Privacy Policy for Tintune

Last updated: August 2025

1. Who We Are

This privacy policy describes how Tintune (developed by Colours by Barslund, Denmark) processes your personal data when you use our app or website, buy goods or services, or contact us for support.

Tintune (Colours by Barslund)
c/o Anders Barslund
Abildgaardsvej 51
2830 Virum, Denmark
Tel: (+45) 60 63 40 24
Email: legal@tintune.com

2. What Data Do We Collect?

When you use Tintune, we collect and process the following types of data:

• Anonymous app usage: Your chosen colors, symbols, and features; your country code (e.g., “DK”); the date (rounded to the day, not time-specific) of your interactions. No data can be linked to your personal identity.
• Purchases: If you buy goods or digital content via our website, we process your name, contact info, order/payment details and user account data for order fulfillment and compliance.
• Newsletter: If you sign up, we process your name and email with your consent, for direct marketing. You may unsubscribe at any time.
• Queries and support: If you contact us, we process your name, contact details, and query to provide assistance.

3. Legal Basis and Storage Periods

• Anonymous app usage: Our legitimate interest (GDPR art. 6(1)(f)) in analysing color trends and improving the product. Data is aggregated, anonymised, and cannot be used to identify individuals.
• Purchases: Data processed to fulfill contracts (GDPR art. 6(1)(b)); stored for up to 3 years after contract performance, unless otherwise required by law (e.g., Danish Bookkeeping Act, see below).
• Newsletter: Processed with your consent (GDPR art. 6(1)(a)). Consent logs are stored for up to 5 years after withdrawal.
• Accounting/invoice info: Stored for 5 years after end of financial year, as required by law (GDPR art. 6(1)(c)).
• Queries/support: Stored for up to 3 months after last contact unless required for dispute/legal documentation.

4. Purpose of Processing

We use your data to:

• Deliver and support our goods, services, and app features
• Analyze usage trends, color and feature popularity across regions and time
• Comply with legal obligations (accounting, documentation)
• Send newsletters/marketing (with your consent)
• Defend our rights in case of disputes or regulatory investigations

Aggregated, anonymized app usage data (not purchases or support info) may be shared with or sold to third parties, such as paint manufacturers, trend analysts, or architecture firms, for research and product development. No data is ever shared that can identify you as an individual.

5. Storage, Security & International Transfers

• Anonymous usage data is stored in Apple’s CloudKit (public zone).
• Your palettes are stored privately via iCloud and accessible only to you.
• Purchase and support data is stored securely with access limited to authorized personnel and trusted service providers (such as hosting/IT/accounting partners).
• Data is not transferred outside the EU/EEA except as required for secure processing by Apple or trusted providers who comply with GDPR requirements.

6. Cookies and Tracking

Tintune does not use cookies or tracking technologies to collect data about your use of the app or website. We do not use analytics for advertising or profiling purposes.

7. Disclosure to Third Parties

• Service providers and IT suppliers who help us deliver our services (e.g., Apple, hosting, analytics, payment processors).
• External advisors (e.g., accountants, legal counsel).
• Other third parties, with your consent, or in case of mergers or legal requirements.
• Anonymous app usage data (color statistics, country, date) may be shared/sold as described above.

8. Your Rights

You have the right to:

• Request access to or a copy of your data
• Request correction, erasure, or restriction of your data
• Object to our processing or to data used for marketing
• Withdraw your consent at any time (for newsletter/marketing)
• Complain to the Danish Data Protection Agency at www.datatilsynet.dk

To exercise your rights, contact us at legal@tintune.com or by mail/phone (see above).

9. Changes to this Privacy Policy

We may update this privacy policy as our services evolve or as required by law. Significant changes will be communicated via the app or website. Your continued use after changes means you accept the updated policy.

Tintune – developed by Colours by Barslund