Delogue Privacy Policy

1. Privacy Policy

Welcome, and thank you for your interest in Delogue (“Delogue,” “we,” “our,” or “us”), our website at www.delogue.com (the “Site”), and all related websites, software, and applications (including other applications), as well as our Platform, including associated services, communications, and products that reference this Privacy Policy. This includes communications with individuals via written or oral means, such as email or phone (collectively, together with the Site, our “Service”).

This Privacy Policy (“Policy”) explains what personal information we collect through the Service, how we use and disclose it, and the measures we take to protect it. By accessing the Site or using our Services, you acknowledge that you have read and understood this Policy and agree to the privacy practices described herein.

This Policy is incorporated into and is subject to the Delogue Standard Terms of Service. Capitalized terms used but not defined in this Policy have the meaning given to them in the Delogue Standard Terms of Service.

1.1 Definitions

• Account: The primary means for accessing and using the Delogue Services, typically subject to payment of a License Fee based on the selected Plan.
• Client: A legal entity represented by a natural or legal person who has accepted our Standard Terms of Service by entering into an agreement, and thereby also agrees to this Privacy Policy.

• Client Data: Files and any other digital data and information, which is processed by the Delogue Services or otherwise inserted to the System by the Client (including the specific Users, Styles, Items, Suppliers, Tasks and Orders).
• Personal Data: Any information relating to an identified or identifiable natural person.
• Public Area: The area of the Site that can be accessed both by Users and Visitors, without needing to log in.
• Restricted Area: The section of the Site or Service accessible exclusively to Users who have been granted Authorization and who have logged in, containing information and features not available to the public.
• User: A natural person who has been granted Authorization, meaning the specific set of rights and privileges assigned by a Client, to access and use the Account on behalf of that Client.
• Visitor: An individual other than a User, who uses the public area but has no access to the restricted areas of the Site or Service.

2. The information we collect on the service

We collect different types of information from or through the Service. The legal bases for Delogue’s processing of personal data are primarily that the processing is necessary for providing the Service in accordance with Delogue’s Terms of Service and that the processing is carried out in Delogue’s legitimate interests, which are further explained in the section “How We Use the Information We Collect” of this Policy. We may also process data upon your consent, asking for it as appropriate.

2.1 User-provided information

When you use the Service, as a User or as a Visitor, you may provide, and we may collect, Personal Data. Examples of Personal Data include name, email address, mailing address, mobile phone number, and billing information. Personal Data also includes other information, such as geographic area or preferences, which we determine based on browser cookies or similar technologies (for example, identifying that you access the website from Copenhagen). We do not collect any Sensitive Data.

We strive to minimize the Personal Data collected and process only what is necessary to provide and improve the Service or comply with legal requirements. You may provide us with Personal Data in various ways on the Service, such as when you register for an Account, use the Service, post Client Data, interact with other Users through communication or messaging capabilities, or send us customer service-related requests.

2.2 Information collected by Clients

A Client or User may store or upload into the Service Client Data, which may include Personal Data relating to individuals such as employees, suppliers, or other third parties. In such cases, Delogue acts as a data processor, or, where applicable, as a sub-processor, on behalf of the Client, who is the data controller.

Delogue has no direct relationship with the individuals whose Personal Data is processed within the Service as part of Client Data. It is the sole responsibility of each Client to ensure that they have a valid legal basis for the collection and processing of such Personal Data and to provide all necessary privacy notices to the affected individuals in accordance with applicable data protection laws.

Delogue processes this data strictly in accordance with the Client’s documented instructions, the applicable Data Processing Agreement (“DPA”), and our Terms of Service. The DPA forms an integral part of the agreement between Delogue and the Client and governs our obligations as a processor, including data security, confidentiality, and data subject rights.

2.3 “Automatically collected” information

When a User or Visitor accesses or uses the Service, we may automatically collect certain technical data from their device using technologies such as cookies, pixel tags (e.g., “clear gifs” or “web beacons”), and similar tracking tools.

This information may include device identifiers (such as IP address or device ID), browser type, operating system, referring URLs, visited pages, time and date of access, session duration, and interactions with the Service (e.g., clicks, scrolls, or viewed content). We may also collect information about whether Users interact with our emails, such as whether they open, click, or forward messages.

This data is collected to support the functionality and performance of the Service, analyze usage patterns, and improve our offerings. Where required by applicable law, we request your prior consent for the use of non-essential cookies and tracking technologies through our cookie banner. For more information, including how to manage your preferences, please refer to our Cookie Policy.

The legal basis for this processing is either our legitimate interest in improving the Service and understanding usage (Article 6(1)(f) GDPR), or your consent where legally required (Article 6(1)(a) GDPR). 

2.4 Integrated services

You may have the option to access or register for the Service using credentials from certain third-party services (each, an “Integrated Service”), such as your Google or Microsoft account. When you authorize us to connect with an Integrated Service, we may receive certain information as permitted by your settings with the provider.

This may include basic account details such as your name and email address, and in some cases, profile picture or other contact-related information. We only collect and store the minimum data necessary to enable the integration and provide the Service.

The legal basis for this processing is your consent (Article 6(1)(a) GDPR), which you provide when initiating the integration. You can manage what data is shared via the settings of the Integrated Service and may revoke access at any time.

We encourage you to review the privacy policies and terms of use of any Integrated Service before authorizing a connection.

2.5 Information from other sources

We may receive Personal Data from third-party sources in connection with providing and maintaining the Service. These sources may include partners who assist us with onboarding or customer success services, Integrated Services you have authorized, or publicly available sources where permitted by law.

We only collect this information where we have a legal basis to do so, for example, when you have given your consent (Article 6(1)(a) GDPR), or where it is in our legitimate interests and does not override your data protection rights (Article 6(1)(f) GDPR).

If we combine such information with Personal Data collected directly through our Service, we will treat the combined information in accordance with this Policy. Any third parties that process data on our behalf will be subject to appropriate contractual safeguards, including our Data Processing Agreement (DPA), where applicable.

3. How we use the information we collect

We process Personal Data in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR). Our legal bases for processing include performance of a contract (Article 6(1)(b)), compliance with legal obligations (Article 6(1)(c)), our legitimate interests (Article 6(1)(f)), and, where required, your consent (Article 6(1)(a)). The purposes and legal bases for each type of processing are outlined in the subsections below. 

3.1 Operations

We use the information, other than Client Data, to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Service. We process Client Data solely in accordance with the directions provided by the applicable Client or User. 

3.2 Improvements

We use the information to understand and analyze the usage trends and preferences of our Visitors and Users, to improve the Service, and to develop new products, services, features, and functionality. Should this purpose require Delogue to process Client Data, then the data will only be used in anonymized or aggregated form.

3.3 Communications

We may use a Visitor’s or User’s email address or other information, other than Client Data, to contact that Visitor or User (i) for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to the Client Data or Personal Data posted on the Service or (ii) with your consent or in accordance with our legitimate interest, with updates on promotions and events, relating to products and services.

3.4 Cookies and tracking technologies

We use automatically collected information and other information collected on the Service through cookies and similar technologies to: (i) personalize our Service, such as remembering a User’s or Visitor’s information so that the User or Visitor will not have to re-enter it during a visit or on subsequent visits; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of Service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the Service. 

3.5 Analytics

We use Google Analytics e.g. to measure and evaluate access to and traffic in the Public Area of the Site and create user navigation reports for our Site administrators. Google operates independently from us and has its own privacy policy, which we strongly suggest you review. Google may use the information collected through Google Analytics to evaluate Users’ and Visitors’ activity on our Site. For more information, see Google Analytics Privacy and Data Sharing.

We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Site and identify visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Visitors or Users. 

4. To whom we disclose information

 Except as described in this Policy, we will not intentionally disclose the Personal Data or Client Data that we collect or store on the Service to third parties without the consent of the applicable Visitor, User or Client. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances: 

4.1 Unrestricted information

 Any information that you voluntarily choose to include in a Public Area of the Service, such as a public profile page, will be available to any Visitor or User who has access to that content.

4.2 Service providers

We engage third-party service providers (including hosting, infrastructure, analytics, communication, and customer support providers) to perform services on our behalf. These providers may have access to or process Personal Data or Client Data in connection with these services.

We limit the information provided to these providers to only what is necessary for them to fulfill their contractual duties, and we ensure they are subject to data processing agreements (DPAs) that require them to maintain confidentiality, implement appropriate security measures, and process the data only as instructed by Delogue or the Client, where applicable. An up-to-date list of our subprocessors is available upon request or as outlined in our Data Processing Agreement (DPA).

4.3 Non-personally identifiable information

We may share aggregated, anonymized, or otherwise non-personally identifiable information with third parties for purposes such as (i) fulfilling reporting obligations, (ii) supporting our business operations or marketing efforts, or (iii) helping third parties understand the behavior and usage patterns of our Clients, Users, and Visitors. 

4.4 Law enforcement, legal process, and compliance

We may disclose Personal Data or other information if required by law, or in the good-faith belief that such disclosure is necessary to comply with applicable laws, respond to valid court orders, subpoenas, warrants, or to cooperate with law enforcement or government agencies.

Additionally, we may disclose Personal Data or other information when we believe it is necessary to (i) prevent liability, (ii) protect against fraud, abuse, or unlawful activity, (iii) defend against third-party claims, (iv) safeguard the security and integrity of the Service and related infrastructure, or (v) protect legal rights, enforce contracts, or ensure safety. 

4.5 Change of ownership

Information about Users and Visitors, including Personal Data, may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, and only if the recipient of the User or Visitor Data commits to a Privacy Policy that has terms substantially consistent with this Privacy Policy.

Client Data may be physically or electronically transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, for the sole purpose of continuing the operation of the Service, and only if the recipient of the Client Data commits to a Privacy Policy that has terms substantially consistent with this Privacy Policy. 

5. Your choices

5.1 Access, correction, deletion

We respect your privacy rights and provide reasonable access to the Personal Data you have shared through your use of our Services. You may request to access, correct, delete, or transfer your Personal Data by contacting us as described in the “How to Contact Us” section.

While changes will be reflected promptly in our systems, we may retain certain information for legitimate business purposes, such as backups, fraud prevention, compliance, or legal claims. You also have the right to object to the processing of your Personal Data, unless we are legally permitted to continue processing.

If you believe your privacy rights have been violated, please contact Delogue’s Data Protection Officer at DPO@delogue.com. You may also file a complaint with the relevant supervisory authority.

Note: This section does not apply to Client Data. In that case, requests for access, correction, or deletion must be directed to the Client that controls such data. Delogue will support Clients in responding to such requests as required by law.

5.2 Navigation information

You may opt out of Google Analytics tracking on our Site by installing the Google Analytics Opt-out Browser Add-on.

5.3 Opting out of commercial communications

If you receive promotional communications from us, you may opt out at any time by using the unsubscribe link included in those communications or by contacting us directly.

Please note that even if you opt out of marketing communications, you will continue to receive administrative messages necessary for the operation of your account or the Service. Processing your opt-out request may take up to ten (10) business days.

5.4 Client Data Management

Delogue processes Client Data on behalf of its Clients and has no direct relationship with the individuals whose data is included. If you wish to access, modify, or delete such Personal Data, please contact the Client directly.

If requested by a Client, Delogue will assist in fulfilling data subject requests within thirty (30) days. Clients may be charged for the handling of such requests. We reserve the right to retain data as needed to fulfill legal or contractual obligations or to defend our interests

The client will be charged for the cost of this. We reserve the right to retain a copy of such data for archiving purposes or to defend our rights in litigation. Any such request regarding Client Data should be addressed as indicated in the “How to Contact Us” section and include sufficient information for Delogue to identify the Client or its customer or third party and the information to delete or amend.

6. Third-Party services

The Service may include links to, or integrations with, websites, platforms, or services provided by third parties. Any information you share with these third parties is governed by their respective privacy and security policies, not this Privacy Policy.

Delogue is not responsible for the privacy practices, security standards, or content of third-party sites or services, even if they are accessible through or integrated into our Service. We strongly encourage you to review the privacy policies of any third-party services before sharing your Personal Data with them.

7. Minors and children’s privacy

Protecting the privacy of minors is a priority. The Service is not intended for individuals under the age of 18, and we do not knowingly collect Personal Data from anyone under 18 without verified parental or legal guardian consent.

If you are under 18, please do not use or access the Service in any way. If we become aware that we have collected Personal Data from a child under 18 without appropriate consent, we will take prompt steps to delete the information from our systems.

If you are a parent or legal guardian and believe that your child under the age of 18 has provided us with Personal Data or created an account, please contact us at support@delogue.com so we can take appropriate action, including deleting the data where required.

The Service is not designed for minors to publicly share content. If a minor has inadvertently shared content through the Service, they may request its deletion as outlined in this Privacy Policy. However, while we make every effort to fulfill such requests, please be aware that complete removal of all traces of the content (e.g., from backups or third-party caches) may not be fully possible.

8. Data security

We take the security of your Personal Data seriously and implement a range of organizational, technical, and physical safeguards to protect it from unauthorized access, loss, misuse, or alteration.

Delogue follows generally accepted industry standards to ensure the security of data both in transit and at rest. These safeguards include, but are not limited to:

• Data encryption (SSL/TLS) during transmission over public networks
• Access controls, user authentication mechanisms, and role-based permissions
• Secure data centers, firewalls, and monitoring of system access
• Internal policies on data confidentiality, handling, and incident response

Despite our efforts, no system can be guaranteed 100% secure. Accordingly, we cannot guarantee or warrant the absolute security of any information you transmit to us or store on our Service. Transmission of data is at your own risk. In the event of a security breach affecting Personal Data, we will notify affected individuals and the appropriate authorities in accordance with applicable law.

If you suspect your Personal Data has been compromised or misused, please contact us immediately using the details in the "How to Contact Us" section. 

9. Data retention

We retain Personal Data only for as long as necessary to fulfill the purposes for which it was collected, or as required to comply with legal, accounting, or regulatory obligations.

Specifically:

• User account data: Deleted within 24 months after account closure, unless retention is required by law.
• System backups: Retained for a maximum of 3 months for disaster recovery purposes.
• Billing and financial data: Retained for 5 years in compliance with the Danish Bookkeeping Act and relevant tax regulations.
• Contractual records: Information related to legal transactions between Delogue and a Client is retained for 5 years, in accordance with the general limitation periods outlined in the Danish Civil Code.
  

Upon expiry of the retention period, data is securely deleted or anonymized. In cases where deletion is not possible (e.g., data stored in backup archives), we will ensure that such data is isolated and protected from further processing until deletion becomes feasible.

10. Settings and User controls 

Where applicable, Delogue provides you with the ability to manage certain privacy settings within the Service. These settings may allow you to limit access to specific Personal Data or control how your information is shared.

However, please be aware of the following:

• No system is infallible: While we implement safeguards to protect your information, no privacy setting or security measure is completely immune to circumvention or unauthorized access.
• User responsibility: Delogue cannot control the actions of other users with whom you may choose to share your information. Once shared, we cannot guarantee that others will handle it in accordance with your expectations.
• Persistence of shared data: Even if you delete or restrict access to content posted on the Service, cached pages, backup copies, or third-party archives may still retain that information. In some cases, third parties may have already saved or re-shared content prior to its removal.
• Residual risk: We cannot and do not guarantee that any information you post on or transmit through the Service will not be accessed, viewed, or stored by unauthorized persons.

We encourage you to use privacy settings thoughtfully and to refrain from sharing sensitive information in areas of the Service that may be visible to others.

If you believe your settings are not working as intended or have questions about managing your information, please contact us using the details provided in the “How to Contact Us” section.

11. Data transfer and international processing

Delogue operates globally and may transfer, access, process, and store Personal Data outside of the country in which the data subject resides, including to the United States and other jurisdictions that may not have equivalent data protection laws. Such transfers are necessary for the performance of our contract with you, to provide the Services, or to fulfill our legitimate interests as described in this Privacy Policy.

Hosting Location

The Service is hosted in Ireland, and all primary data operations, including hosting of production systems, occur within the European Economic Area (EEA).

Transfers to the United States and Third Countries

We may transfer Personal Data to service providers, subprocessors, or other recipients located in the United States or other non-EEA countries that do not offer the same level of data protection as the EEA.

When doing so, we rely on one or more of the following safeguards to ensure appropriate protection of Personal Data in accordance with the General Data Protection Regulation (GDPR):

• The recipient country has been recognized by the European Commission as providing an adequate level of data protection;
• We enter into Standard Contractual Clauses (SCCs) or other approved data transfer mechanisms with recipients;
• We implement supplementary safeguards, where required, such as encryption and strict access controls.

Subprocessors

Delogue engages certain third-party service providers (“subprocessors”) to support the delivery of our Services and process data on our behalf. These subprocessors are subject to contractual obligations that include data protection requirements consistent with this Privacy Policy and our Data Processing Agreement (DPA).

For more information about the subprocessors we use or to obtain a copy of our DPA, please contact us using the information provided in the “How to Contact Us” section.

12. Data controller and data processor

Delogue acts as a data processor on behalf of its Clients when processing Client Data via the Service. Clients and their authorized Users are the sole entities who determine the purposes and means of processing any Personal Data included in Client Data. Delogue does not own, control, or actively monitor the content Clients store or submit through the Service. Delogue only accesses such data when authorized by the Client or where required to provide the contracted Service, maintain system integrity, or fulfill legal obligations.

As such, Delogue does not act as a data controller within the meaning of the European Union’s General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”) with respect to any Personal Data included in Client Data. The Client is solely responsible for ensuring that Personal Data is collected and processed in accordance with applicable data protection laws, including providing appropriate privacy notices and obtaining any required consents from individuals.

Delogue may engage subprocessors to process Client Data strictly on its behalf and under the terms of a written Data Processing Agreement (DPA), which reflects the obligations required under Article 28 of the GDPR and other applicable regulations. Delogue ensures that such subprocessors offer sufficient guarantees to implement appropriate technical and organizational measures to safeguard Personal Data.

Delogue is not responsible for the content of any Personal Data stored by Clients or Users on the Service, nor for the ways in which Clients collect, use, share, or otherwise process such data. It is the sole responsibility of the Client to determine the legality of their processing activities and to uphold their obligations as a data controller under applicable law.

13. Changes and updates to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational, legal, or regulatory reasons. When we make changes to this Policy, we will revise the "Last Updated" date at the top of the document and publish the updated version on our website and/or through the Service.

Where required by applicable law, we will also notify you in advance of material changes and, where necessary, obtain your consent. We encourage you to review this Policy periodically to remain informed about how we collect, use, and protect your Personal Data.

Your continued use of the Service following the posting of any revised Policy constitutes your acknowledgment and agreement to be bound by the updated terms.

14. Use of Artificial Intelligence and automated processing

We may use artificial intelligence (AI) and machine learning technologies as part of our services or internal operations. This may include the use of AI to analyze aggregated user behavior, assist with support ticket classification, enrich vendor or contract data, detect anomalies, or optimize workflows.

Where AI is used to process Personal Data, it is done so in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR). Automated decision-making is not used in a way that produces legal or similarly significant effects for individuals unless we have obtained your explicit consent or such processing is otherwise permitted by law.

We do not use AI systems to profile users for targeted marketing without your consent, and we ensure that any third-party AI services we integrate with are contractually bound to comply with applicable privacy standards.

If you have any questions about our use of AI or automated tools, or if you wish to object to certain types of processing, you may contact us at DPO@delogue.com.

15. How to Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy, the handling of your Personal Data, or your data protection rights, you may contact us at:

General Inquiries: support@delogue.com

Data Protection Officer (DPO): DPO@delogue.com

We aim to respond to all legitimate inquiries within a reasonable timeframe and in accordance with applicable data protection laws. If you are located in the European Economic Area (EEA) and feel that your concerns have not been addressed satisfactorily, you also have the right to lodge a complaint with your local supervisory authority.

Last update: July 31, 2025