Privacy Statement
Last updated:
FUNE is a digital platform that lets you record information and wishes for later. This statement explains which personal data we currently process, why, and what your rights are. FUNE is still under development: at the moment you can only sign up for the newsletter and waiting list.
1. Who is responsible for the processing
Fune B.V. (FUNE) is the controller for the processing of personal data described in this statement. The contact details are at the bottom of this page.
2. Which personal data we process
We currently process the following data.
- Newsletter and waiting list: first name, last name, email address, the language of the website on which you sign up, the source of your sign-up (Coming Soon page), your consent to receive news, product updates and information, and the date and time of your sign-up. Mailchimp also records the IP address from which you signed up and the status of your confirmation.
- Technical data and logs: when you visit the website, our servers process technical data such as your IP address, the time, the requested page, and the device and browser type. When you sign up for the newsletter, your IP address is also used for at most one minute to prevent abuse through excessive sign-ups.
- Language preference: if you change the website language, we store that choice in a cookie (see Cookies).
3. Data once accounts become available
Accounts are not available yet. This is what we expect to process once they are; we will update this statement before we start.
Account data: name, email address and login details, and the data needed to secure your account.
FUNE content stored by you: wishes, memories, contacts, documents, images, recordings and other information that you put in your account yourself. This may include personal and sensitive information. We only use that content to provide the service to you and only share it with whom you indicate.
For the transactional emails of the account, such as confirmation and login emails, we use Mailgun.
4. Purposes and legal bases
We process your data for the following purposes and on the following legal bases (Article 6 GDPR).
- Processing your newsletter and waiting list sign-up, sending your confirmation and keeping you informed about FUNE: consent (Article 6(1)(a)).
- Being able to demonstrate that you gave consent and respecting your unsubscription: legitimate interest (Article 6(1)(f)), to meet our accountability obligation.
- Keeping the website secure, available and protected against abuse, including limiting the number of sign-ups per IP address: legitimate interest (Article 6(1)(f)).
- Remembering your language preference: this is necessary for the website to function and does not require consent.
- Once accounts are available: providing the service, namely managing your account and content: performance of a contract (Article 6(1)(b)).
5. Newsletter, waiting list and consent
You only sign up if you actively tick the consent checkbox. That box is never ticked in advance. Signing up is not possible without consent.
After you sign up we send you an email with a confirmation link (double opt-in). You only receive newsletters once you confirm it. To be able to demonstrate that you gave consent, we record your consent, the time, the source and the language.
You can withdraw your consent at any time via the unsubscribe link at the bottom of every newsletter. Withdrawal does not affect the lawfulness of processing up to that moment.
Emails are sent via Mailchimp. Mailchimp may register whether you open an email or click a link in order to improve the newsletter.
6. Retention periods
- Newsletter and waiting list: for as long as you are subscribed. After you unsubscribe, your email address is kept with the status 'unsubscribed' so that we do not email you again. If you also want that removed, you can submit a deletion request (see Your rights).
- Sign-ups that are not confirmed are not kept longer than necessary.
- Backup and proof of consent: during the transition to Mailchimp we also keep our own record of sign-ups, with data and consent, on FUNE's servers. We keep it no longer than necessary to demonstrate your consent and delete or limit it once the sign-ups are fully confirmed in Mailchimp.
- Technical logs: for a short time, only for troubleshooting and security.
- The IP address for the sign-up limit is deleted after at most one minute.
7. Processors and external suppliers
We only share personal data with parties we need for our service and with whom we have or will make processing agreements.
- Railway: hosting and infrastructure for the website, the API and the database. FUNE's services run in the Europe region (the Netherlands).
- Mailchimp (The Rocket Science Group LLC, part of Intuit): collecting and managing newsletter sign-ups and sending the newsletter and the confirmation email.
- Mailgun and Cloudflare (R2 object storage): only relevant once accounts are available, for transactional email and for storing files you upload respectively. Until then, no personal data of visitors ends up with these parties.
- We currently do not use analytics or advertising services.
8. Transfers outside the EEA
Mailchimp and Railway are US companies. As a result, personal data may be processed or accessed outside the European Economic Area. For Mailchimp this is the case for the newsletter data.
Where necessary, the transfer takes place on the basis of an adequacy decision of the European Commission (such as the EU-US Data Privacy Framework) or on the basis of standard contractual clauses.
10. Security
We take appropriate technical and organisational measures to secure personal data, such as encrypted connections (HTTPS), restricted access to systems and limiting the number of sign-ups per IP address. Do you notice a security problem or suspect misuse? Please contact us immediately.
11. Your rights
Under the GDPR you have the following rights:
- access to the data we process about you;
- rectification of incorrect data;
- erasure of your data;
- restriction of processing and objection to processing based on legitimate interest;
- portability of data you provided yourself;
- withdrawal of your consent, at any time.
Send your request using the contact details below. We respond within one month and may ask you to identify yourself.
12. Filing a complaint
If we cannot resolve it together, you can file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at autoriteitpersoonsgegevens.nl.
13. Changes
We may amend this statement, for example when FUNE gets new features. The current version is always on this page, with the date of the last change at the top. For significant changes we will inform you in an appropriate way.
14. Contact
Questions about this statement or your personal data? Please contact us using the details below.
- Company name
- Fune B.V.
- Address
- Schaatsenrijder 5, 2851 ZN Haastrecht
- Chamber of Commerce (KvK) number
- 80361900
Email: info@fune.nu