This Privacy Policy explains how Sanera Technologies processes personal data when you use the Cards app and its related services: which data we process, for what purposes and on which legal bases, to whom it is disclosed, how long it is retained, and the rights available to you under the General Data Protection Regulation (GDPR) and the laws of the Netherlands.
This Privacy Policy applies to the processing of personal data in connection with the Cards mobile application for iOS and Android (the "App"), the public card pages and links generated by the App, the Apple Wallet and Google Wallet passes issued through the App, and the web portal through which organisations administer work cards (together, the "Service"). Our general Privacy Policy, available at sanera.nl/privacy-policy, governs all other services and websites of Sanera Technologies.
The controller within the meaning of the General Data Protection Regulation (EU) 2016/679 ("GDPR") is Sanera Technologies, Dalsteindreef, 1112 XJ Diemen, the Netherlands ("Sanera", "we", "us" or "our"). Where an organisation issues work cards to its personnel through the Service, that organisation determines which personal data appears on those work cards and to whom they are issued. In respect of that data, the organisation acts as controller and Sanera processes the data on its behalf as processor.
In this Privacy Policy, "personal data", "processing", "controller" and "processor" have the meanings given to them in Article 4 GDPR. "You" means any natural person who uses the Service or whose personal data is processed through it.
Your e-mail address and name. If you set a password, we store only a one-way cryptographic hash of it. If you sign in with Apple or Google, we receive from that provider your e-mail address, your name (which Apple provides on first sign-in only) and an account identifier, together with a refresh token that we store in encrypted form solely in order to revoke the App's access when you delete your account (see section 12). One-time verification codes are sent to your e-mail address.
The information you enter on your cards, which may include your name, job title, organisation, a short description, contact details (such as telephone numbers, e-mail addresses, websites and social media or messaging accounts), a photograph or picture, a logo, the design of the card and, for work cards, a barcode provided by your organisation. You determine for each item whether it is public.
The fact that you are connected with another user, which of your cards each party has chosen to share, and the relevant dates. Notes you record about a connection, and where you met, are visible to you alone. We also process connection requests and blocks.
Where you belong to an organisation in the Service: your membership and role, invitations sent to or by you, and the organisation's details (name, verified domains, brand colours, logo and subscription status). Administrative actions are recorded in an audit log available to the organisation's administrators. Payments for organisation subscriptions are processed by Stripe; we retain only a customer reference and the subscription status.
For each sign-in: the device name and type, the App version, the IP address and the time. A push notification token for each device on which you have permitted notifications. The devices on which an Apple Wallet pass for your card is installed, so that the pass can be updated. A security log of sign-ins and sensitive account actions, including the IP address and device concerned.
The number of times the link or code of a card is opened each day. These figures are aggregated and anonymous: we do not record who opened a card or their IP address.
The content of any report you submit about another user (see section 10), any correspondence you send to us, and the information needed to handle it.
The following features operate entirely on your device. The data they use is not transmitted to Sanera:
If you enable Meetings, the App reads your calendar in order to display the cards of the persons you are about to meet. The App does not modify your calendar.
The App accesses your device's contacts only when you choose to save or update a connection in your contacts. Your address book is never uploaded.
Text on a scanned business card, or a code read from a photograph, is recognised on your device. You review the result before anything is saved.
The layered photograph effect is generated on your device.
Follow-ups, event notes and the related reminders are stored on your device only.
Your sign-in credentials are held in the secure storage of your device, and copies of your cards are kept for widgets and Wallet passes. This data is removed from the device when you sign out.
We process personal data for the following purposes and on the following legal bases:
Providing the Service: your account, cards, public page, connections and Wallet passes; sending verification codes, invitations and service messages; and, for organisations, the administration of members, invitations, work cards and subscriptions.
Push notifications and access to your camera, photo library, contacts and calendar, each of which the App requests only through your device's permission prompt. You may withdraw consent at any time in your device settings, without affecting the lawfulness of processing before withdrawal.
Maintaining the security and integrity of the Service, preventing fraud, spam and abuse, handling reports about users and their content, and compiling anonymous view statistics. We have balanced these interests against your rights and limit the data processed to what is necessary.
Retaining billing records as required by Dutch tax law, responding to lawful requests from public authorities, and meeting our obligations as a hosting service provider under the Digital Services Act (Regulation (EU) 2022/2065).
We do not sell or rent personal data, display advertising, track you across applications or websites owned by other companies, or use your personal data to train artificial intelligence models. We do not engage in automated decision-making, including profiling, that produces legal or similarly significant effects within the meaning of Article 22 GDPR.
Any person who has your card's link or code can see your name and the details you have made public, including on the Wallet pass and in the contact file they may save.
Your connections see the cards you have chosen to share with them, limited to the public details on those cards, and kept up to date. Contact details you keep private are never shown. You may remove a connection or block a user at any time; the other user is not notified.
If you hold a work card, your organisation's administrators can see your work card, your role and the number of connections of that work card, but not the identity of those connections. They have no access to your personal card or its connections.
An organisation may connect its Google Workspace or Microsoft Entra ID directory, or an identity provider using SCIM (such as Okta). In that case we receive the name, work e-mail address and account status of persons on the organisation's verified domains, in order to invite new personnel and deactivate the work card of a person who leaves. Deactivating a work card does not affect that person's personal account or personal card. When the organisation disconnects its directory, we delete the access credentials it granted.
A limited number of authorised Sanera personnel may access account information where necessary for support, the handling of reports and security. Such access is logged.
We engage the following processors, each bound by a data processing agreement and permitted to process personal data only on our documented instructions:
We may disclose personal data where required by Dutch or European Union law, in response to a binding order of a court or competent authority, or to a successor in the event of a merger, acquisition or transfer of all or part of our business, subject to equivalent safeguards.
Certain processors are established in, or may access personal data from, countries outside the European Economic Area. Where personal data is transferred to such a country, the transfer is based on an adequacy decision of the European Commission, including the EU-U.S. Data Privacy Framework where the recipient is certified under it, or on the Standard Contractual Clauses adopted by the European Commission, supplemented where necessary by additional safeguards.
We retain personal data no longer than necessary for the purposes for which it is processed:
We implement appropriate technical and organisational measures to protect personal data, including encryption in transit and at rest, one-way hashing of passwords, storage of credentials in the secure storage of your device, re-authentication for sensitive actions such as data export and account deletion, and restricted and logged access by personnel. No method of transmission or storage is entirely secure, and we review these measures regularly.
Subject to the conditions of the GDPR, you have the right of access (Article 15), rectification (Article 16), erasure (Article 17), restriction of processing (Article 18) and data portability (Article 20), the right to object to processing based on legitimate interests (Article 21), and the right to withdraw consent at any time (Article 7(3)).
You may also exercise your rights by contacting us at the address in section 16. We may ask you to verify your identity, and we will respond within one month of receipt, which may be extended by two further months where necessary in accordance with Article 12(3) GDPR.
You have the right to lodge a complaint with a supervisory authority, in particular the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). We would appreciate the opportunity to address your concern first.
You may report a user whose card or conduct you consider unlawful, misleading, offensive or otherwise inappropriate, using Report on that user's card or connection request in the App, or the report link on a public card page. A report records the reason you select, any note you add, the card concerned and, for reports made in the App, your account identifier. You may also block the user at the same time.
The reported user is not informed of your identity. Reports submitted through a public card page are anonymous.
Reports are reviewed by authorised Sanera personnel, and we endeavour to review each report within 24 hours. Where a report is substantiated, we may remove content, deactivate a card or suspend the account concerned. Reports are processed on the basis of our legitimate interest in keeping the Service safe and our obligations under the Digital Services Act, and are retained as set out in section 7.
The App requests each of the following permissions only when you first use the feature concerned. The App remains usable if you decline:
You may delete your account at any time under Account > Delete account. Upon deletion we:
If you own an organisation in the Service, you must transfer ownership or delete the organisation before deleting your account. Entries in the security log and reports concerning your account are retained for the periods set out in section 7. Data stored only on your device (section 3) is removed when you sign out or uninstall the App.
If you are unable to sign in, you may request deletion by e-mail and we will delete the account after verifying your identity. You may also revoke the App's access independently: on iOS under Settings > [your name] > Sign in with Apple, and for Google at myaccount.google.com under Security, Your connections to third-party apps and services.
The Service is not directed at persons under the age of 16, and we do not knowingly process personal data of children under that age. If you believe that a child under 16 has created an account, please contact us and we will delete it.
Cards may contain links to websites and services operated by third parties, including links added by other users. Sanera is not responsible for the privacy practices of those third parties, and we encourage you to review their privacy policies.
We may amend this Privacy Policy from time to time. The date of the latest revision is shown at the top of this page. Where an amendment materially affects the processing of your personal data, we will notify you in the App or by e-mail before it takes effect.
Questions, requests and complaints concerning this Privacy Policy or the processing of your personal data in Cards may be addressed to:
Sanera Technologies
Email: info@sanera.nl
Phone: +31 (6) 39 65 25 54
Dalsteindreef, 1112 XJ Diemen, Netherlands