GärdsmygenData processing agreement
Version 2026-10-08. Part of the terms for Gärdsmygen.
1. Parties
The association is the controller of the personal data in its Gärdsmygen. The processor is the provider (named before sign-up opens), which processes it only on the association's behalf, under this agreement and the General Data Protection Regulation (GDPR), article 28.
2. The processing
- Purpose: to let the board run the association in Gärdsmygen: the mail to the board, cases, meetings and decisions, the year's tasks, the finances, documents, registers and contacts.
- Data subjects: the board members, the association's members and residents, those who write to the board, suppliers and contact persons.
- The data: names, contact details, apartment numbers, the content of letters and cases, minutes and decisions, invoices and registers. Letters can hold sensitive data that someone wrote themselves; it is processed only as part of the case. Personal identity numbers are not stored.
- Connected mailbox: when the board connects its email, the processor reads new mail in the mailbox's inbox (sender, recipients, subject, text and attachments up to 4 MB) and sends the replies a board member confirms from it. Nothing in the mailbox is changed or deleted.
- Duration: as long as the association uses Gärdsmygen, and after that until the data is removed under section 8.
3. Instructions and confidentiality
The processor processes the data only under this agreement and the association's use of Gärdsmygen, and says so if an instruction would break the data protection rules. Those working for the processor who can reach the data are bound to confidentiality and do so only when the service needs it, for example to help the association at its request.
An administrator switching on Help with drafts is the association's instruction to let the sub-processor for Help with drafts (section 5) process the text, and the choice to also write suggestions as letters arrive is an instruction for those letters. The processor records when it was chosen and by whom, and every change of the choice in the association's audit log. No new text is sent after the help has been switched off.
4. Security
- The association's data is stored in a shared database in the EU (Frankfurt), where the database itself separates each association's rows from the others' (row-level security) and every access is made on behalf of a single association.
- Encrypted connections (HTTPS) and login with a one-time link or code, without passwords.
- Access levels for the board, and keys stored encrypted.
- The access to a connected mailbox (a key from Google or Microsoft, or the password for another email service) is stored encrypted and removed when the mailbox is disconnected.
- No tracking of who opens letters or links.
- Backups of the database with the hosting provider.
5. Sub-processors
- Netlify, Inc.: hosting and database. The association's data is stored in Frankfurt.
- Lettermint B.V. (the Netherlands): mail to and from Gärdsmygen, with servers in the EU.
- Anthropic, PBC (USA): the language model behind Help with drafts, which is used only for an association whose administrator has switched it on. The association's name, the text of a case, a board member's question or wish, the meeting's details (attendees, agenda, decisions), year planner entries, the text of files read in with Flytta in, excerpts from the association's documents and the template's draft are sent there, after personal identity numbers, email addresses, phone numbers and long account and card numbers have been replaced by placeholders. The transfer to the USA rests on the European Commission's standard contractual clauses, which are part of Anthropic's data processing agreement.
- Gärdsmygen can instead run the same language model within the EU, at Amazon Web Services (Amazon Bedrock, Stockholm region) or Google Cloud (Vertex AI, in the EU). That is used only if the processor moves the processing there; the association is then told as for a new sub-processor, and the text is then processed within the EU. An association that chose Help with drafts while the text was processed within the EU does not get it outside the EU unless an administrator chooses again.
The board's own email service (for example Google, Microsoft or the association's web host) is not a sub-processor of the processor: the association has its own agreement with it, and Gärdsmygen fetches and sends mail there on the association's behalf once the board has connected the mailbox.
The association approves these. The processor gives at least 30 days' notice before a new sub-processor is used; the association can then object and end the agreement. Netlify, Inc. and Anthropic, PBC are American companies. The data at Netlify is stored in Frankfurt; should it be transferred to the USA, that happens under Netlify's data processing agreement and the EU's rules for such transfers. The text sent to Anthropic is processed in the USA under the European Commission's standard contractual clauses.
6. Help to the association
The processor helps the association answer when someone asks for access to, correction or erasure of their data, and with impact assessments when needed. A personal data breach is reported to the association without delay and at the latest 48 hours after the processor discovers it.
7. Audit
The processor gives the association the information needed to show that the agreement is kept. The association can audit the processing with 30 days' notice, at its own cost.
8. When the agreement ends
The association can have a copy of its data. The data is removed at the latest 90 days after the agreement ends, and the backups within 30 days after that.