Personal data policy

Frankly
Insure

Last updated:
March 2026

Versione:
1.1

2026

1. Who we are

Frankly Insure (“we”, “us”, “our”) is an insurtech company registered in Denmark. This Privacy Policy applies to our landing pages, which are available at:

- https://franklyinsure.com

- https://www.franklyinsure.com

- https://franklyinsure.dk

- https://www.franklyinsure.dk

Under EU data protection law, Frankly Insure is Data Controller for the personal data collected through these pages.

CVR: 42626449

Address: Nyhavn 63B, 3., Copenhagen, Denmark

Contact: contact@franklyinsure.com

Website: https://franklyinsure.com

2. What This Policy Covers

This Privacy Policy covers personal data collected through the landing pages listed in Section 1 — more specifically, information collected as a result of your visit to these pages (including technical data, security checks and product analysis).

It covers not:

- Police and claims data — how your insurance information and claims data are collected, used and stored is described in our [policy document] (#), which you should have received when taking out your insurance

- Product Portals — our insurance portals (e.g. the self-service portal under *.frankly.insure) are subject to their own separate privacy policies, which are available in the respective products;

3. What data we collect and why

3.1 Security — Google reCAPTCHA

We apply Google reCAPTCHA on our websites to protect against automated abuse, bot activity and malicious attacks. reCAPTCHA analyzes behavioral signals, browser characteristics and interaction patterns to assess whether a visitor is a human or a bot. This processing has no impact on the content or services we make available to you.

The data collected by reCAPTCHA is processed by Google LLC (USA) on the basis of standard contractual clauses.

Legal basis: Legitimate interests in protecting the security and integrity of our platform (GDPR Art. 6 (1) (f)).

3.2 Web Analytics — Google Analytics

We apply Google Analytics to understand how visitors find and navigate our landing pages (e.g. which pages are visited, duration of sessions and traffic sources). This data is aggregated and is used solely for the purpose of improving our website. We do not use Google Analytics to identify individual users.

The data is processed by Google LLC (USA) on the basis of standard contractual clauses.

Legal basis: Legitimate interests in understanding and improving our website (GDPR Art. 6 (1) (f)).

3.3 Product Analysis — Datadog Real User Monitoring and Session Replay

We apply Datadog Real User Monitoring (RUM), including session replay functionality, to understand how visitors interact with our landing pages and to identify and resolve usability issues and bugs.

Datadog RUM collects:

- Page views, navigation progress and interaction events (click, scroll)

- Session recordings of how users move through our pages

- Technical information, including browser type, device type, screen resolution, and performance metrics

- Error events and crashes on the page

About Form Data: Data you submit via forms on our landing pages is stored in our own systems and is not transmitted to Datadog. Datadog session replay is configured to mask all form fields before sending data to Datadog — Datadog receives only structural and navigational data, never the content of the fields you fill in.

This data is processed by Datadog Inc. (USA) via their EU infrastructure (datadoghq.eu) on the basis of standard contractual clauses.

Legal basis: Legitimate interests in improving our product and ensuring the proper functioning of our landing pages (GDPR Art. 6 (1) (f)). We have assessed that this interest is not overridden by your rights, as no form data is transferred to Datadog and data is processed within EU infrastructure.

3.4 Contact and inquiries

If you contact us via a form or email address on our landing pages, we will collect the information you provide (e.g. name and email address) in order to respond to your enquiry. We apply Twilio SendGrid to send reply emails.

Legal basis: Legitimate interests in responding to inquiries (GDPR Art. 6 (1) (f)) or measures taken at your request prior to the conclusion of a contract (GDPR Art. 6 (1) (b)).

3.5 Technical data and log data

Our infrastructure at Google Cloud Platform (GCP) automatically collects technical log data when you visit our sites, including IP addresses, query timestamps and error information. This data is used exclusively for security monitoring and infrastructure maintenance.

Legal basis: Legitimate interests in maintaining the security and availability of our platform (GDPR Art. 6 (1) (f)).

4. What we don't do

- We does not sell, rent or share your personal data with advertisers or third parties for marketing purposes

- We apply not your data for automated decision-making or profiling that has a legal or similarly significant effect

- We apply not your data for purposes other than those described in this policy

5. Who we share your data with

We only share personal data when necessary:

Modtager

Formål

Placering

Sikkerhedsforanstaltning

Google LLC

reCAPTCHA-sikkerhedstjek; Google Analytics; GCP-infrastruktur

EU (GCP); USA (reCAPTCHA, Analytics)

SCCs; EU-dataplacering for infrastruktur

Datadog Inc.

RUM og session replay (maskeret)

EU (datadoghq.eu)

SCCs; EU-dataplacering

Twilio SendGrid

E-maillevering ved besvarelse af henvendelser

USA

SCCs; Twilio DPA

We will not share your data with other third parties unless required by law (e.g. through government requests).

6. International Data Transfers

Frankly Insure is based in Denmark (EU). Some of our service providers are established in the United States. When personal data is transferred outside the EEA, we ensure that appropriate safeguards are in place — in particular Standard Contractual Clauses (SCCs) approved by the European Commission pursuant to Art. 46 (2) (c) GDPR. Where technically feasible, we configure these services to process data within EU infrastructure.

7. How long we keep your data

Datatype

Opbevaringsperiode

Begrundelse

Henvendelses- / kontaktdata

2 år fra seneste kontakt

Besvarelse og opfølgning på henvendelser

Google Analytics-data

14 måneder

Analyse af webtrafik

RUM / session replay-data

30 dage

Produktovervågning; ingen behov for langtidsopbevaring

Tekniske logdata

1 år

Sikkerhedsovervågning

reCAPTCHA-signaler

90 dage

Forebyggelse af svindel og angreb

Transaktionelle e-maillogs

30 dage

Leveringsbekræftelse

After the applicable retention period, data will be deleted or anonymised in a secure manner.

8. Your rights

According to the GDPR, you have the following rights regarding your personal data:

- Right to insight — you can request a copy of the personal data we hold about you

- Right to rectification — you can ask us to correct inaccurate or incomplete information

- Right to erasure — you can ask us to delete your data, subject to any legal retention obligations

- Right to restriction — you can ask us to restrict the processing of your data in certain circumstances;

- Right to data portability — you can request your data in a structured, machine-readable format when processing is based on contract or consent

- Right to object — you can object to processing based on legitimate interests; we will discontinue processing unless we can demonstrate compelling legitimate grounds

To exercise any of these rights, please contact us at contact@franklyinsure.com. We will respond to your inquiry within 30 days.

9. Cookies

We use cookies on our websites. You can browse the full list of cookies at any time and manage or withdraw your consent via our cookie settings (provided by Cookiebot).

10. Security

We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, loss or disclosure. This includes encryption during transmission (TLS) and at rest, role-based access management, as well as multi-factor authentication on all internal systems.

11. Children

Our websites are not aimed at children under the age of 18. We do not knowingly collect personal data from children. If you believe that a child has submitted personal data through our websites, please contact us at contact@franklyinsure.com and we will delete this information without undue delay.

12. Changes to this Policy

We may update this Privacy Policy from time to time. The version number and “last updated” date at the top of the page indicate when the policy was last revised. We will notify users of material changes via a notice on our websites.

I'm 13. Complaints

If you are dissatisfied with our processing of your personal data, please first contact us at contact@franklyinsure.com, then we will do our best to solve your problem.

You also have the right to lodge a complaint with the Data Inspectorate:

Data Inspectorate

Carl Jacobsen Road 35

2500 Valby, Denmark

Website: https://www.datatilsynet.dk

Email: dt@datatilsynet.dk