privacy policy
Data controller: creativeservices.be BV, with registered office at Bergstraat 27, 8800 Roeselare, Belgium, company number BE0843617314, hereinafter "STUTE" or "we".
This privacy policy applies to all users of the STUTE platform (hereinafter the "Platform"): Shops, Initiatives, and the individuals who request or gift products through a list (hereinafter "End Users"). It describes which personal data we process, why, for how long, and what rights you have under the General Data Protection Regulation (GDPR) or the equivalent legislation of your country.
1. What data we process
From Shops
- Company details: name, company/VAT registration number, address, country
- Contact details: contact person's name, email address, phone number
- Account details: login credentials, linked payment provider (Mollie/Stripe)
- Transaction data: orders, revenue, commission
From Initiatives
- Name of the organisation/initiative, legal form/status where applicable
- Contact details: contact person's name, email address, phone number, country
- Account details: login credentials
- Content of the list created (texts, photos)
From End Users (people who view a list, order, or gift something)
- Name, email address, delivery address where applicable
- Order and payment data (processed via the payment provider, see art. 4)
- Technical data necessary for the operation of the Platform (e.g. IP address, session data)
2. Why we process this data (purposes and legal basis)
- Performance of the contract (art. 6.1.b GDPR): creating and managing accounts, displaying lists and products, processing orders and payments, customer support.
- Legal obligation (art. 6.1.c GDPR): accounting and tax obligations (e.g. invoicing, VAT administration).
- Legitimate interest (art. 6.1.f GDPR): security of the Platform, fraud prevention, technical management and troubleshooting.
We do not use your data for automated profiling or automated decision-making with legal effects.
3. Cookies
The Platform uses only functional/technically necessary cookies (e.g. to keep you logged in or secure your session). We place no analytics cookies and no third-party cookies (no tracking, no advertising cookies). These functional cookies do not require prior consent under applicable cookie legislation, as they are strictly necessary for the operation of the Platform.
4. Sharing of data
4.1 We never sell your personal data to third parties.
4.2 We only share data between registered users of the Platform, and only to the extent necessary to make the service work. For example: data of an End User who orders or gifts something is shared with the relevant Shop so it can process and deliver the order; data about a list is shared between the Initiative and the relevant Shop(s).
4.3 We also share data with third parties acting as processors on our behalf and acting solely on the instructions of STUTE, such as payment providers (Mollie and/or Stripe) for processing payments, and our hosting partner for storing and securing data. All our processors are established within the European Union.
4.4 We do not share any data with third parties for marketing purposes and do not pass on data to advertisers.
4.5 We may share data with government or judicial authorities where we are legally required to do so.
5. Where your data is stored
All personal data is stored on servers located in the European Union. No personal data is transferred to countries outside the EU/EEA.
6. Retention period
- Account data: for as long as the account is active, and for 12 months thereafter following closure, unless earlier deletion is requested.
- Accounting/tax data (e.g. invoices): for the legally required retention period (in Belgium, generally 7 years).
- Technical/log data: for a maximum of 12 months.
7. Your rights
You have the right, at any time, to:
- request access to the data we process about you;
- have inaccurate data corrected;
- have your data deleted — this can be done on simple request, by emailing support@stute.app, without needing to provide a reason, subject to data we are legally required to retain (e.g. accounting records);
- have processing restricted;
- receive your data in a structured, commonly used format (portability);
- object to processing based on our legitimate interest;
- lodge a complaint with the supervisory authority of your country (in Belgium: the Data Protection Authority, www.dataprotectionauthority.be).
We respond to every request within the legally required timeframe (in principle within 1 month).
8. Security
We take appropriate technical and organisational measures to protect your data against loss, misuse, unauthorised access, alteration or destruction (including encrypted connections, access restrictions, regular backups).
9. Data breach
In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the competent supervisory authority and, where legally required, the affected users, without undue delay.
10. Children
The Platform is not directed at children. We do not knowingly process personal data of individuals under the age of 16 without the consent of a parent or guardian.
11. Changes to this privacy policy
We may update this privacy policy from time to time. The most recent version can always be consulted via the Platform. In the event of significant changes, we will inform users via the Platform or by email.
12. Contact
For questions about this privacy policy or to exercise your rights, you can contact us at:
creativeservices.be BV, Bergstraat 27, 8800 Roeselare, Belgium
Email: support@stute.app