This Privacy Policy explains how Osoft NUF (“we”, “us”, “our”) processes your personal data when you use SantaClues (Beta) — our real-time sales-coaching platform.
We are committed to handling your data transparently, securely, and in compliance with the EU General Data Protection Regulation (GDPR, Regulation (EU) 2016/679).
This Privacy Policy describes what personal data we collect, why we collect it, how we use it, and what rights you have under the GDPR.
It applies to users in the European Union (EU) and European Economic Area (EEA) who access the SantaClues (Beta) service operated by Osoft NUF.
It does not apply to external websites or services we link to.
SantaClues is currently in beta testing, meaning our data-processing activities may evolve as the service matures. We will notify you of any significant updates before they take effect.
Definitions such as “personal data”, “processing”, “controller”, and “processor” follow Article 4 of the GDPR.
Controller: Osoft NUF
Organisation number: 995048477
Registered address: c/o Hydra Regnskap AS Idrettsvegen 103E, 5353 Straume
Email: hello@santaclues.ai
Osoft NUF is responsible for the processing of your personal data.
We have not appointed a formal Data Protection Officer, but all privacy inquiries are handled according to Articles 37–39 GDPR.
Data you provide directly
• Name, email address, and company details when creating an account
• Voice data and transcripts from sales calls or uploaded recordings
• Feedback and correspondence with our team
Data collected automatically
• Usage information such as pages visited, features used, and session length
• Technical data such as IP address, browser type, and device information
• Fonts and visuals loaded through Google Fonts
Data from third parties
We use limited data from service providers that help us deliver SantaClues, including Webflow Inc. (website hosting), Google LLC (Google Fonts, analytics), and OpenAI L.L.C. (AI-based analysis). Each provider acts as our data processor and processes data only under our instructions.
We process personal data only when we have a valid legal basis under Article 6 of the GDPR.
We use your data to provide and operate the SantaClues (Beta) platform. This is necessary for the performance of our contract with you.
We also use data to maintain security, debug issues, and improve the platform. These uses are based on our legitimate interest in developing and maintaining a reliable service.
Where required by law, such as for analytics or marketing communications, we rely on your consent.
We may process certain information to comply with legal obligations, such as responding to lawful requests by authorities.
We do not use your personal data for automated decision-making that produces legal or similarly significant effects (Article 22 GDPR).
We use your personal data to operate the service, ensure security, deliver insights, and improve performance.
We may share personal data only with trusted service providers who process data on our behalf under strict contractual safeguards.
We may also share data when required by law or a valid legal request from authorities.
We never sell your personal data to third parties.
Our key service providers include Google LLC (for fonts and analytics), Webflow Inc. (for website hosting), and OpenAI L.L.C. (for AI analysis).
Some of these providers are located outside the EEA, primarily in the United States.
When transferring personal data internationally, we use the European Commission’s Standard Contractual Clauses (SCCs) or rely on an adequacy decision where available, in accordance with Articles 44–49 GDPR.
Copies of these safeguards can be requested at hello@santaclues.ai
We keep personal data only for as long as necessary to fulfil the purposes described in this policy.
Account information is retained until you delete your account or until the beta phase ends.
Call recordings are generally deleted within 90 days after analysis unless required longer for debugging or legal obligations.
Usage logs and analytics data are retained for up to 12 months.
After the retention period, data is securely deleted or anonymised.
We apply appropriate technical and organisational measures to protect personal data as required by Article 32 GDPR.
These include encryption in transit (TLS), access controls, secure storage, and regular security monitoring.
Although no online service is entirely risk-free, we continuously review and strengthen our safeguards to prevent unauthorised access, loss, or misuse.
As an EU/EEA user, you have the right to:
• Access the personal data we hold about you (Article 15)
• Correct inaccurate or incomplete data (Article 16)
• Request deletion of your data (“right to be forgotten”, Article 17)
• Restrict how we process your data (Article 18)
• Receive your data in a portable format (Article 20)
• Object to certain types of processing (Article 21)
You can exercise your rights by contacting hello@santaclues.ai
We respond to all valid requests within one month, as required by Article 12 GDPR.
If you believe your rights have been violated, you can file a complaint with your national Data Protection Authority or with Datatilsynet in Norway.
Where personal data is transferred outside the EEA, we use appropriate safeguards such as Standard Contractual Clauses or rely on adequacy decisions recognised by the European Commission.
We regularly review these safeguards to ensure ongoing compliance.
SantaClues uses cookies and similar technologies to ensure the site functions properly and to measure usage patterns.
Essential cookies are required for operation and cannot be disabled.
Analytics cookies, where used, are placed only with your prior consent in accordance with the ePrivacy Directive and guidance from the CNIL and EDPB.
You can manage or delete cookies through your browser settings at any time.
We may update this Privacy Policy from time to time to reflect new features or legal requirements.
When we make material changes, we will post a notice on our website or email registered users before the new version takes effect.
The “last updated” date at the top shows when this version became active.
Osoft NUF
Email: hello@santaclues.ai
Address: c/o Hydra Regnskap AS Idrettsvegen 103E, 5353 Straume
If you have any questions or concerns about this Privacy Policy or your personal data, please contact us using the email above.
This Privacy Policy is provided for transparency and information purposes. It does not create contractual rights beyond those established by applicable law.
⚖️ This draft is for informational purposes only and does not constitute legal advice. Consult qualified counsel before relying on it for compliance purposes.