Privacy Policy

1. Who we are

Whistlechannel is operated by Manpro AB (org. no. 556699-1807). For our own website, account and billing data we act as the controller. For the report data that a customer organisation collects through its channel, that customer is the controller and we act as their processor under the Data Processing Agreement.

2. Data we process

• Account & billing: name, work email, organisation, and payment/subscription details (payment card data is handled by our payment processor, not by us).
• Report data (as processor): the content a reporter submits, case status, messages and any attachments. Reporters may omit identifying details, but their voice, attachments and report contents can identify them.
• Technical: minimal operational logs. We do not log reporters’ IP addresses, and analytics are suppressed on reporter and anonymous pages.

3. Legal bases

• Providing the service and administering accounts — performance of a contract (GDPR Art. 6(1)(b)).
• Security, fraud prevention and service improvement — legitimate interests (Art. 6(1)(f)).
• Legal and compliance obligations, including support of EU Directive 2019/1937 documentation — legal obligation (Art. 6(1)(c)).

4. EU data residency & transfers

Report data is hosted within the EU/EEA and served from EU-only edge locations. We do not use US cloud providers for report content. Payment is handled by a separate processor (see sub-processors); billing data may be processed by that processor’s EU entity. AI-assisted categorisation runs on our own EU infrastructure; no third-party or US AI provider receives report content.

5. Sub-processors

We engage a small number of sub-processors to run the service. The current list, their location and data scope is published at /subprocessors.

6. Retention

As processor, we retain report data for as long as the customer’s configured retention period and applicable law require, then delete or return it. Account and billing data is retained for the life of the account and for the period required by accounting law thereafter.

7. Security

TLS protects data in transit. Sensitive report fields and private attachments use server-side AES-256-GCM encryption. The application decrypts for authorised users and server-side analysis; operators with access to the service and its keys can also decrypt. We hold no ISO 27001 certification or SOC 2 attestation. We make no blanket guarantee of NIS 2 or AI Act compliance.

8. Your rights

Under the GDPR you may request access, rectification, erasure, restriction, portability, and object to processing. For account/site data, contact us below. If your data was submitted through a customer’s channel, the customer is the controller — we will assist them in responding to your request.

9. Cookies

Necessary cookies and local storage support authentication, security, language and theme preferences, and access to encrypted reports. These work without analytics consent.

When Matomo analytics is configured, we ask for your permission before loading it on public information pages. Matomo runs without analytics cookies and receives page paths without query strings or referrers. We do not use session replay or automatic form tracking. No visitor analytics is sent from sign-in, registration, organisation channels, report forms or anonymous follow-up pages.

You can accept or reject optional statistics in the cookie banner and change your choice using “Cookie settings”. Your choice is stored locally for up to 180 days. Rejecting or withdrawing consent does not affect access to the service. Withdrawing consent stops further analytics; it does not undo statistics already sent while consent was active.

10. Contact

Data-protection contact: mikael@manpro.se. You also have the right to lodge a complaint with your supervisory authority (in Sweden, the Integritetsskyddsmyndigheten, IMY). See our contact page for full company details.