Privacy
Privacy policy
Last updated: 20 October 2026
This policy explains how Probability Consulting AB handles personal data in connection with Transfolio. It covers two things:
- the website, transfolio.io, including demo requests;
- the Transfolio app, portfolio.transfolio.io, used by organisations to monitor their transformation portfolios.
Who we are
Transfolio is a product of Probability Consulting AB (Org. nr 559009-8488), Stockholm, Sweden. Contact us about anything in this policy at hello@transfolio.io.
For the website, we are the data controller: we decide how your data is used.
For the app, the organisation that uses Transfolio (our customer) decides what is entered and is the data controller. We process that data on the customer's behalf, under a data processing agreement with them. This policy describes how we do that, so that everyone using the app knows what happens to their data.
The website
What we collect
When you request a demo, we collect:
- your first and last name
- your work email address
- your organisation and job title
- the size of your initiative portfolio, if you choose to tell us
- anything you write about your main challenge
Our hosting providers also record technical data, such as IP addresses, in server logs, to keep the site secure and working. We don't use analytics, advertising or tracking cookies, and we don't build profiles of visitors.
Why we use it
We use your details only to reply to your request, arrange and run a demo, and follow up on it. Our legal basis is our legitimate interest in responding to people who contact us (GDPR Article 6(1)(f)). We will not add you to a mailing list or send you marketing without asking first.
How long we keep it
We keep demo requests for up to 12 months after our last contact with you, then delete them. If your organisation becomes a customer, we keep your contact details for as long as the customer relationship lasts.
The Transfolio app
What the app holds
- Account details: name, work email address, role (for example Head of Transformation or Driver) and organisation.
- Portfolio content entered by users:
- initiative details;
- the names and email addresses of heads, drivers and sponsors;
- health-scan answers, objectives and notes;
- dependency and control-gate names;
- status changes and the notes that go with them.
- Records needed to run the service:
- sign-in records;
- when invitations and reminder emails were sent;
- when share links were created, opened and revoked.
Scan notes are free text. Please don't enter sensitive personal data in them, such as health information or details about individuals' performance.
Why it's used
Only to provide Transfolio to the customer organisation:
- to let users sign in;
- to collect and score health scans;
- to show results to the people the organisation has given access to;
- to send service emails: invitations, password resets and scan reminders;
- to produce the AI Executive Briefing.
We don't use app data for marketing, and we don't sell it.
Who can see it
Access is decided by role and enforced in the database:
- Heads of Transformation see their own organisation's portfolio.
- Drivers see only the initiatives they run.
- No organisation can see another's data.
- Read-only share links, created by a Head, show selected scores and the briefing to people without an account. They never include scan notes or email addresses, they expire, and they can be revoked at any time.
- Transfolio staff access customer data only when needed to provide support or keep the service secure.
Where it's stored
The app's database, sign-in service and server functions are hosted in Stockholm, Sweden (EU).
How long it's kept
For as long as the customer's agreement lasts. When the agreement ends, we delete or return the customer's data as set out in that agreement. Users can ask their organisation's Head of Transformation, or us, to correct their details.
AI in Transfolio
The AI Executive Briefing is written by Claude, an AI model from Anthropic, using the customer's own scan data:
- Figures are calculated by Transfolio, not by the AI. The AI writes the narrative around them, and any figure it writes that can't be traced back to the data is flagged.
- What's sent: to write the briefing, we send Anthropic a summary of the portfolio's recent scans. It includes initiative names, the names of drivers and sponsors, scan answers, objectives and the drivers' notes. Email addresses are not sent.
- How Anthropic handles it: Anthropic processes this data to return the briefing. It does not use it to train its models, and deletes it from its systems within 30 days, except where longer retention is needed for safety or legal reasons.
- Who sees the briefing: briefings are stored in the app and visible only to the organisation's Heads of Transformation, and to anyone they share a link with.
- Automated decisions: the AI does not make decisions about people. It summarises portfolio health for human review.
Service providers
We use a small number of providers. Each processes personal data only on our instructions, under a data processing agreement.
| Provider | What they do | Where |
|---|---|---|
| Supabase | App database, sign-in and server functions | Data hosted in Stockholm, Sweden (EU). Support and operations may be provided from Singapore and the USA. |
| Lovable | Hosts the website and the app's web pages; stores website demo requests | EU and USA |
| Resend | Sends service emails and demo-request notifications | USA |
| Anthropic | Writes the AI Executive Briefing | USA |
| Google (Workspace) | Our email inbox, hello@transfolio.io | EU and USA |
Where a provider processes data outside the EU/EEA, the transfer is protected by the European Commission's standard contractual clauses or another safeguard recognised under the GDPR.
Cookies and browser storage
Transfolio does not use analytics, advertising or tracking cookies. We only store what is strictly necessary for the website and app to work, so we don't ask for cookie consent. If this changes, we will ask for your consent first.
Website (transfolio.io)
| Name | Type | Purpose | Lasts |
|---|---|---|---|
| __cf_bm | Cookie | Protects the site against automated abuse | 30 minutes |
| __dpl | Cookie | Makes sure every page you view comes from the same version of the site | 24 hours |
Fonts are served from transfolio.io itself; the website doesn't contact Google or other third parties when you browse.
App (portfolio.transfolio.io)
| Name | Type | Purpose | Lasts |
|---|---|---|---|
| sb-…-auth-token | Local storage | Keeps you signed in | Until you sign out |
| tf_recovery_pending | Local storage | Keeps you on the password-reset page until you've set a new password | Until the reset is finished or cancelled |
| tf_recovery | Session storage | Recognises a password-reset link | Until the reset is finished or cancelled |
The app sets no cookies and uses no analytics or tracking.
Your rights
You can ask us to:
- give you a copy of the data we hold about you
- correct it
- delete it
- restrict or object to how we use it
- send it to you or another organisation in a portable format
Website data: email hello@transfolio.io and we'll respond within one month.
App data: contact your organisation, which decides how its Transfolio data is used. If you contact us, we'll pass your request to them and help them respond.
If you're unhappy with how your data is handled, you can complain to the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, imy.se).
Changes
If we change this policy, we'll update the date at the top of this page. For significant changes affecting the app, we'll also tell customer organisations directly.