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1. Introduction
2. Contact Information
3. What means personal data and processing of personal data?
4. Purpose of this Privacy Policy
5. Personal data we are processing
6. How do we protect your data?
7. Whom do we disclose your data to?
8. Third party links and content
9. Third-party websites and services
10. Transfer of personal data to a third country
11. Changes to this Privacy Policy
12. Users rights
13. Cookies and Similar Technologies
Doconomy AB is a private limited company incorporated in Sweden, with registration number 559163-0602, having its registered office at Östermalmsgatan 26A, Stockholm 114 26, Stockholm) and the controller of personal data covered in this privacy policy. If you have any questions regarding the processing of your personal data or this privacy policy, please contact us at: Doconomy AB Östermalmsgatan 26A 114 51 Stockholm Mail: privacy@doconomy.com
Personal data is widely defined by European Data Privacy law and includes all types of information that directly or indirectly can identify a natural person. This means that name, address, phone number are considered personal data, but that log data, encrypted data or other types of electronic ID such as an IP-Address can also be classified as personal data, if they can be connected to a natural person. Processing is similarly defined very widely by European law and includes almost every action taken in relation to personal data - for example collection, registration, organization, structuring, storage, adaption, transfer or deletion.
This Privacy Policy aims to provide you with some helpful information regarding our use of your personal data and to help you understand the rights you have in connection with your personal data. This Privacy Policy informs you of our policies regarding the collection, use and disclosure of Personal information when you use our Service. We will not use or share your information with anyone except as described in this Privacy Policy.
We strive to process as little personal data about you as possible. In this perspective, the Service require no login to be used. However, we may collect and process the following categories of personal data when you use the Service: Website/Mobile App Usage Data This personal data is collected about you when you are using the Service. It may include URL information, cookie data, your IP address, language. Location Information We collect the IP address you use to connect to the Service and - if you choose to share it - your location information from a mobile device. Device Information This personal data includes the type or types of devices you are using to access or connect to the website or the mobile app, device attributes, network connection type and provider, network and device performance, browser type and operating system. The above information might be collected from your device when you visit or use the Services, as outlined in the below “Cookies and Similar Technologies” section (Section 13). We believe that the benefits of our storage and use of your personal data outweigh any potential negative impact on you and that it will not unduly prejudice your rights or freedoms. To the extent that we process further data, we will obtain your consent or ensure that processing is authorized on another relevant legal basis.
Keeping your data safe is important to us. Therefore, we have taken appropriate technical, organizational and administrative security measures to protect your personal data from unauthorized access and other unauthorized processing. We regularly analyze and evaluate the measures in order to ensure that protection of your data is as safe as possible.
In some cases, we need to share your personal data with other parties. This could for example be the case where we need to provide information to public authorities. We also share your personal data with some of our suppliers that process data on our behalf, so called data processors. In the list below we specify what categories of recipients that we may share your data with:
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Business partners, for example banks and other financial institutes.
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Suppliers, for example suppliers of IT-infrastructure and hosting services, support services and other suppliers of software or business process services.
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Public authorities and courts.
The Service may include links to websites and services provided and maintained by third parties. Such third party websites and/or services may have their own terms of use and privacy policies and your use of such websites and/or services will be governed by and subject to such terms of use and privacy policies. You should review the terms of use and privacy policy for each website and/or service that you visit/use. You understand and agree that Doconomy does not endorse and is not responsible for the behavior, features or content of any such third party websites and/or services or for any transaction you may enter into with the provider of any such websites and/or services.
Our Service may from time to time contain links to third party websites that are not controlled by us. If you visit such websites or use such services, please be aware that this Privacy Policy does not apply for such third parties’ processing, and we encourage you to carefully review how such third parties process personal data before using their websites or services.
We strive to always choose suppliers established within the EU/EEA. However, we might need to transfer your personal data to suppliers and partners established outside the EU/EEA. Your personal data may, therefore, be subject to privacy laws that are different from those in your country of residence. The personal data that we collect from you may in limited cases be transferred to and processed in a country outside the EU/EEA (i.e. a so-called third country), including countries which the EU Commission does not consider to have an adequate level of protection for personal data. In such case we will take all necessary steps required under applicable law in order for such transfer of your personal data across borders to be compliant with applicable law. We will only transfer your personal data to a country outside the EU/EEA where; (i) the EU Commission has decided that the third country ensures an adequate level of protection, (ii) the transfer is being safeguarded by the use of EU model clauses (under Article 46.2 in the General Data Protection Regulation (2016/679) (”GDPR”)) and supplemented by the additional safeguards deemed necessary. For more information about the mechanisms that we rely upon to safeguard the transfer and processing, please contact us.
We are constantly working on improving and developing our Service, so we may change this Privacy Policy from time to time. We will not diminish your rights under this Privacy Policy or under applicable data protection laws in the jurisdictions in which we operate. If the changes are significant, we will provide a more prominent notice, when we are required to do so by applicable law. Please review this Privacy Policy from time to time to stay updated on any changes.
You have several rights under the GDPR related to you having control of your personal data and to receive information directly from us on how we process personal data about you. In the following you can read about your rights. If you want to know more or come in contact with us to exercise your rights, the easiest way is to email privacy@doconomy.com. Right to have personal data deleted (“Right to be forgotten”) In some cases, you have the right to have us delete personal data about you. For example, you can request us to delete such personal data that we no longer need for the purpose it was collected for, or that we process based on your consent and you revoke your consent. There are situations where Doconomy is unable to delete your data, for instance when the data is still necessary to process for the purpose for which the data was collected, Doconomy’s interest to process the data overrides your interest in having them deleted, or because we have a legal obligation to keep it. You also have the right to object to us using your personal data for certain purposes such as direct marketing, which you can read more about in this list of your rights. Right to be informed You have the right to be informed on what personal data that we process about you and how we do this. If you have any questions relating to how we process your data, you can always privacy@doconomy.com. Right to receive access to your personal data (“Subject access”) You have the right to know if Doconomy processes personal data about you, and to receive a copy (“data extract”) of such data, so-called subject access. Through the data extract you will receive information about what personal data Doconomy holds about you and how we process it. Right to access, and request a transfer, of your personal data to another recipient (“Data portability”) This right means that you can request a copy of the personal data relating to you that Doconomy holds for the performance of a contract with you, or based on your consent, in a machine-readable format. This will allow you to use this data somewhere else, for example to transfer your personal data to another controller/recipient. Right to rectification You have the right to request that we rectify inaccurate information or complete information about you that you consider is inaccurate or incomplete. Right to restrict processing If you believe that your personal data is inaccurate, that our processing is unlawful or that we do not need the information for a specific purpose, you have the right to request that we restrict the processing of such personal data. You also have the possibility to request that we stop processing your personal data while we assess your request. If you object to our processing per your right described directly below, you may also request us to restrict processing of that personal data while we make our assessment. Right to object against our processing of your personal data You have the right to object to processing of your personal data which is based on our legitimate interest, by referencing your personal circumstances. You can also always object to our use of your personal data for direct marketing purposes. When you let us know that you no longer wish to receive direct marketing from us, we will turn off marketing for you, and stop sending it to you. Right to withdraw one’s consent Where we process your personal data based on your consent or explicit consent, you have the right to revoke that consent at any time. When you revoke your consent, we will stop processing your data for such purposes. Right to lodge a complaint If you have complaints about Doconomy’s processing of your personal data, you may lodge a complaint with the national relevant authority.
We use tracking technology (such as cookies) on our Platform and app to help us understand and improve our service, as well as to understand your preferences. Cookies are text files placed on your computer/app to collect standard internet log information and visitor use of the Service and to compile statistical reports on the Service. You may set your browser not to accept cookies. However, in a few cases some of our Service features may not function as a result. Our Service thus uses cookies to distinguish you from other users of our Service. This helps us to provide you with a good experience when you use our Service and also allows us to improve our Service. Understanding of how the Service is used, particularly in relation with behavioural and tracking details: e.g. location data, behavioural patterns, personal preferences, IP-number, cookie identifiers, unique identifier of devices you use to access and use the Service. You can control cookies via the cookie panel at the bottom of this page.
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To enable you to use the Service.
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To improve the functioning of our website.
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IP-address and approximate geographical address.
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Technical information (IP-address and approximate geographical address, serial number for the unit that is being used). Behavioral information such as what sites and links you have clicked on.
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For the duration of 12 months