1. Who we are
The controller is Settio Partners AB (org. nr 559587-0303), [ADD: street address and postcode of the registered office], Västerås, Sweden, which runs Settio. Write to us about anything in this policy at [email protected]. We have not appointed a data protection officer; this address reaches the person responsible for privacy at Settio.
2. Our two roles
Controller
We decide how and why data is used for our website, the free tools (such as the Citizenship Countdown), the free personal account, the accounts of the people who use the Settio platform, billing, support and our own marketing. Section 3 describes this processing.
Processor for employers and agencies
When an employer or an agency uses the Settio platform to run work-permit and relocation cases, it is the controller of the data about its employees, candidates and their families (“Customer Data”). Settio processes that data only on its instructions, under our Data Processing Agreement. Employees see a privacy notice from their employer in the employee portal, and can use their rights under Ask, Your data in the portal. Questions about Customer Data go to the employer first; if you write to us, we pass your request on.
3. What we process and why (as controller)
Visiting the website
- What
- IP address, browser and device type, pages requested, time. Our website host receives this with every request.
- Why
- To deliver the site and keep it secure.
- Legal basis
- Legitimate interests, Art. 6(1)(f): running a secure website.
- How long
- In the host's logs, for the limited time the host keeps them.
Your cookie choice
- What
- The answer you give in the cookie banner (cookie
settio_consent). - Why
- To respect your choice and show we asked.
- Legal basis
- Legal obligation, Art. 6(1)(c) and Art. 7(1) GDPR.
- How long
- 12 months, then we ask again.
Analytics (only after “Accept all”)
- What
- A random identifier, the pages you view and the actions you take on the site (such as starting a free tool or clicking sign up), approximate location from the IP address, browser and device. Typed text is masked. Never the dates or trips you enter in a tool.
- Why
- To see which pages help and improve them.
- Legal basis
- Consent, Art. 6(1)(a), and lag (2022:482) om elektronisk kommunikation 9 kap. 28 §. Withdraw it any time under Cookie settings.
- How long
- Up to 13 months.
Chat (only after “Accept all”)
- What
- Your messages, the name or email you give in the chat, and technical data the chat needs.
- Why
- To answer your questions.
- Legal basis
- Consent for loading the chat (LEK 9 kap. 28 § and Art. 6(1)(a)); legitimate interests, Art. 6(1)(f), for answering you.
- How long
- Up to 24 months after the conversation.
Contact form and demo bookings
- What
- Your email, company, role and what you tell us; for a booking also your name and the time you pick.
- Why
- To answer you and prepare the meeting.
- Legal basis
- Steps before a contract at your request, Art. 6(1)(b), or legitimate interests, Art. 6(1)(f).
- How long
- Up to 24 months after our last contact, unless you become a customer.
Citizenship Countdown and the other free tools
- What
- Nothing reaches us while you use them: your answers and trips are kept in your own browser (local storage
settio:citizenship-clock) until you clear them. - Why
- So the tool remembers your answers on your device.
- Legal basis
- Necessary for the service you ask for (LEK 9 kap. 28 § second paragraph); we receive no personal data.
- How long
- On your device until you clear it.
Countdown reminders
- What
- Your email address, the date you asked about, your language and when you agreed.
- Why
- To email you before that date (at most twice).
- Legal basis
- Consent, Art. 6(1)(a). Stop it with the link in any reminder.
- How long
- Deleted after the last reminder or as soon as you stop it.
Keeping your road in a free account
- What
- If you choose this in the Countdown, your answers and trips are sent to Settio and held for you while you sign up or sign in.
- Why
- So your account starts with them.
- Legal basis
- Steps at your request to provide the account, Art. 6(1)(b).
- How long
- One hour, or until your account picks them up.
The free personal account
- What
- Your name, email (and picture if you sign in with Google); your road: status, start and decision dates, permit, the trips you enter (with an optional reason and note), salary if you add it, the checklist you tick, and the family members you add (name, relation, birth date); the documents you put in your vault, with their kind and dates; the dates you choose to share with an employer; reminder settings; and the files or text you send to the assistant to find your trips.
- Why
- To give you the countdown, reminders, document expiry dates and the sharing you choose.
- Legal basis
- Contract, Art. 6(1)(b). For the family members you add: legitimate interests, Art. 6(1)(f), in planning your household's move; please tell them you added them.
- How long
- Until you delete the account (Account in the app). Deleting it removes the road, the documents and the workspace at once; backups are overwritten in their normal cycle.
Platform users (team members and clients)
- What
- Name, email, role, workspace, language, sign-in history (time, method, success) and the actions you take in the app (an audit trail).
- Why
- To run your account, keep it secure and give your organisation a record of who did what.
- Legal basis
- Contract with your organisation, Art. 6(1)(b), and legitimate interests in security, Art. 6(1)(f).
- How long
- While the account exists; sign-in history and the workspace audit log 400 days.
Billing and bookkeeping
- What
- The customer's company details, plan, invoices and payments, and the contact person.
- Why
- To invoice and keep the accounts the law requires.
- Legal basis
- Contract, Art. 6(1)(b), and legal obligation, Art. 6(1)(c) (bokföringslagen (1999:1078)).
- How long
- Seven years after the end of the calendar year (bokföringslagen 7 kap. 2 §).
We don’t sell personal data, we don’t use it for advertising, and we don’t make decisions about anyone by automated means alone (Art. 22).
4. Sensitive data and children
- Identity documents. In the Settio platform and the employee portal, passports, national ID cards and residence permit cards are read on the person’s own device or on Settio’s servers, never by an AI service, and no copy of a passport or ID card is kept, only the details read from it. In the free personal account, a document you add to your vault is stored there, and its kind and dates are read once by our AI provider (see section 5).
- Nationality, family and trips are not special categories of data under the GDPR, but we treat them with care: we only ask for what the countdown or the case needs, and trips are never shared with an employer.
- Health. In employer cases, the platform can record only whether a medical check required for a permit was passed, never a reason or a result. The employer is responsible for its legal basis under Art. 9(2)(b) GDPR and the Swedish Data Protection Act 3 kap. 2 § (or its own country’s law).
- Criminal records. We don’t ask for them in the free tools or the personal account, and you shouldn’t put a police certificate in your vault: the citizenship countdown doesn’t need one. Where an employer’s case needs a police certificate for a permit, the employer is the controller and handles it under Art. 10 GDPR and the law that requires it.
- Children. Our accounts are for adults. Children’s details reach Settio only when a parent adds them in a personal account or an employer adds a family member to a case, and only what the plan needs (name, birth date, relation).
5. AI
We use Anthropic’s Claude models for these features. Anthropic acts as our processor, doesn’t use the data to train its models, and keeps it only for the limited time its commercial terms allow.
- Platform: checking which step an uploaded document belongs to (never an identity document), reading an authority’s letter the team uploads, and answering questions from our help guides.
- Personal account: finding trips in a file or text you send (a spreadsheet or document is turned into lines with dates in your browser first), and reading the kind and dates of a document in your vault. It is told to return no names or numbers. Each account has a daily limit.
- Every AI result is shown as a suggestion that a person checks. See our AI policy.
6. Who receives data
- Our service providers (processors), each under a data processing agreement: hosting and database ([ADD: MongoDB Atlas cluster region, e.g. AWS eu-north-1 Stockholm]), file storage (Cloudflare R2), email (Resend), AI (Anthropic), website hosting (Vercel), website analytics (PostHog EU), chat (Crisp), contact form (HubSpot), meeting bookings (Cal.com), payments (Stripe) and phone notifications (the push service of the person’s browser: Google, Apple, Mozilla or Microsoft, which receive only counts and a link). The full list with locations is on our subprocessors page.
- Your employer or agency, for data in its own cases; and an employer you choose to share dates with from a personal account (only those dates, never trips, documents or salary).
- Authorities, only when the law requires it.
- A buyer of our business, if that happens, under this policy.
7. Transfers outside the EU and EEA
Some providers are based in the United States (for example Anthropic, Cloudflare, HubSpot, MongoDB, Resend, Stripe and Vercel), and files in Cloudflare R2 are stored in Cloudflare's global storage (it may be outside the EU). Where data leaves the EU and EEA, we rely on the European Commission’s adequacy decision for the EU-US Data Privacy Framework (Art. 45) where the provider is certified under it, and otherwise on the EU Standard Contractual Clauses (Decision (EU) 2021/914, Art. 46(2)(c)) in the provider’s data processing agreement. Ask us at [email protected] for a copy of the safeguards.
8. Security
We protect data with measures that fit the risk (Art. 32), including:
- encrypted connections (HTTPS) and encryption at rest by our database and storage providers;
- personal identity numbers and integration credentials encrypted again in our own code;
- passwords stored only as hashes, and sign-in links, portal links and API keys stored only as hashes;
- access by role inside each workspace, and an audit trail of who opened identity documents;
- no copy kept of a passport or ID card in the platform;
- automatic deletion of closed cases after the period the employer sets.
More on our security page.
9. Your rights
You have the right to:
- get a copy of your data (Art. 15) and receive the data you gave us in a portable format (Art. 20);
- have wrong data corrected (Art. 16) and data erased (Art. 17);
- restrict processing (Art. 18);
- object to processing based on legitimate interests (Art. 21);
- withdraw consent at any time, without affecting what was done before (Art. 7(3)).
How to use them:
- Website and free tools: Cookie settings at the bottom of every page; the stop link in a reminder; clear the Countdown in the tool.
- Personal account: edit or delete anything in the app; delete the whole account under Account.
- Employee portal: Ask, Your data (download, correct, delete), or ask your employer.
- Anything else: email [email protected].
We answer within one month (Art. 12(3)). If you think we handle your data wrongly, you can complain to the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY), Box 8114, 104 20 Stockholm, imy.se, or to the authority where you live or work.
Questions
10. Changes to this policy
We update this policy when what we do changes, and change the date at the top. If a change matters to you, we tell account holders by email or in the app before it applies.