Privacy policy

Last updated: September 28th, 2022

The privacy of your data—and it is your data, not ours!—is a big deal to us. In this policy, we lay out: what data we collect and why; how your data is handled; and your rights with respect to your data. We promise we never sell your data: never have, never will.

This policy applies to all products built and maintained by Intrepid Labs OÜ, including Konbini.

What we collect and why

Our guiding principle is to collect only what we need. Here’s what that means in practice:

Identity & access

When you sign up for an Intrepid Labs product, we ask for identifying information such as your name, email address, and maybe a company name. That’s so you can personalize your new account, and we can send you product updates and other essential information. We may also send you optional surveys from time to time to help us understand how you use our products and to make improvements. With your consent, we will send you our newsletter and other updates. We sometimes also give you the option to add a profile picture that displays in our products.

We’ll never sell your personal information to third parties, and we won’t use your name or company in marketing statements without your permission either.

Billing information

If you sign up for a paid Intrepid Labs product, you will be asked to provide your payment information and billing address. Credit card information is submitted directly to our payment processor and doesn’t hit our servers. We store a record of your subscription in order to provide you with the service you paid for. We occasionally use aggregate billing information to guide our marketing efforts.

Product interactions

We store on our servers the content that you upload or receive or maintain in your Intrepid Labs product accounts. This is so you can use our products as intended, for example, to create apps and interact with merchants in Konbini. We keep this content as long as your account is active. If you delete your account, we’ll delete the content within 60 days.

Website interactions

We collect information about your browsing activity for analytics and statistical purposes such as conversion rate testing and experimenting with new product designs. This includes, for example, your browser and operating system versions, your IP address, which web pages you visited and how long they took to load, and which website referred you to us. If you have an account and are signed in, these web analytics data are tied to your IP address and user account until your account is no longer active. The web analytics we use are described further in the Advertising and Cookies section.

Advertising and Cookies

We use persistent first-party cookies and some third-party cookies to store certain preferences, make it easier for you to use our applications, and perform A/B testing as well as support some analytics.

A cookie is a piece of text stored by your browser. It may help remember login information and site preferences. It might also collect information such as your browser type, operating system, web pages visited, duration of visit, content viewed, and other click-stream data. You can adjust cookie retention settings and accept or block individual cookies in your browser settings, although our apps won’t work and other aspects of our service may not function properly if you turn cookies off.

Voluntary correspondence

When you email Intrepid Labs with a question or to ask for help, we keep that correspondence, including your email address, so that we have a history of past correspondence to reference if you reach out in the future.

We also store information you may volunteer, for example, written responses to surveys. If you agree to a customer interview, we may ask for your permission to record the conversation for future reference or use. We will only do so with your express consent.

When we access or share your information

To provide products or services you’ve requested. We use third party subprocessors, such as cloud computing providers and customer support software, to run Konbini (the service). We establish GDPR-compliant data processing agreements with each subprocessor, extending GDPR safeguards everywhere personal data is processed.

The following is a list of personal data subprocessors we use.

We may share your information at your direction if you integrate a third-party service into your use of our products.

No human at Intrepid Labs looks at your content except for limited purposes with your express permission, for example, if an error occurs that stops an automated process from working and requires manual intervention to fix. These are rare cases, and when they happen, we look for root cause solutions as much as possible to avoid them recurring. We may also access your data if required in order to respond to legal process (see “When required under applicable law” below).

To help you troubleshoot or squash a software bug, with your permission. If at any point we need to access your content to help you with a support case, we will ask for your consent before proceeding.

To investigate, prevent, or take action regarding restricted uses. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We want to protect the privacy and safety of both our customers and the people reporting issues to us, and we do our best to balance those responsibilities throughout the process. If we discover you are using our products for a restricted purpose, we will take action as necessary, including notifying appropriate authorities where warranted.

When required under applicable law.

Intrepid Labs OÜ is an EU company, and all data infrastructure is located in the EU.

  • Requests for user data. Our policy is to not respond to government requests for user data unless we are compelled by legal process or in limited circumstances in the event of an emergency request. However, if EU law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring us to share data, we must comply. Likewise, we will only respond to requests from government authorities outside the EU if compelled by the government through procedures outlined in a mutual legal assistance treaty or agreement. It is our policy to notify affected users before we share data unless we are legally prohibited from doing so, and except in some emergency cases.
  • Preservation requests. Similarly, Intrepid Labs' policy is to comply with requests to preserve data only if required by law. We do not share preserved data unless required by law or compelled by a court order that we choose not to appeal. Furthermore, unless we receive a proper warrant, court order, or subpoena before the required preservation period expires, we will destroy any preserved copies of customer data at the end of the preservation period.
  • If we are audited by a tax authority, we may be required to share billing-related information. If that happens, we will share only the minimum needed, such as billing addresses and tax exemption information.

Finally, if Intrepid Labs OÜ is acquired by or merges with another company — we don’t plan on that, but if it happens — we’ll notify you well before any of your personal information is transferred or becomes subject to a different privacy policy.

Your rights with respect to your information

At Intrepid Labs, we strive to apply the same data rights to all customers, regardless of their location. Some of these rights include:

  • Right to Know. You have the right to know what personal information is collected, used, shared or sold. We outline both the categories and specific bits of data we collect, as well as how they are used, in this privacy policy.
  • Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
  • Right to Correction. You have the right to request correction of your personal information.
  • Right to Erasure / “To Be Forgotten”. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, from all of our service providers. Fulfillment of some data deletion requests may prevent you from using Intrepid Labs services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
  • Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority.
  • Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of personal information. (Again: we never have and never will sell your personal data.)
  • Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
  • Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party.
  • Right to not Be Subject to Automated Decision-Making. You have the right to object to and prevent any decision that could have a legal or similarly significant effect on you from being made solely based on automated processes. This right is limited if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.
  • Right to Non-Discrimination. We do not and will not charge you a different amount to use our products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights may, by virtue of your exercising those rights, prevent you from using our Services.

Many of these rights can be exercised by signing in and updating your account information.

If you have questions about exercising these rights or need assistance, please contact us at privacy@usekonbini.com or at Intrepid Labs OÜ, Sepapaja tn 6, 15551 Tallinn, Estonia. If an authorized agent is corresponding on your behalf, we will need written consent with a signature from the account holder before proceeding.

If you are in the EU or UK, you can contact your data protection authority to file a complaint or learn more about local privacy laws.

How we secure your data

All data is encrypted via SSL/TLS when transmitted from our servers to your browser, as well as to API clients. All persistent data (including database backups) is encrypted at rest.

What happens when you delete content in your product accounts

In many of our applications, we give you the option to delete or trash content. Where possible, deleted content will be deleted immediately. Sometimes this may take longer for technical reasons, and sometimes we may need to keep some of it around for a while longer, such as usage data we need to bill you correctly.

If you choose to delete your account, your content will become immediately inaccessible and should be purged from our systems in full within 60 days.

Location of site and data

Our products and other web properties are operated in the European Union. If you are located outside of the European Union, please be aware that any information you provide to us will be transferred to and stored in the European Union. By using our websites or Services and/or providing us with your personal information, you consent to this transfer.

Your data may also be transferred to locations outside of the EU, for purposes such as caching and payment processing. We try to keep instances of this to a minimum.

EU privacy law

In order to comply with EU privacy law, Intrepid Labs has adopted a data processing addendum with Standard Contractual Clauses. Our DPA is available at https://usekonbini.com/policies/dpa.

Customers who prefer to have an executed copy of our Data Processing Addendum should contact us. Regardless of whether it is executed, we protect and secure customer data to the standards set out in the addendum.

There are a few ad hoc cases where EU personal data may be transferred outside of the EU in connection with Intrepid Labs OÜ operations. Such transfers are only occasional and data is transferred under the Article 49(1)(b) derogation under GDPR and the UK version of GDPR.

Changes & questions

We may update this policy as needed to comply with relevant regulations and reflect any new practices. Whenever we make a significant change to our policies, we will refresh the date at the top of this page and take any other appropriate steps to notify users.

Have any questions, comments, or concerns about this privacy policy, your data, or your rights with respect to your information? Please get in touch by emailing us at privacy@usekonbini.com and we’ll be happy to try to answer them!


Adapted from the Basecamp open-source policies / CC BY 4.0