Integritetspolicy

Översikt

CLVR Benefits AB ("CLVR", "we", "us") provides an employee benefits platform to companies and the employees of those companies. This Privacy Policy explains what personal data we collect, why we collect it, and the rights you have under the EU General Data Protection Regulation (GDPR) and Swedish data protection law.

This policy applies to all of our services: the marketing site at clvrbenefits.com, the employee webapp at app.clvrbenefits.com, the admin back-office, and any conversations you have with our team.

If you have questions about this policy, you can reach our Data Protection Officer at dpo@clvrbenefits.com. We respond within five business days.

Vem är ansvarig

CLVR Benefits AB is the data controller for personal data we collect on the marketing site, from prospects we talk to, and from our own employees.

CLVR is not a self-serve product. Every customer is onboarded under a bespoke commercial agreement that we prepare and counter-sign with the company. Individuals cannot register for CLVR on their own. If you are using the platform, it is because your employer has entered into that agreement with us and has chosen to extend access to you.

For employees using the platform through their employer, the employer is the data controller and CLVR acts as the data processor under a signed Data Processing Agreement (DPA) appended to that commercial agreement. The DPA governs how we process employee data on the employer's behalf. Any benefit provider you transact with through the platform becomes a separate controller for the order they fulfil.

Vad vi samlar in

The categories of personal data we process depend on how you use the service. The table below covers everything we may hold, the data points in each category, and why we need them.

We do not collect special categories of personal data (such as racial or ethnic origin, religious beliefs, health, sexual orientation, trade union membership, or genetic / biometric data). Nor do we collect information about criminal convictions or offences.

CLVR Benefits also collects and uses aggregated data (such as statistical or demographic data) for any purpose. Aggregated data is derived from personal data but is not personal data in law because it does not directly or indirectly reveal your identity. If we ever combine aggregated data with your personal data so that it can identify you, we treat the combined data as personal data and apply this policy to it.

Rättslig grund

We rely on one of these legal bases for each processing activity:

• Contractual necessity for processing your selections, receipts, and payments. Without this we cannot deliver the service that your employer has contracted CLVR to provide.
• Legitimate interest for product analytics, security logs, fraud prevention, and quality improvements. We balance the interest against your rights and freedoms each time we rely on it.
• Consent for marketing emails and optional cookies. You can withdraw consent at any time without affecting the lawfulness of processing we did before you withdrew.
• Legal obligation for tax reporting, accounting, anti-money-laundering checks, and responding to lawful requests from authorities.

Hur data delas

We do not sell personal data. We share it only with:

• Your employer, for the benefits selections you make through their account, the receipts you submit, and any reporting they need for payroll or accounting.
• Benefit providers you transact with through the platform. They receive the personal data they need to fulfil the order you placed, after which they become a separate data controller for that order.
• Payment, payroll, and identity providers (such as Stripe, BankID, Fortnox, and Microsoft Entra ID), strictly to process transactions and authenticate you.
• Sub-processors we engage to operate the service (cloud hosting, email, analytics, AI). The full list with their location and purpose is maintained in our Trust Center.
• Group companies, located in or outside Sweden but within the EU/EEA, where they support the delivery of the service.
• Fraud-prevention agencies who use the data to prevent fraud and money laundering and to verify your identity.
• Authorities, where we are legally required to disclose data.

Lagring

We keep personal data only as long as we need it for the purposes set out in this policy, or as long as we are legally required to. Concretely:

• Account data is kept while your employer maintains an active CLVR contract and you are listed as an active user under it. Once your access ends, your employer's grace period applies (default 90 days, and configurable by them between 30 and 730 days). After the grace period, your name, contact details, personnummer, address and receipts are removed automatically. Amounts remain on the record so your employer's own totals still reconcile. Your employer can also have this done sooner, on your request. We separately retain anonymised statistics (role, city, salary, benefit usage, year) that cannot be linked back to you or to your employer.
• Benefits activity and transactions are kept for 7 years to comply with Swedish bookkeeping law (Bokföringslagen).
• Support messages are kept for 24 months from the last interaction.
• Marketing data is deleted within 60 days of unsubscribing or going inactive.

We may retain data for a longer period if you raise a complaint or where we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Dina rättigheter

Under the GDPR you have the right to:

• Access the personal data we hold about you.
• Correct it if it is wrong or incomplete.
• Delete it, subject to the retention requirements above.
• Restrict or object to certain types of processing, including direct marketing.
• Port your data to another provider in a structured, commonly used, machine-readable format.
• Withdraw consent at any time, without affecting prior processing.
• Not be subject to decisions based solely on automated processing. See the next section on AI-assisted decisions.

To exercise any of these rights, email trust@clvrbenefits.com. We respond within 30 days. If you are not satisfied with our response, you can lodge a complaint with the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY).

Säkerhet

CLVR runs on EU-based cloud infrastructure with encryption at rest and in transit, scoped access controls, audit logging, and regular third-party penetration tests. Our staff cannot access employee benefit details without a documented, ticketed reason.

We have procedures in place to handle any suspected personal data breach and will notify you and the relevant regulator where we are legally required to do so.

For full detail on our security posture, controls, and certifications, see our Trust Center.

AI-assisterade beslut

CLVR Benefits offers optional AI-powered features that assist in processing expense reports and in answering questions about your employer's policies. These features are enabled at the discretion of your employer and include:

• Receipt scanning. AI extracts vendor, date, amount, and VAT information from uploaded receipt images to pre-fill expense forms.
• Expense evaluation. AI evaluates certain categories of expense reports (currently wellness and gym membership receipts) and may automatically approve, decline, or defer them to human review.
• CLVR Assistant. An assistant in the webapp that answers your questions about your employer's policies from the documents your employer has uploaded, with a reference to the document and page. It makes no decisions about you and tells you when the documents do not cover a question. If your employer also allows it, the assistant may read your own benefit data (your allowance, expenses, benefits, total compensation and elections) to answer you, and you may attach a receipt for it to price. The receipt is read and never stored. If your employer allows that too, the assistant may ask to see the page you are looking at. The page is sent only after you press Allow, as text rather than a picture, and it is not stored. It sees your own data and nobody else's. Where you are an HR user, your own assistant also answers about your company, from the same records the HR pages already show you.

Human oversight. All AI decisions are subject to HR review. HR can view every AI decision with its confidence score and reasoning, and can revert any decision at any time. When the AI is uncertain (confidence below 85%), the expense is automatically deferred to human review. This constitutes human-in-the-loop processing under GDPR Article 22.

Your rights. If an expense is declined by AI, you are notified with a clear explanation and can edit and resubmit the expense. You may also contact your HR representative to request manual review of any automated decision.

Data sent to AI. What is sent depends on which features your employer has enabled. For receipt scanning and expense evaluation: receipt images and PDFs, expense form data, and benefit category names, with no employee names, emails, salaries or balances. For the CLVR Assistant: the question you type and the company policy documents. Where your employer has enabled those steps as well, the assistant is also sent your own benefit figures, a receipt you attach, and a page you have chosen to share. An assistant answers from your own records and, where you are an HR user, from your company's, and never from another company's. Your personnummer is never sent, and nothing you type into a password field can be. AI processing is performed by Anthropic (Claude). We do not use your data to train models. We retain only what is necessary for these features and for audit compliance.

Assistant conversations. Your conversations with the CLVR Assistant are yours: you read them, you can delete any of them at any time, and they are deleted automatically 90 days after the last message. Your employer does not see them. What your employer sees is a list of the questions the assistant could not answer, grouped by wording and without names, so that missing policies can be added. Conversations are left out of the data export a company receives at the end of its contract with us. CLVR staff can read conversations for one purpose, to check the answers and improve the assistant, and for nothing else. Every such read is recorded in our audit log, and a conversation you delete is gone for them too.

Ändringar i denna policy

We may update this policy from time to time. Material changes will be notified to customers in the webapp at least 30 days before they take effect, and where appropriate by email to the designated representatives of our customers.

The current version and effective date are always shown at the top of this page. The version number tracks the release of the marketing site. If it changes, this page has been touched.

Kontakt

For any questions about this Privacy Policy or how we handle your personal data, contact us:

CLVR Benefits AB (org. nr 559418-3641)
Vegagatan 23
172 34 Sundbyberg, Sweden
dpo@clvrbenefits.com