Privatlivspolitik - SkrivSikkert

Privacy Policy

A complete overview of how we protect your data.

Hosting: Denmark & Sweden
Contact: gdpr@spellbright.ai
Updated: November 2025
Privacy by Design

SkrivSikkert ApS implements privacy-by-design principles by collecting minimal personal information.

No Data Storage
No personally identifiable information, session data, or user profiles stored permanently
Local Browser Processing
All user data remains in local browser memory without server-side storage
Anonymization
Encrypted anonymous identifiers with no reverse-engineering possible
EU Jurisdiction
All data processing within EU borders (Denmark + Sweden)

Frequently Asked Questions

No, our AI models are not trained on your data. This is documented in our privacy policy under "Transparency in AI Use": "Prompts or other text generated through the platform are not used to train or improve the models."

This means when you use our tools to translate, summarize, or proofread copyrighted material, the text is:

  • Only used to deliver the immediate service
  • Not part of the model's training data
  • Not accessible to other users
  • Automatically deleted after processing

You can safely use all our tools with copyrighted material without concern for copyright infringement.

All your data stays within EU borders:

  • Web Hosting: Denmark (with Simply.com)
  • AI Processing: Sweden (Microsoft Azure OpenAI data center)
  • No data transfers to countries outside the EU

Yes, SkrivSikkert is fully GDPR-compliant. We:

  • Operate under Danish and EU data protection law
  • Have a dedicated Data Protection Officer (DPO)
  • Use only GDPR-certified partners (Simply.com and Microsoft Azure OpenAI)
  • Have completed a data protection impact assessment
  • Implement privacy-by-design principles
  • Comply with all GDPR requirements for data minimization, pseudonymization, and user rights

We're recommended for Danish educational institutions, which highlights our focus on safe use in the education sector.

  • SkrivSikkert ApS: Does NOT have access to your prompts or AI-generated outputs
  • Microsoft Azure OpenAI: Processes data only to deliver the service - no access during normal operation
  • Other Users: Have NO access to your data

We have comprehensive data breach procedures:

  • Immediate assessment of breach scope
  • Notification to the Data Protection Agency within 72 hours
  • Direct communication to affected users
  • Implementation of measures to limit consequences
  • Thorough investigation and preventive action

However: Due to our data minimization practices (no permanent storage of prompts/outputs), the risk of a meaningful data breach is extremely low, as we simply don't have data to lose.

We have comprehensive security measures in place:

Technical Measures:

  • Encryption of data during transmission and storage
  • Anonymization through encrypted identifiers
  • Multi-factor authentication for sensitive system access
  • Regular security updates
  • Automatic content filters and abuse monitoring

Organizational Measures:

  • Strict access controls
  • Ongoing staff training in data protection
  • Regular security assessments and audits
  • Dedicated Data Protection Officer (DPO)

We designed our platform specifically with the education sector and protection of minors' data in mind:

No Personal Identification:

  • No user logins on the main platform
  • No collection of personally identifiable information
  • Complete anonymity for all users

Local Data Processing:

  • All user activity processed only in browser's local memory
  • Data doesn't leave the user's device (except encrypted AI communication)
  • Automatic deletion at session end

Special Considerations for Minors:

  • No profiling or tracking of user behavior
  • No risk of students' work becoming visible to others
  • Teachers and students can use the tool without GDPR concerns

This ensures the platform can be used safely in all educational contexts, from elementary school through higher education.

Introduction and Principles

Introduction

This privacy policy describes how SkrivSikkert ApS ("Skrivsikkert.dk," "us," "our," "we") protects and processes your personal data when you use our services through our website for grammar correction, translations, and general interactions with the AI models we offer. We handle your personal data in line with this privacy policy and applicable law, including the EU's General Data Protection Regulation (GDPR) and the Danish Data Protection Act. Skrivsikkert.dk is the data controller for your personal data, and questions about personal data can be directed to us using the contact information provided later in this document.

At SkrivSikkert.dk, we designed our platform in line with GDPR (Regulation No. 2016/679 of April 27, 2016) and the Data Protection Act. This commitment is an ongoing process where we dedicate ourselves to developing our services with a focus on data protection and user privacy.

Our primary goal is to respect and protect our users' privacy. For this reason, we've made the decision not to require user logins or identify users in any way. This means we don't collect, log, or store any data that can be linked to users' personal identity or their activity on SkrivSikkert.dk. Our approach ensures your interactions with our platform remain private and secure. We made this decision in part because we're used by schools and other public institutions in educational settings.

The application you interact with is built in WordPress and hosted on a web server with the Danish-owned company Simply. The web server is located in Denmark and is GDPR-certified. Our language model is developed by Microsoft (Azure OpenAI), and our data center is located in Sweden. Therefore, no data transfer occurs to countries outside Europe.

When you submit a request through our service, your information is processed in a way that protects your privacy. Your requests are converted into an "anonymous identifier," which is an encrypted code that ensures we cannot track or store information about what you asked. This secure process means we don't store or monitor the session where your request is processed. Everything you do on our platform is stored locally on your device in your web browser and is accessible only to you. This ensures your data stays private and is automatically deleted when you leave our site. We guarantee your data security and protect your privacy this way.

Agreements with Schools

We offer business agreements for schools that want to integrate SkrivSikkert into their teaching. If you're interested in exploring how SkrivSikkert can support learning in your classroom or help students with dyslexia, don't hesitate to contact us at hello@spellbright.ai for more information. Our focus on making SkrivSikkert safe to use in education can be seen in how we're recommended by the Center for IT in Education (CIU) to all directors at vocational schools and high schools across the country.

Learn more about our prices for business subscriptions for schools on our business order page. For orders of over 100 subscriptions, we offer special pricing. Contact us at hello@spellbright.ai or +45 36 20 97 37 for a customized quote.

Data Processing and Security

Anonymity

All your interactions with our AI models, including entered text (prompts) and generated responses, are processed anonymously and stored only temporarily in your browser's local memory. This data is automatically deleted when you close your browser session, ensuring no personally identifiable data is stored on our servers.

Security Measures

We have implemented comprehensive security measures, including:

  • Encryption of data during transmission and storage.
  • Various access controls and security protocols to protect against unauthorized access.
  • Regular security assessments and audits to ensure our systems and procedures comply with the latest GDPR requirements and the upcoming AI regulation.
  • Procedures for rapid system and data recovery in case of a technical or physical incident.
  • Regular security updates to our systems.
  • Multi-factor authentication for access to sensitive systems.
  • Ongoing training for our staff in data protection and security.

Data Centers

Our LLM model is located in Sweden, ensuring all data remains within EU jurisdiction and is subject to GDPR's strict protection requirements. We guarantee your data is not transferred to countries outside the EU. All data processing occurs exclusively within EU borders, specifically in Denmark (hosting) and Sweden (AI processing).

Sub-Processors

We work only with carefully selected and GDPR-compliant sub-processors, including Microsoft (Azure OpenAI) for our AI services. All our sub-processors are required to maintain the same high standards for data protection as we do.

Data Confidentiality and Security

Your data when using the AI tools is processed with strict confidentiality and security protocols. This data:

  • Is not accessible to other customers.
  • Is not accessible to OpenAI.
  • Is not accessible to SkrivSikkert employees.
  • Is not used to improve OpenAI models.
  • Is not used to improve Microsoft's or third parties' products or services.
  • Is not automatically used to improve Azure OpenAI models.
  • No data transfer occurs to jurisdictions outside the EU.

Data Storage and Deletion

To comply with abuse monitoring, Azure OpenAI (Microsoft) may store prompts and generated content securely and encrypted for up to thirty (30) days. SkrivSikkert.dk has no access to read your data during this monitoring period. The stored data can only be made accessible to a Microsoft employee who has undergone a comprehensive security clearance process and is employed within the EU.

A review of this data can only occur if either a prompt or generated output is automatically identified as potentially harmful by Microsoft's automatic content filters. Only then can the flagged data be reviewed. All data is permanently deleted after the monitoring period. This data is also not linked to the sender's IP address or anything else that is personally identifiable.

Data Minimization

We take the principle of data minimization very seriously. This means we only collect and process the personal data absolutely necessary to deliver our services. Our approach to data minimization includes:

  • Limited Data Collection: We collect no personally identifiable data.
  • Anonymization: Where possible, we anonymize data to remove personally identifiable information.
  • Automatic Data Deletion: We've implemented automatic processes to delete data that is no longer necessary.
  • Regular Data Review: We regularly review our data stores to identify and remove unnecessary data.
  • Privacy by Design: Our systems are designed from the ground up with data minimization in mind, ensuring we only process data absolutely necessary for each specific function.

Data Retention Periods

We have clear policies for data retention to ensure we only keep data as long as necessary. Our data retention periods are as follows:

AI Interactions (Prompts and Outputs)

  • Not stored by SkrivSikkert.
  • Automatically deleted from our systems at the end of each browser session
  • May potentially be stored by Microsoft Azure OpenAI for up to 30 days as part of their security procedures, but this data is not accessible to us and is reviewed only in extremely rare cases
  • This data is not linked to personal identifiers such as IP addresses.

We regularly review our data retention practices to ensure we comply with GDPR's storage limitation principle. If you have specific questions about storage of your data, you're welcome to contact our DPO.

Rights and Legislation

Your Rights

As a user, you have rights under GDPR, including:

  • Right of access to your personal data
  • Right to rectification of inaccurate personal data
  • Right to erasure ("right to be forgotten")
  • Right to restriction of processing
  • Right to data portability
  • Right to object to processing of your personal data

To exercise your rights or if you have questions about our data protection practices, you can contact our Data Protection Officer (DPO) at gdpr@spellbright.ai.

Please note that due to our limited data retention, we cannot provide access to historical prompts or AI-generated content. We can only give you access to data you've shared directly with us through, for example, our contact form. You can withdraw your consent at any time by contacting our DPO.

Note that withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Additional Details on Consent Processes

  • We only obtain consent through active actions, never through pre-checked boxes.
  • We keep documentation of given consent, including time and content.
  • You can withdraw your consent at any time through your account profile or by contacting our DPO.
  • We renew consent if our data processing purposes change significantly.

Data Portability

To exercise your right to data portability, you can request a copy of your personal data in a structured, commonly used, and machine-readable format. We will fulfill your request within 30 days.

GDPR and Legal Compliance

Our use of Azure OpenAI Service and our general data processing practices ensure full compliance with GDPR and other relevant data protection legislation. This is achieved through the following measures:

  • Data is processed in accordance with Microsoft's Products and Services Data Protection Addendum, which is fully GDPR-compliant.
  • All data storage and processing occurs exclusively on a European data center in Sweden, guaranteeing compliance with European, including Danish, data protection requirements
  • Users have full control over their data, including the right of access, rectification, erasure ("right to be forgotten"), restriction of processing, data portability, and the right to object.
  • We implement various security measures, including encryption of data during transmission and storage, as well as strict access controls.
  • All user interactions with our AI models are processed anonymously, and data is stored only temporarily in the user's browser's local memory, ensuring maximum protection of personal data.
  • We do not transfer personal data to countries outside the EU.
  • We conduct regular security assessments and audits to ensure continued compliance with GDPR and other relevant data protection rules.
  • In case of a data breach, we have implemented procedures for rapid notification to both the data controller and affected data subjects.
  • We work only with carefully selected and GDPR-compliant sub-processors who are required to maintain the same high standards for data protection.

Platform and Technical Details

To ensure data remains within the EU, we use the following:

  • Use of data centers located exclusively within the EU
  • Implementation of technical restrictions that prevent data transfer outside the EU
  • Regular auditing of data flows to ensure compliance
Risk Assessment and Decision-Making

Initial Data Protection Impact Assessment

As part of our commitment to ensuring the highest standard of data protection, we have conducted an initial data protection impact assessment for our AI-based service. This analysis helped us evaluate potential risks associated with our data processing activities.

The result of our initial analysis showed that our current data processing activities do not require a full Data Protection Impact Assessment (DPIA) according to GDPR criteria. This is primarily due to:

  • Our limited retention of personal data
  • The absence of automated decisions with significant impact on users
  • Our implemented security measures and data minimization practices

We have specifically assessed that our service does not fall under the categories that typically require a full DPIA, as we:

  • Do not conduct systematic and extensive evaluation of personal aspects based on automatic processing, including profiling.
  • Do not process special categories of data (sensitive data) on a large scale.
  • Do not conduct systematic monitoring of a publicly accessible area on a large scale.

Nevertheless, based on our analysis, we have implemented and improved a range of measures to minimize potential risks:

  • Strengthened encryption methods for data in transit and at rest
  • Strict access control policies
  • Regular staff training in data protection
  • Continuous monitoring and updating of our security measures

We commit to regularly reviewing and updating our risk assessment to ensure it remains relevant as our services evolve and the data threat landscape changes. Should our data processing activities change significantly in the future, we are prepared to conduct a full DPIA if it becomes necessary.

We conduct regular risk assessments of our data processing activities. These assessments include:

  • Assessment of the likelihood and consequences of these risks
  • Implementation of measures to mitigate identified risks
  • Ongoing monitoring and evaluation of these measures

Automated Decision-Making

It's important to emphasize that our system does not make automated decisions with legal or similarly significant consequences for our users. Our system performs the following actions:

  • Generates suggestions and recommendations based on user input
  • Offers language and stylistic improvements

All outputs from our AI system are meant as suggestions, and the final decision to implement these suggestions always lies with the user. We encourage our users to review and evaluate all AI-generated suggestions critically before use.

In line with GDPR Article 22, we ensure that:

  • Users are always informed that they're interacting with an AI system
  • No significant decisions are made solely based on automated processing

The website is built in WordPress and hosted on a GDPR-certified web server with the Danish-owned company Simply, located in Denmark. Interaction with our AI services occurs through this platform.

Key Points About the Application

  • Hosting: The web server is located in Denmark and is GDPR-certified.
  • AI Model: Our language model is developed by Microsoft (Azure OpenAI), and the data center is geographically located in Sweden.
  • Data Transfer: No data transfer occurs to countries outside the EU.
  • User Creation: To access our services, you must create a user profile. Your login credentials and profile are stored securely on our servers.
  • Data Security: We implement various security measures, including content filters and real-time abuse monitoring, to protect your data and ensure a safe user experience.
  • Limited Data Access: We only have access to your login information. We do not have access to or the ability to store your prompts or generated content from AI interactions.
  • Microsoft as Sub-Processor: Microsoft (Azure OpenAI) is fully GDPR-compliant. They operate under strict data protection obligations as defined in Microsoft's Products and Services Data Protection Addendum.

Data Processing

  • When you use our AI tools, your entered text (prompts) is sent to Microsoft Azure OpenAI for processing
  • This process occurs with strict data confidentiality and security protocols.
  • Microsoft Azure OpenAI functions as our sub-processor and is fully GDPR-compliant.
  • They process your prompts and generate content (outputs) without storing or using the data for purposes other than delivering the immediate service.
  • All data transmission between our platform and Microsoft Azure OpenAI is encrypted.
  • Microsoft Azure OpenAI's data center is located in Sweden, ensuring data remains within the EU.
  • Neither we nor Microsoft permanently store your prompts or outputs. They are kept only temporarily (up to 30 days) by Microsoft exclusively for abuse monitoring and system improvement purposes, after which they are automatically deleted.
  • We do not have access to your individual prompts or outputs either before or after processing.
Technical Infrastructure

Technical and Organizational Measures

When you submit a request through our service, your information is processed in a way that protects your privacy. Your requests are converted into an "anonymous identifier," which is an encrypted code that ensures we cannot track or store information about what you asked. This secure process means we don't store or monitor the session where your request is processed. Everything you do on our platform is stored locally on your device in your web browser and is accessible only to you. This ensures your data stays private and is automatically deleted when you leave our site.

Transparency in AI Use

Azure OpenAI Service generates responses or material by processing user prompts (input) and generating content (output) through completion, chat completion, image, and embedding operations. The models are stateless and don't store prompts or other text. By being "stateless," the models don't store information between interactions. This reduces the risk of bias from previous inputs affecting future outputs. It ensures the model's response is based solely on the current input, without bias from previous user data.

Prompts or other text generated through the platform are not used to train or improve the models. While Microsoft Azure OpenAI potentially stores data for a short period for security reasons, this data is not used to train or improve the models. Data is reviewed only in extremely rare cases of potentially serious abuse and is not accessible to the platform.

Azure OpenAI Service also implements ongoing advanced methods for bias correction, ensuring the models' outputs remain fair and unbiased. This ensures all users receive fair and objective responses regardless of their background or the topics they ask about.

To promote fairness, Azure OpenAI Service also works to diversify the training data used to develop AI models. By including a broad range of perspectives and experiences, it ensures AI models can understand and generate content that is relevant and inclusive for a global audience.

In line with GDPR's principles of transparency and fairness, we offer the following additional insight into our AI use:

  • Scope of Data Processing: Our AI models process only the text users actively enter. No additional contextual data or user behavior is collected or analyzed.
  • Processing Duration: All processing occurs in real-time. After generating output, input data is immediately deleted from active memory.

Third-Party Integrations

On the platform, we use carefully selected third-party integrations and sub-processors to improve functionality and user experience on our platform. We're committed to ensuring these integrations and sub-processors comply with the same high standards for data protection as the rest of our platform, in full accordance with GDPR and our own privacy policy.

Our approach to third-party integrations and sub-processors includes:

  • Thorough due diligence
  • Strict data minimization
  • Regular review and evaluation
  • Full transparency
  • Geographic restriction

Current third-party integrations and sub-processors include:

Microsoft Azure OpenAI (CVR: 13612870, Kanalvej 7, 2800 Kgs. Lyngby)

  • Purpose: Hosting of language model for AI-based text generation and analysis.
  • Data Processing: Occurs in data center located in Sweden.
  • Security Measures: Full GDPR compliance, encryption of data in transit and at rest, strict access controls.

Simply.com (CVR: 29412006, Højvangen 4, 8660 Skanderborg)

  • Purpose: Hosting of web application built in WordPress.
  • Data Processing: Ensures storage and processing of data within EU jurisdiction.
  • Security Measures: GDPR-certified web hosting, regular security updates.

WordPress

  • Purpose: Content Management System for our platform.
  • Data Processing: Local processing on our hosted servers.
  • Security Measures: Regular security updates, limited plugin use.

Elementor Pro

  • Purpose: Advanced page builder and design tool for our WordPress platform.
  • Data Processing: Local processing on our hosted servers.
  • Security Measures: Regular security updates.
Security Procedures

Control and Responsibility

If a sub-processor fails to fulfill their obligations, we remain fully responsible to the data controller. We commit to informing the data controller of any planned changes regarding the addition or replacement of sub-processors with at least 30 days' notice.

Data Breach Procedures

In case of a data breach, we have implemented the following procedures:

  • Immediate assessment of the breach's scope and potential consequences
  • Notification to relevant authorities within 72 hours of discovering the breach
  • Direct communication to affected users via email and/or our website
  • Implementation of measures to limit and remedy any negative consequences
  • Thorough investigation of the breach's cause and implementation of preventive measures

We commit to being transparent and acting quickly to protect our users' data and rights.

Cookies and Tracking Technologies

You can manage your cookie preferences in the following ways:

  • Through our cookie banner, which appears when you first visit our website
  • By clicking 'Cookie Settings' at the bottom of our website
  • By changing the settings in your browser

We respect 'Do Not Track' signals from web browsers. You can also choose to block or delete cookies through your browser settings. Note that blocking certain cookies may affect the functionality of our website.

Contact and Updates

Right to Complain

As a user, you have the right to file a complaint with a data protection authority if you believe your personal data has been processed in violation of data protection law. In Denmark, the Danish Data Protection Agency serves as the national data protection authority.

Danish Data Protection Agency

Address: Carl Jacobsens Vej 35, 2500 Valby, Denmark

Phone: +45 33 19 32 00

Email: dt@datatilsynet.dk

Website: www.datatilsynet.dk

Privacy Policy Updates

We review and update our privacy policy regularly, at least once a year or more often if there are significant changes to our data processing practices or relevant legislation. For significant changes, we will:

  • Post the updated policy on our website with a clear indication of the change date
  • In special cases, we may request renewed consent from users

We encourage our users to regularly review our privacy policy to stay informed about how we protect their personal data.

Update Notifications

For significant changes, we will inform our users via email and/or a prominent notice on our website before the changes take effect.

Versioning and Updates

We encourage you to review this policy regularly. Our privacy policy will always be updated on our website.

Last Updated: September 10, 2025

Contact Our DPO

To exercise your rights or if you have questions about our privacy policy, you're welcome to contact us. Here's our contact information to make it as easy as possible for you:

SkrivSikkert ApS

Sundkobbel 40, 6300 Gråsten,

Denmark

CVR: 45455238

Data Protection Officer (DPO)

Stefan Huhne

Email: gdpr@spellbright.ai

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