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    Privacy Policy

    Draft for legal counsel review - not yet in force.

    Last updated: July 2026

    This Privacy Policy explains how Emelum OÜ (registry code 17234831, Nõmme tn 30, Kärdla linn, Hiiumaa vald, 92412, Estonia), operating the BizKard digital business card platform at bizkard.me ("BizKard", "we", "us", "our"), collects, uses, stores, and protects personal data.

    This Policy has three parts, because BizKard processes personal data about different groups of people:

    • Part A applies to you if you are a BizKard account holder or card owner (or a workspace member whose card is managed by your organization): it describes the data we collect about you and how we use it, including the data you choose to publish on your public card page.
    • Part B applies to you if you are a lead or card viewer: someone who submitted their contact details through a BizKard card, whose paper business card was scanned by a BizKard user, or who visited a public card page. Part B is our notice under Articles 13 and 14 of the GDPR for those situations.
    • Part C applies to everyone: subprocessors, international transfers, security, retention, your rights, and complaints.

    For questions, requests, or complaints under this Policy, contact us at privacy@bizkard.me.

    1. Who We Are

    The controller (or, where stated below, processor) of the personal data described in this Policy is:

    Emelum OÜ Registry code: 17234831 Nõmme tn 30, Kärdla linn, Hiiumaa vald, 92412, Estonia Email: privacy@bizkard.me

    Emelum OÜ is established in the European Union (Estonia). No representative under Article 27 GDPR is required. Our lead supervisory authority is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), www.aki.ee.

    2. Our Roles: When We Are Controller and When We Are Processor

    • Emelum as controller. We are the controller for Account Data: the data described in Part A that we collect about our own account holders and website visitors (account details, billing, usage, support), because we determine the purposes and means of that processing.
    • Emelum as processor. We are the processor for Customer Data: the card content and contact data that our customers create, collect, and manage through the Service. This includes Lead Data (contact details submitted through a card's "share your details" flow or extracted from scanned business cards) and, in team workspaces, the card data of workspace members managed by the organization. For that data, the card owner or workspace organization is the controller, and we process it only on their documented instructions under our Data Processing Agreement (the "DPA"). If your data was collected by a BizKard user and you want to exercise your rights, that user or organization, as controller, is primarily responsible for handling your request; we will assist as described in Part B.

    PART A - Account Holders, Card Owners, and Workspace Members

    3. Data We Collect About You

    Account Data. When you create an account we collect your email address and the profile information you provide: name, title, company, and similar details. Authentication is handled through our hosting provider's authentication service (Supabase Auth); passwords are stored only in hashed form.

    Card Data. The content you place on your cards: name, title, photo, company, logos, links, phone numbers, email addresses, and any other details you add. If your card is managed within a team workspace, your organization provides and controls this data (see Section 6).

    Billing Data. Paid subscriptions and one-time purchases are processed by our payment processor, Stripe. We do not store full card numbers. We store subscription status, plan, invoices, and purchase records associated with your account. The payment processor handles your payment data under its own privacy policy and acts as an independent controller for certain fraud-prevention processing.

    Usage Data. We record how you interact with the platform: features used, actions performed, timestamps, and technical data such as browser type, operating system, IP address, and device information.

    Lead activity and card analytics. We store, on your behalf, the Leads captured through your cards, scans, voice notes, and imports, including Leads identified by the visitor identification service described in Part B Section 9. For your card statistics we record view and interaction events on your card pages, including each visitor's approximate location, referrer, campaign (UTM) parameters, device and browser information, and a per-visitor identifier, and make them available to you in the analytics dashboard, as a CSV export, and in a monthly analytics digest email. The digest is sent from noreply@notify.bizkard.me and contains a one-click unsubscribe; unsubscribing is honored through a suppression list.

    Support Communications. When you contact us, we keep the correspondence, along with email send logs and unsubscribe and suppression records.

    We do not knowingly collect special categories of personal data (Article 9 GDPR) about our users, and we ask that you do not submit such data.

    4. Public Card Pages: What You Publish Is Public

    When you publish a card, the information on it is available on a public web page that anyone with the link can view, save (including as a downloadable contact file), and share. You choose what to put on your card and whether to publish it, and you can unpublish at any time using the Service's controls. Once someone has saved or shared your card details, those copies are outside our and your control. Public card pages are indexable by search engines and may appear in search results; we do not apply a noindex directive, and card pages generate social-media link previews. A private or unlisted card option is planned but not yet available; until then, every published card is public and indexable.

    5. Purposes and Lawful Bases (Account Data)

    PurposeDataLawful basis (GDPR Art. 6)
    Providing the platform, creating and managing your account, cards, and workspacesAccount Data, Card Data, Usage DataContract performance, Art. 6(1)(b)
    Publishing your card page at your instructionCard DataContract performance, Art. 6(1)(b)
    Billing, invoicing, subscription managementBilling DataContract performance, Art. 6(1)(b); legal obligation, Art. 6(1)(c) (accounting and tax law)
    Platform security, abuse prevention, logging, access controlUsage Data, logsLegitimate interests, Art. 6(1)(f) (securing the service)
    Service communications (transactional email, subscription lifecycle, workspace invitations), sent from noreply@notify.bizkard.meAccount Data, email logsContract performance, Art. 6(1)(b)
    Monthly analytics digest email to card owners with card views, with one-click unsubscribeAccount Data, card statisticsLegitimate interests, Art. 6(1)(f); you can opt out at any time via the unsubscribe link
    Responding to inquiries and support requestsSupport dataLegitimate interests, Art. 6(1)(f); pre-contractual steps, Art. 6(1)(b)
    Marketing communications to youAccount DataConsent, Art. 6(1)(a), withdrawable at any time via the unsubscribe link
    Product improvement in aggregated or de-identified formUsage DataLegitimate interests, Art. 6(1)(f)
    Establishing, exercising, or defending legal claims; complying with lawAny of the above as neededLegal obligation, Art. 6(1)(c); legitimate interests, Art. 6(1)(f)

    Where we rely on legitimate interests, you can object at any time (Section 15).

    6. Workspace Members

    If your card is managed in a team workspace, your organization (the Workspace Owner) decides what appears on your card and whether it is published, and is the controller of your card data; we process it on the organization's behalf under the DPA. Questions about why your card exists, what it shows, or requests to change or unpublish it should go first to your organization's workspace administrator. You can also contact privacy@bizkard.me and we will assist and forward your request. Under the Terms of Service, the organization must have authority (and where required, your consent) to manage your card, and must remove your card when you leave or withdraw consent.


    PART B - Leads and Card Viewers (Articles 13 and 14 GDPR Notice)

    7. If You Submitted Your Details Through a BizKard Card

    When you view someone's BizKard card and choose to share your contact details with them (for example through the "Just met someone" form), the details you submit (such as your name, email address, phone number, company, and any note) are stored in that card owner's BizKard contact list. The card owner (or their organization) is the controller of this data: they decide why they collect it and how they use it. Emelum stores and processes it only on their behalf as processor.

    The card owner may contact you using the details you shared, by their own means (their own email, phone, or messaging service). BizKard does not itself send follow-up messages to you: the Service only provides the card owner with your details and, on request, message drafts, and the card page's "Auto Follow-Up" button simply opens a pre-addressed draft in the viewer's own email client. Under our Terms of Service and Acceptable Use Policy, card owners must have a lawful basis and, where required, your consent for contacting you, and must honor your opt-outs.

    8. If Your Paper Business Card Was Scanned

    BizKard users can photograph physical business cards they have received and have the contact details extracted (using AI-based text recognition provided through the Lovable AI Gateway with Google Gemini models) and saved to their contact list. If someone scanned your card, the extracted data (typically name, title, company, phone, email, and address) is stored in that user's BizKard contact list; the photographed image itself is processed transiently for extraction and is not stored. This is an Article 14 situation: we did not obtain your data from you. The user who scanned your card (or their organization) is the controller; Emelum is their processor. Our terms require users to scan only cards that were given to them directly, in a business context.

    9. If You Visited a Public Card Page

    When you visit a public card page we process the following:

    • Technical and analytics data. We process your IP address, browser and device information, screen size, language, timezone, referrer, campaign (UTM) parameters, and timestamps, and your approximate location (country, region, city) derived from your IP address (where our infrastructure does not already provide it, via a lookup with the third-party geolocation service ipapi.co). We use this data to deliver and secure the page and to provide the card owner with view and interaction statistics for their card. Legal basis for delivering and securing the page: legitimate interests (Art. 6(1)(f)). A persistent visitor identifier and campaign (UTM) parameters are also stored in your browser, but only if you consent through the consent banner shown on the card page. See the Cookie Policy for the browser storage involved.
    • Visitor identification (with consent). With your consent, a third-party identification service (RB2B) may match your visit to a business identity and, where a match is found, provide your name, work email address, job title, company, LinkedIn profile, and location to the card owner as a lead in their contact list. The consent banner is shown to all visitors, worldwide, and the identification service runs only if you allow it through the banner, wherever you are located.
    • Google Fonts. Card pages load fonts from Google's servers (fonts.googleapis.com and fonts.gstatic.com), which discloses your IP address to Google when the page loads.

    Downloading a contact file or sharing a card does not require an account.

    Retention of view records. Card view records, including IP addresses and other IP-derived data, are retained for a maximum of 24 months and then deleted.

    10. Your Rights as a Lead or Viewer

    You have the rights described in Section 15 (access, erasure, rectification, restriction, objection, and others). Because the card owner is the controller of Lead Data:

    • The card owner is primarily responsible for handling your request. If you know who collected your details (usually the person whose card you interacted with or to whom you gave your card), you can contact them directly, including by replying to any message they send you.
    • You can always also contact us at privacy@bizkard.me. We will forward your request to the relevant card owner without undue delay, assist them in resolving it, and, where we are able and permitted, help remove your data. If you receive unwanted messages from a card owner, you can opt out via the message where an opt-out is provided, and report abuse to us.

    Retention of Lead Data. Lead Data is retained until the card owner deletes it, until the owner's account or workspace is deleted, or until a valid erasure or objection request is upheld. There is no automatic expiry.


    PART C - GENERAL PROVISIONS (All Data Subjects)

    11. Subprocessors and Third-Party Recipients

    We use a limited set of service providers to run BizKard, including hosting, payments, email delivery, and AI features. The current list, with each provider's function, the data involved, and location, is maintained on our [Subprocessor List](./06-Subprocessor-List.md), which we update with at least 30 days' notice of changes for DPA customers.

    We may also disclose personal data where required by law, to protect our rights or the safety of others, or in connection with a corporate transaction (merger, acquisition, reorganization), with notice where required.

    We never sell personal data.

    12. International Data Transfers

    Emelum OÜ is established in Estonia, but our hosting infrastructure (Lovable Cloud, built on Supabase) is located in the United States, and several vendors on our Subprocessor List are US companies. Where personal data is transferred outside the European Economic Area, we rely on:

    • the European Commission's Standard Contractual Clauses (SCCs) with each vendor, supplemented where appropriate by additional safeguards such as encryption in transit and at rest; and
    • for vendors certified under the EU-US Data Privacy Framework (DPF), that adequacy mechanism, with SCCs as fallback.

    You may request more information about the safeguards applicable to a specific transfer at privacy@bizkard.me.

    13. Children

    BizKard is not directed at children. You must be at least 16 years old to create an account, and users aged 16 to 17 must obtain parental consent for paid subscriptions. We do not knowingly collect personal data from anyone under 16; if we learn that we have, we will delete it.

    14. Security

    We apply technical and organizational measures appropriate to the risk, including: logical separation of customer accounts and workspaces enforced by database row-level security policies; encryption in transit (TLS) and at rest; role-based access controls and least-privilege staff access; logging of administrative actions; and backups. A summary of measures is also set out in Annex B of the DPA. No system is perfectly secure; if a personal data breach occurs that is likely to result in a risk to you, we will notify the competent authority and, where required, affected individuals in accordance with Articles 33 and 34 GDPR.

    15. Your Rights

    If you are in the EEA or UK (and in many other jurisdictions), you have the right to: access your personal data; rectify inaccurate data; erase data ("right to be forgotten"); restrict processing; data portability (a machine-readable copy of data you provided); object to processing based on legitimate interests, including direct marketing (an absolute right); and withdraw consent at any time without affecting prior processing. We do not make automated decisions about you that produce legal or similarly significant effects.

    Exercise these rights at privacy@bizkard.me. We respond within one month (extendable by two months for complex requests, with notice). We may need to verify your identity. Where the data sits in a customer's contact list or workspace for which the customer is controller, we will forward your request as described in Part B.

    16. Retention (Summary)

    • Account Data: for the life of your account, then deleted or anonymized within 30 days of a verified deletion request (see Section 17), except as noted below.
    • Card Data: until you unpublish or delete the card, or until account/workspace deletion.
    • Lead Data: until deleted by the controlling customer or until workspace/account deletion (see Section 10); no automatic expiry.
    • Billing records and invoices: 7 years after the end of the financial year, as required by Estonian accounting law.
    • Support correspondence: 24 months after the matter is closed.
    • Card view records (including IP addresses and other IP-derived data) and logs (including email send logs): maximum 24 months, after which they are deleted.
    • Email suppression and unsubscribe records: retained as long as needed to honor the opt-out.
    • After account closure, the deletion timelines in the Terms of Service (30-day export window, deletion within 90 days) apply.

    17. Account and Data Deletion

    You may request deletion of your account (or workspace) and associated personal data at any time by emailing privacy@bizkard.me from the email address on the account. In-product account or workspace deletion is not currently available. We will verify the request and complete deletion or anonymization within 30 days of verification [COUNSEL: deletion is currently a manual back-office process - confirm the 30-day commitment is operationally deliverable before publishing], except for data we must retain by law or need for the establishment or defense of legal claims. You can delete individual leads and cards in-product at any time; deleting a card also deletes its view records, while leads you captured survive card deletion until you delete them.

    18. Complaints

    If you are not satisfied with our response, you have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), Tatari 39, 10134 Tallinn, Estonia, www.aki.ee, info@aki.ee, or with the supervisory authority of your habitual residence, place of work, or the place of the alleged infringement.

    19. Changes to This Policy

    We may update this Policy from time to time. Material changes will be communicated through the platform or by email before they take effect, and the "Last updated" date will be revised. Prior versions are available on request.

    20. Contact

    Emelum OÜ (operating BizKard) Nõmme tn 30, Kärdla linn, Hiiumaa vald, 92412, Estonia Registry code 17234831 privacy@bizkard.me