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:

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:

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

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:

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:

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:

Service providers

We use a small number of providers. Each processes personal data only on our instructions, under a data processing agreement.

ProviderWhat they doWhere
SupabaseApp database, sign-in and server functionsData hosted in Stockholm, Sweden (EU). Support and operations may be provided from Singapore and the USA.
LovableHosts the website and the app's web pages; stores website demo requestsEU and USA
ResendSends service emails and demo-request notificationsUSA
AnthropicWrites the AI Executive BriefingUSA
Google (Workspace)Our email inbox, hello@transfolio.ioEU 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)

NameTypePurposeLasts
__cf_bmCookieProtects the site against automated abuse30 minutes
__dplCookieMakes sure every page you view comes from the same version of the site24 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)

NameTypePurposeLasts
sb-…-auth-tokenLocal storageKeeps you signed inUntil you sign out
tf_recovery_pendingLocal storageKeeps you on the password-reset page until you've set a new passwordUntil the reset is finished or cancelled
tf_recoverySession storageRecognises a password-reset linkUntil the reset is finished or cancelled

The app sets no cookies and uses no analytics or tracking.

Your rights

You can ask us to:

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.