Privacy Policy

Last updated: 2026-11-05

English·Dansk

This Privacy Policy describes how Innovation Solutions ApS, Morsøgade 12, 6700 Esbjerg, CVR 41171081, Denmark ("Innovation Solutions", "we") processes personal data in connection with the Orbit platform ("the Service").

1. Our roles: controller and processor

2. Personal data we process as controller

3. Purposes and legal bases

3A. Service analytics and platform improvement

Innovation Solutions may analyse technical usage and diagnostic information for operation, security, reliability and improvement of the Service. Where the information is personal data processed by Innovation Solutions as controller, an appropriate legal basis will be identified for each purpose, including legitimate interests under GDPR Article 6(1)(f) where applicable and after the required balancing assessment. The lawful basis depends on the circumstances and is not created merely by this Privacy Policy. Customer personal data processed on behalf of a Customer will not be repurposed for independent cross-customer analysis without an appropriate lawful arrangement and relevant Customer instructions or other applicable legal basis.

4. Customer personal data processed by Innovation Solutions

Where Innovation Solutions acts as processor, the Customer determines the purposes and means of the processing and is responsible for ensuring that it has an appropriate legal basis and all necessary notices, permissions and other requirements for the personal data it places in or processes through the Service. Innovation Solutions processes such personal data only to provide, host, maintain, secure and support the Service and as otherwise instructed by the Customer and permitted by the DPA and applicable law. Ownership of Customer Data is governed by the Terms of Service. Nothing in this Privacy Policy transfers ownership of Customer Data to Innovation Solutions.

4A. Aggregated and anonymised insights

The Terms of Service distinguish Customer Data from effectively anonymised and aggregated statistical outputs. Where permitted by the agreement, the DPA and applicable law, Innovation Solutions may generate statistical measures and benchmarks for improving the Service and understanding operational patterns. Anonymisation itself may involve processing personal data and must therefore have a lawful basis, defined purpose and suitable safeguards. Removing names or assigning pseudonyms is not, by itself, anonymisation. We will assess risks of singling out, linkage and inference, including where small groups or unique assets or projects may make a Customer or individual recognisable. We do not publish customer-identifiable statistics without separate authorisation.

4B. AI and machine learning

We do not use identifiable Customer Data to train or fine-tune general-purpose, cross-customer or third-party artificial-intelligence models on the basis of this Privacy Policy alone. Such use would require a separate documented arrangement, appropriate lawful basis, transparency information and protections, and any necessary DPA changes. Customer-directed AI features, if introduced, will be assessed under the relevant controller/processor roles and communicated before use.

5. Recipients, subprocessors and international transfers

We use vetted service providers and processors to operate the Service, including cloud hosting (Amazon Web Services, EU region), payment processing (Stripe), and email delivery services. Where Innovation Solutions acts as processor for a Customer, the use of subprocessors is governed by the DPA. Where a service provider processes personal data outside the EU/EEA, transfers are made using an applicable lawful transfer mechanism, such as an adequacy decision of the European Commission or the European Commission's Standard Contractual Clauses, together with supplementary measures where required. Innovation Solutions does not sell personal data.

5A. External data and content

The Service may incorporate third-party licensed software, integrations or content. Intellectual-property licences and reuse permissions are governed by the relevant providers and the Terms of Service; they are not a legal basis for personal-data processing. We will assess whether integrations involve transfers of personal data and make the disclosures and contractual arrangements required by law.

6. Security

Innovation Solutions implements appropriate technical and organisational measures designed to protect personal data against unauthorized or unlawful processing and against accidental loss, destruction, alteration or disclosure. Where Innovation Solutions processes Customer Data as a processor, applicable security measures and personal data breach obligations are governed by the DPA. No system or method of electronic storage or transmission can be guaranteed to be completely secure. The security measures described in this Privacy Policy are therefore not a guarantee that a security incident, interruption or data loss can never occur.

7. Backups and recovery

Innovation Solutions maintains automated daily backups of the Service and Customer Data for operational resilience and disaster-recovery purposes. Backups are retained for up to seven (7) days and are automatically

overwritten or deleted thereafter in accordance with Innovation Solutions's backup processes. Backups are maintained as a technical safeguard for the Service and are not intended to constitute an individual archival or backup service for Customers. Customers remain responsible for maintaining appropriate copies or exports of Customer Data that are operationally, commercially or legally important to them. Innovation Solutions does not guarantee that individual records, files or Customer Data can be restored from backup in every circumstance. Contractual responsibility and limitations relating to availability, backups, data loss and recovery are governed by the Terms of Service and, where applicable, the DPA.

8. Retention

8A. Retention of aggregated outputs

Lawfully generated, effectively anonymous statistics may be retained for product improvement and benchmarking while they remain anonymous and do not disclose protected Customer information. Source personal data and identifiable intermediate datasets remain subject to the retention, deletion, processing instructions and restrictions applicable to the relevant processing role. Anonymity will be reassessed where emerging data or methods create material re-identification risks.

9. Personal data breaches

Innovation Solutions maintains procedures for identifying, assessing and responding to personal data breaches. Where Innovation Solutions acts as controller, we will notify the competent supervisory authority and affected individuals where required by applicable data protection law. Where Innovation Solutions acts as processor, Innovation Solutions will notify and assist the relevant Customer in accordance with the DPA and applicable data protection law.

10. Your rights

Where Innovation Solutions acts as controller, and subject to the conditions and limitations of applicable data protection law, you may request access to your personal data, rectification, erasure, restriction of processing, data portability, and may object to processing based on legitimate interests. Requests concerning personal data processed by Innovation Solutions on behalf of a Customer should normally be directed to the relevant Customer, such as your employer or the organization that provided your access to Orbit. Innovation Solutions will assist Customers with data-subject requests as required by the DPA and applicable law. To exercise rights concerning processing for which Innovation Solutions is controller, contact support@innovationnow.dk. You may also lodge a complaint with Datatilsynet, the Danish Data Protection Agency.

11. Automated decision-making

Unless expressly disclosed otherwise, Innovation Solutions does not use personal data for which it acts as controller to make solely automated decisions that produce legal effects or similarly significant effects on individuals. Customers may use functionality within the Service as part of their own HR, recruitment, project, compliance or operational processes. The Customer is responsible for determining whether its use of such

functionality involves automated decision-making or profiling and for complying with any applicable legal requirements.

12. Cookies

The Service uses strictly necessary cookies and similar technologies for session authentication, security and interface preferences. No advertising or cross-site tracking cookies are set unless this Privacy Policy and any required consent mechanism are updated accordingly.

13. Changes to this Privacy Policy

We may update this Privacy Policy when our processing activities, the Service or applicable legal requirements change. Material changes will be notified in the Service or by another appropriate means. The current version is always available at /legal/privacy.

14. Contact

Innovation Solutions ApS, Morsøgade 12, 6700 Esbjerg, Denmark, CVR 41171081. support@innovationnow.dk or legal@innovationnow.dk.