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Legal

Privacy policy

Last updated: October 20, 2026

Winnen is a communication platform for small businesses: one inbox for texts, calls, webchat and email, plus appointments, payment links, reviews and an AI assistant. This policy explains what personal data we process when you use the Winnen app (iOS, Android and web), our website winnen.app, and our services — and what your rights are.

Winnen is based in Almere, the Netherlands. We process personal data under the EU General Data Protection Regulation (GDPR).

Two roles: our customers and their customers

For the people who sign up for Winnen and use it at work — business owners and their team members — Winnen is the data controller.

For the customers of those businesses (the people who text, call, email or book with them), the business is the data controller and Winnen processes that data on the business's behalf, as a processor. If you are a customer of a business that uses Winnen, please contact that business first about your data; we will help them answer your request.

What we collect

  • Account data: name, email address, phone number, password (stored hashed), language and role within the business.
  • Business data: business name, address, opening hours, services, team members and settings you enter.
  • Communication content: text messages, emails, webchat messages, internal notes, call details (who called whom, when and for how long), and — where the business has enabled them — call recordings, voicemails and transcripts.
  • Contact records: names, phone numbers, email addresses and other details a business stores about its customers.
  • Appointments, invoices and payment status. Card payments are handled by Stripe; Winnen never sees or stores full card numbers.
  • Reviews and review replies, when a business connects its Google Business Profile.
  • Device and app data: push notification tokens, device type, app version and diagnostic logs needed to deliver calls and notifications reliably.
  • Website data: if you accept analytics cookies on winnen.app, Google Analytics measures visits. Without your consent no analytics cookies are set.

Microphone, calls and notifications

The Winnen app uses your microphone only during a call you place or answer, and — if you use it — for voice dictation while you type a reply. It does not listen in the background.

To ring your phone for incoming business calls, the app uses Apple VoIP push and CallKit (iOS) and Firebase Cloud Messaging (Android). These services receive a device token and the minimum call details needed to show the incoming call.

How we use data

  • To provide the service: route calls and messages, show the shared inbox, send the messages you write, book appointments, and send payment and review requests.
  • To run AI features a business switches on: answering calls, summarising calls, and drafting reply suggestions. AI processing runs on our own infrastructure and that of our telephony provider, Telnyx.
  • To keep Winnen secure and working: preventing abuse, fixing bugs and keeping logs.
  • To communicate with you about your account, billing and important changes.
  • To meet legal obligations, such as tax and accounting rules.

Legal bases

We process account and business data to perform our contract with you (GDPR art. 6(1)(b)), security and service-improvement data on the basis of our legitimate interests (art. 6(1)(f)), website analytics only with your consent (art. 6(1)(a)), and records we must keep by law under art. 6(1)(c). For data we process as a processor, the business that uses Winnen determines the legal basis.

Who we share data with

We do not sell personal data. We share it only with service providers that help us run Winnen, under data processing agreements:

  • Hetzner — server hosting and databases, in Germany (EU).
  • Telnyx — phone numbers, calls, SMS, call recordings, transcription and AI voice. Telnyx may process data in the United States.
  • Mailgun — sending and receiving email, EU region.
  • Stripe — payments and payouts for businesses that accept payments.
  • Google — Google Calendar sync and Google Business Profile reviews when a business connects them, Firebase Cloud Messaging for Android notifications, and Google Analytics on our website with consent.
  • Apple — push notifications and CallKit on iOS.

International transfers

Where a provider processes data outside the European Economic Area — for example Telnyx in the United States — we rely on the EU–US Data Privacy Framework where the provider is certified, or on the European Commission's Standard Contractual Clauses, together with additional safeguards where needed.

How long we keep data

We keep account, business and communication data for as long as the business's Winnen account is active, because the inbox history is part of the service. Raw copies of incoming emails are deleted after 90 days. Call recordings and AI transcripts follow the retention period the business sets. When an account is closed, we delete or anonymise its data within 30 days, except where the law requires us to keep it longer (for example invoices, which we keep for 7 years under Dutch tax law).

Security

Data is encrypted in transit (HTTPS/TLS), passwords are stored hashed, access is limited to staff who need it, and every business's data is kept separate from every other business's. Provider webhooks are signature-verified before we act on them.

Your rights

You have the right to access, correct, delete, restrict or object to the processing of your personal data, and to receive it in a portable format. Where we rely on consent, you can withdraw it at any time. To use these rights — including deleting your Winnen account — email us at hello@winnen.app. We answer within one month.

You also have the right to complain to a data protection authority. In the Netherlands that is the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl).

Children

Winnen is a business tool and is not intended for children under 16. We do not knowingly collect their data.

Changes to this policy

We may update this policy as Winnen changes. The date at the top shows the latest version. If a change materially affects how we use your data, we will tell account holders by email or in the app.