Privacy Policy

Zitado is provided by:

Camonda ApS (registered secondary name: ZELLERT ApS) Søndergade 3, 1. 7830 Vinderup Denmark Danish company registration number (CVR): 43532421 Email: info@zitado.com Telephone: +45 71 99 09 25

You can use this email address for privacy questions and requests concerning your personal data. Existing customers should normally submit product-support requests through Zitado's in-app support function.

Camonda ApS (registered secondary name: ZELLERT ApS) acts as an independent data controller when it determines the purposes and means of processing for its own business activities. These include website visits, enquiries, sales communications, account administration, subscription management, billing, security and our own marketing.

The customer organisation is generally the data controller when it uses Zitado to maintain information about its employees, teams, Ai tools, use cases, training, controls, tasks and compliance documentation. In that context, ZELLERT acts as a data processor, handling personal data on the customer's instructions under a data processing agreement (DPA). The customer determines what lawful information is entered, who may access it and how it is used.

If you have been added to Zitado by your employer or another organisation, that organisation will normally be your first point of contact for requests about access, correction or erasure of the information it controls. We assist the organisation under the DPA. We respond directly to requests relating to processing for which ZELLERT is the controller.

Depending on your interaction with Zitado, we may process:

• Contact and business information: your name, work email address, telephone number, company, job role and the contents of your enquiry.
• Account and access information: user identifier, email address, organisation and role, authentication information and necessary security events. Authentication is managed through our sign-in service; you should never send us your password in a support request.
• Subscription and billing information: selected plan, invoicing details, transactions and payment status. Card payment information is processed through Stripe where that payment method is used.
• Support information: messages, case categories, relevant screenshots and technical details you provide or which are necessary for troubleshooting.
• Public screening information: answers submitted through Zitado's Ai Act screening, the associated outcome and, where relevant, a connection to a subsequent account sign-up. A token may be used to retrieve a screening result.
• Technical information: IP address, browser and device details, timestamps, visited pages, error and security logs, and information from necessary browser-storage technologies.
• Analytics and advertising information – subject to applicable consent: online identifiers, visit events, campaign parameters, conversion events and information collected by optional analytics or advertising tools. See our Cookie Policy.
• Newsletter details – following a separate sign-up: email address, subscription/consent status and any additional information you choose to provide.

When a customer uses the authenticated platform, it may also enter ordinary personal data concerning employees and other responsible individuals, such as names, business email addresses, teams, roles, assignments, training status and information appearing in documents or free-text fields. These are generally processed on the customer's instructions and are not used as ZELLERT's own advertising database.

We receive information directly from you or from the organisation creating your account. Public screening answers are provided by the person completing the screening.

For information we process solely as a processor for a customer, the customer identifies its own lawful basis. That processing is governed by the customer's instructions and our DPA, not by consent for Zitado's own marketing.

Some information is required to create an account, make a payment or respond to a request. Without it, the specific service cannot always be provided. Optional analytics, marketing cookies and newsletter subscriptions are not required to use Zitado.

Zitado is intended for ordinary business and governance information. Customers must not enter or upload Danish civil registration numbers, health information, biometric information, political or religious beliefs, trade-union membership, information about sexual life or orientation, other special categories of personal data, or data relating to criminal offences.

If such information has nevertheless been uploaded, the customer should contact Zitado so that it can be handled appropriately under the applicable law and agreements.

Zitado's ordinary registration, documentation and administrative functions are intended to be available without automatically sending customer data to an external generative Ai model.

Zitado’s Ai functions are optional. Access depends on the plan, trial and any add-ons. An authorised user must request generation, and processing on the Customer’s behalf must fall within the Customer’s documented instructions. Plan access, payment or activation is not itself such an instruction. Ordinary registration and administration do not automatically trigger these generations.

For document drafts, Zitado sends relevant context about the organisation, tools, use cases, screening, controls and follow-up, including free text, to OpenAI. The policy generator sends reviewed text sections in which the browser has replaced known identifying information with placeholders where possible. The substitution list and document basis are sent to Zitado’s server but are not included as such in the model input. The server restores known names and saves the result as a draft. Bounded or partly pseudonymised input may still contain personal data. The Customer’s user must review the result before approval, publication or use.

Optional Ai training generation sends a bounded source containing the tool name, use-case title and description, registered data types, permission status and conditions, selected applicable rules and the administrator’s training options to OpenAI. Employee answers, scores, profiles and training history are excluded from this model input. The result is saved as an inactive draft that requires human review before publication and assignment. Free text may still contain personal information.

We use OpenAI Ireland Ltd. for the optional Ai features described here under a data processing agreement. The account uses global standard retention, and optional data sharing is disabled. API input and output are not used for model training by default without a separate opt-in, which ZELLERT does not enable for Customer content. The supplier’s security logging may generally cover up to 30 days, subject to the exceptions in its terms. The store: false setting is not the same as zero retention.

Zitado is a documentation and decision-support tool. It does not, on its own behalf, make decisions about individuals that produce legal or similarly significant effects solely through automated processing. Customers must assess their own use of the platform and any automated decisions they make.

Processing on the Customer’s behalf is further described in the Data Processing Agreement with Annexes A–D, including the subprocessor register. Separate Customer agreements and restrictions continue to apply. Publishing the standard agreement is not the Customer’s acceptance of it or an extension of the Customer’s Ai instructions.

We use suppliers and partners where necessary to deliver Zitado or functions you have selected:

A recipient's data-protection role may depend on the service and purpose. Some providers act as processors; others may act as independent controllers for defined processing activities. Where permitted or required, necessary information may also be disclosed to accountants, professional advisers or authorities.

We use an EU region for Zitado's Supabase production database. EU database hosting does not mean that all support access, operational logs, payments, content delivery, analytics or other processing necessarily takes place only within the EU/EEA.

Where personal data is transferred to, or made accessible from, a country outside the EU/EEA, there must be a lawful transfer mechanism. Depending on the supplier, this may be a valid European Commission adequacy decision (including the EU–US Data Privacy Framework for a certified recipient) or the European Commission's Standard Contractual Clauses, together with any supplementary safeguards that are necessary. You can contact us for more information about the relevant mechanisms.

The primary database is located in Frankfurt (eu-central-1), and web hosting uses the Frankfurt region (fra1). Separate backups use Hetzner in Germany and an R2 bucket with EU jurisdiction. These regional choices do not automatically cover every supplier’s account, log, support and security processing.

We retain information only for as long as needed for the relevant purpose or required by law.

The following retention and deletion periods apply. A separate customer agreement with a stricter deletion deadline applies to that customer's data.

Earlier erasure requests are handled under the applicable rules and customer instructions. A specific legal obligation or necessary legal claim may justify longer retention of limited information; this does not automatically extend every period. A user account may relate to several organisations, which must be handled separately. Retention by OpenAI and analytics/marketing providers depends on the specific data flow. A stated period for one feature or data category is not a common deletion deadline for every supplier copy.

A separately agreed overall deletion deadline covers all relevant recoverable copies of the Customer’s information. ZELLERT must plan return, active deletion and expiry or removal of backup and provider copies within that deadline. The Customer’s agreed export access must not be shortened unilaterally to make the deletion schedule fit. A shorter export period or other change to the exit arrangements requires the Customer’s agreement. Support, emails and logs containing information processed on the Customer’s behalf must be included in the plan; a generally longer retention period must not override a stricter customer agreement. Only specifically identified information with an independent lawful retention basis may be excepted. On completion, ZELLERT must be able to explain the deletion performed and any remaining information, its basis and its deadline.

Return and deletion are handled through a documented procedure covering each relevant data category. For each case, ZELLERT records the Customer’s instructions, export access, affected systems and copies, and applicable deadlines. An export may be provided manually to a verified, authorised recipient; a payment restriction must not itself prevent the Customer’s agreed export access. Deletion of active information and recoverable residual copies is documented separately. A shorter customer-specific deadline takes precedence over general retention periods.

Zitado stores campaign attribution for at most 30 days from the first recorded campaign visit and stores only a screening access token with lifetime metadata for at most 30 days from the original screening start. Expired local records are removed on the next visit/read. This does not delete screening results or other server data.

Where ZELLERT is the controller of your personal data, you may have the right under the GDPR, depending on the circumstances, to:

• receive information about and access your personal data;
• have inaccurate information corrected;
• have information erased or its processing restricted where the conditions apply;
• object to processing based on legitimate interests;
• receive data portability where the GDPR applies;
• withdraw consent at any time, without affecting processing lawfully carried out before withdrawal; and
• object to direct marketing.

Email info@zitado.com. We may ask for information necessary to verify your identity. We normally respond within one month and will notify you where a GDPR-permitted extension is required.

Where a customer organisation is the controller of information about you in Zitado, please normally contact that organisation first. We assist it with responding to requests.

You may also lodge a complaint with the Danish Data Protection Agency (Datatilsynet) or another competent data protection authority in the EU/EEA.

We apply technical and organisational measures proportionate to the risks, including access controls, authentication, role-based permissions and secure communications. No online service can promise absolute security. If you suspect unauthorised access or a security incident, please contact info@zitado.com.

We will never ask you to email us your password.

Creating a Zitado account does not by itself subscribe you to a newsletter. Newsletters and similar consent-based email marketing require a separate sign-up. You can unsubscribe using the link in a message or by contacting us.

Necessary technologies help operate the platform. Any activation of optional analytics and marketing technologies requires a separate cookie choice. You can update these choices using Cookie settings and find details in the Cookie Policy.

We may update this policy when our service, providers or legal requirements change. The current version and revision date are shown here. We will provide additional notice of material changes where required.