. |
| Users of the Deem application | When you use the Deem application, we collect information about how you use it: your user and workspace identifiers, your role, the pages and features you use and when, device and browser information, error reports (without message content) and recordings of your sessions in which all text and input fields are masked. |
We do not intentionally collect special categories of personal data or data relating to criminal convictions for the controller purposes described in this Privacy Policy. Please do not provide such data to us unless we specifically request it and there is a lawful basis for the processing.
4 Purposes and Legal Bases
We process personal data for the following purposes and on the following legal bases under the GDPR.
| Purpose | Personal data normally used | Legal basis |
|---|---|---|
| Providing and administering user accounts and access to the Service | Customer representative and Service user data, including account, authentication, access-rights and activity data. | Performance of contract (Art. 6(1)(b)). |
| Managing customer relationships and agreements | Business contact details, role, organization, contract and communication information. | Performance of contract (Art. 6(1)(b)) and legitimate interests in managing B2B relationships (Art. 6(1)(f)). |
| Responding to demo requests, inquiries and other communications | Prospect/contact details, inquiry content, meeting information and communication history. | Legitimate interests in responding to requests and developing business relationships (Art. 6(1)(f)). |
| Providing customer support and troubleshooting | User/account data, support communications, screenshots or information you provide, diagnostic logs and related technical data. | Performance of contract (Art. 6(1)(b)) and legitimate interests in supporting and improving the Service (Art. 6(1)(f)). |
| Product analytics and improving the Service | User and workspace identifiers, role, product usage events, device and browser information, error reports, masked session recordings. | Legitimate interests in operating, troubleshooting and improving the Service (Art. 6(1)(f)). You can object at any time; see section 10. |
| Security, abuse prevention, audit logging and incident response | Technical, usage, support, diagnostic, audit and security logs; account and access-rights information. | Legitimate interests in securing the Service and protecting Deem, customers and users (Art. 6(1)(f)); legal obligations where applicable (Art. 6(1)(c)). |
| Service communications | Name, work email, role, organization and account information. | Performance of contract (Art. 6(1)(b)). |
| Website operation, analytics and cookie management | Technical data, cookie identifiers, usage data and cookie choices. | Legitimate interests for essential website operation and security (Art. 6(1)(f)); consent for non-essential cookies where required (Art. 6(1)(a)). |
| Invoicing, accounting and legal administration | Business contact details, billing information, contract records, payment administration information and related correspondence. | Legal obligations (Art. 6(1)(c)), performance of contract (Art. 6(1)(b)) and legitimate interests in managing legal and financial administration (Art. 6(1)(f)). |
| Recruitment | Application materials, contact details, interview notes, references and recruitment communications. | Legitimate interests in managing recruitment (Art. 6(1)(f)); consent where required. |
We do not sell, trade or rent personal data. We do not use personal data for third-party advertising, and we do not use personal data to train or fine-tune general-purpose AI models.
Automated decisions. Deem does not use personal data for automated decision-making in its controller role that produces legal effects concerning you or similarly significantly affects you within the meaning of Article 22 GDPR.
5 Sources of Personal Data
We normally collect personal data directly from you, from your organization, from your use of our website or Service, from communications with us, or from business tools used to manage customer relationships, support, billing, security and recruitment. We may also receive business contact information from publicly available sources, referrals, events or partners where this is relevant to a business relationship.
6 Who Can Access or Receive Personal Data
We limit access to personal data to personnel, contractors and advisors who need access for the purposes described in this Privacy Policy and who are subject to confidentiality obligations.
We may share personal data with suppliers and service providers that help us operate our business, website and Service, including providers of hosting and infrastructure, authentication, customer relationship management, support, analytics, security, communications, finance, legal, accounting and recruitment tools. These providers may only process personal data for the purposes we instruct, unless they act as independent controllers for a specific service.
Your organization’s account administrators and other authorized users may access certain account, usage, support or workspace information where necessary to administer the customer relationship and use of the Service.
We may disclose personal data where required by law, court order, supervisory authority request or other legally binding request, or where necessary to protect the rights, safety or property of Deem, our customers, users or others. Where lawful and appropriate, we will seek to notify the relevant affected party.
If Deem is involved in a merger, acquisition, financing, restructuring or sale of assets, personal data may be transferred or reviewed under appropriate confidentiality and security protections. Any resulting processing will continue to be subject to applicable data protection law.
7 International Transfers
We primarily process and store personal data in the European Union. Some suppliers or service providers may be established outside the EEA or may access personal data from outside the EEA. Where personal data is transferred outside the EEA, we use appropriate safeguards such as an adequacy decision, the EU–U.S. Data Privacy Framework, the European Commission’s Standard Contractual Clauses and supplementary measures where appropriate.
8 Retention
We keep personal data only for as long as necessary for the purposes for which it was collected, unless a longer retention period is required or permitted by law. Retention periods vary depending on the type of data and the context.
| Data category | Typical retention |
|---|---|
| Customer representative and Service user data | For the duration of the relevant customer relationship and user account, and thereafter as needed for administration, security, legal claims or statutory retention obligations. |
| Support and communication records | For as long as needed to handle the matter and maintain appropriate business records, unless longer retention is needed for security, legal or compliance reasons. |
| Security, diagnostic and audit logs | For the period necessary for security monitoring, troubleshooting, audit and incident response, unless longer retention is needed for an ongoing investigation or legal reason. |
| Marketing and prospect data | Until you opt out or the data is no longer relevant for the business relationship, subject to applicable law. |
| Website and cookie data | For the periods described in the cookie banner or cookie settings, or for as long as necessary for website security and operation. |
| Accounting, invoicing and contract records | For the period required by applicable accounting, tax and limitation laws. |
| Recruitment data | For the recruitment process and a reasonable period thereafter, unless longer retention is required or permitted by law or you consent to longer retention. |
| Product analytics data | Product analytics data is kept for up to 12 months, and session recordings for up to 30 days, after which they are deleted. |
The DPA and customer agreement govern retention, export and deletion of customer personal data that Deem processes as processor. Those processor retention mechanics are not described in detail in this controller-focused Privacy Policy.
9 Security
We use technical and organizational measures designed to protect personal data against unauthorized or unlawful processing and against accidental loss, destruction or damage. These measures include, as applicable, encryption in transit and at rest, access controls, role-based least-privilege access, multi-factor authentication, logging and monitoring, tenant-level isolation for the Service, supplier due diligence and incident response procedures. Additional information is available in our Security & Data Protection Overview at https://deem.inc/legal/security.
10 Your Rights
Depending on the circumstances and applicable law, you may have the right to request access to your personal data, rectification, erasure, restriction of processing, data portability, objection to processing based on legitimate interests, and withdrawal of consent where processing is based on consent.
To exercise your rights in relation to Deem’s controller processing, contact us at privacy [at] deem.inc. We will respond without undue delay and in any event within the time limits required by applicable law, normally within one month.
If your request concerns personal data processed by one of our customers as controller, please contact that customer directly. If you contact us, we will refer the request to the relevant customer and assist it as required by the DPA.
You may lodge a complaint with a supervisory authority. In Sweden, the supervisory authority is the Swedish Authority for Privacy Protection (IMY), www.imy.se.
11 Cookies
Our website and application use essential cookies and similar technologies for session management, security and basic functionality. We may also use non-essential analytics cookies to understand aggregate usage and improve our website and Service, where permitted by law and subject to your cookie choices. We do not use advertising cookies unless expressly stated in the cookie banner. You can manage non-essential cookies through the cookie banner or cookie settings.
12 Children
The Service is a business tool and our website and Service are not directed at children. We do not knowingly collect personal data from children.
13 Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Material changes will be notified by appropriate means, such as email, in-app notice or website notice, and will be reflected in the “Last updated” date above.
14 Contact
Trailed AB
Nordenskiöldsgatan 11A, 211 19 Malmö, Sweden
privacy [at] deem.inc
https://deem.inc