Privacy Policy
May 2018
Your privacy is important to RewardSmarter Sweden AB. In order to help you feel secure when you visit our website or use our services, we have created this Privacy Policy, which describes how RewardSmarter Sweden AB processes, stores and manages your personal data.
Using our website and/or services constitutes an approval of this Privacy Policy.
Data Controller
In this policy, RewardSmarter Sweden AB, VAT SE559104680901, is called RewardSmarter and acts as the data controller, while you or your company shall be called the user or client.
RewardSmarter is responsible for all personal data which you submit by using the services, through our website, on the phone, via email or social media, or directly through courses, seminars, trade shows, etc.
You can contact RewardSmarter in the following ways:
Mail: RewardSmarter Sweden AB, P.O. Box 5013, 102 41 Stockholm, Sweden
Email: info@rewardsmarter.com
Scope of the Privacy Policy
This Policy is applicable to users who visit, register themselves on and/or send messages through the websites rewardsmarter.com and lonekartlaggning.se, or who contact RewardSmarter on social media. It is also applicable for the signing of contracts and for usage of our services.
Personal data is information which on its own or in combination with other information can be used to identify you, the user, as a natural person. This could for example be your name, your email address or your telephone number.
The Data Which Is Collected, and How It Is Used
Our main aim in processing your personal data is in order to allow RewardSmarter to fulfills its obligations to you as a user/client. However, we also collect information about users who are not clients, but who would like to be contacted by us.
RewardSmarter acts as data controller for the processing which is listed in the table Personal Data Processing Activity below.
As the data controller, RewardSmarter is responsible for ensuring that your personal data is processed in a secure way, and in accordance with GDPR. We do not sell customer information to third parties.
Security and Sharing of Personal Data
RewardSmarter protects your personal data in accordance with GDPR. In cases where RewardSmarter shares personal data with external parties, for example for administrative processes regarding mailers, contracts, invoicing etc., RewardSmarter acts as the data controller, while its subcontractors act as data processors. The data processors must follow instructions from RewardSmarter as well as RewardSmarter’s policies and may not share your personal data with anyone else, or use it for purposes other than what is covered by the instructions from RewardSmarter. The data processors are also obligated to ensure certain technological and organizational measures are taken in order to protect your personal data.
Personal data may also be shared in cases where this is required by law, regulations or decisions from authorities.
The Use of Cookies
Our websites use cookies. Cookies are small text files which are stored on the visitor’s computer and which, among other things, save their personal settings and follow the visitor’s activity on the website. There are several types of cookies. Session cookies are used when the visitor is active on the website. These cookies are only saved temporarily on the user’s computer (within the working memory) and are automatically removed once the user closes their browser. Permanent cookies are used to tell the visitor what has happened on the website since their last visit, and to identify returning users, as well as to remember information which has previously been submitted.
The RewardSmarter websites also use third party cookies for Google Analytics. Google Analytics collects statistics regarding number of visits, number of individual page visits, which websites the visitors come from, and which search engines and keywords are used to access our website. The aim is to give us an understanding of how our website is used, and how we can improve it. For this purpose, we collect information about domain names, browsers and operating systems, the time at which you accessed our websites and which link (if any) you used to do so. This information is only used internally and is not shared with external parties.
The majority of browsers are set to accept cookies. If you do not want cookies to be stored on your computer, you can set your browser to alert you when it receives a cookie. You can then decide where you would like to accept the cookie or not.
Links
RewardSmarter’s website includes links to other websites. This policy does not apply to those external websites. You should read the individual privacy policies for those websites before sharing your personal data.
How Is Personal Data Used for Direct Marketing?
RewardSmarter uses direct marketing via email to offer relevant information and campaigns to you as a client, or to those who show an interest in becoming clients. We also market our services to parties who we believe may be interested in them.
RewardSmarter complies with the Swedish marketing law (Marknadsföringslagen) and follows the SWEDMA ethical guidelines regarding direct marketing.
The Right to Information and to Correction
If your information is registered by RewardSmarter, you have the following rights:
- You have the right to be informed about which personal data processing activities we are conducting. These have been compiled in the table Personal Data Processing Activities. In the table, you can see purposes, legal basis and storage periods.
- You have the right to request an excerpt from our register, where you can see which data processing activity is being performed on your personal data, and what the purpose of this activity is.
- You have the right to demand a correction if we have erroneous or incomplete information about you.
- You have the right to be erased from our system if the following conditions are met:
- The data is no longer required for the purpose(s) is was collected for.
- If the data has been collected with your consent and you revoke this consent.
- If the processing is based on balancing of interest and there are no legitimate reasons for this use which supersede your request.
- If your personal data has been processed illegally.
- If you object to the processing of personal data for direct marketing purposes.
The right to be erased is not applicable if RewardSmarter is legally required to store the data, for example in accordance with Swedish accounting legislation (Bokföringslagen).
- You have the right to data portability (the right to have your personal data moved), provided that the legal grounds for this is consent or an agreement. You have the right to move personal data which regards you, which you yourself have provided, or which has been generated by your actions/activity.
- You have the right to request limited processing. However, you do not have the right to have this request granted if the processing is required in order to supply the services.
- You have the right to object to a processing data activity. RewardSmarter will then cease this processing while the matter is investigated.
- You have the right to complain to the Swedish Data Protection Authority (Datainspektionen) regarding processing which is conducted by RewardSmarter.
If you would like to invoke any of these rights, please send an email to info@rewardsmarter.com.
Personal Data Processing Activity | Aim | Personal Data Categories | Type of Registered Entity | Legal Basis | Storage Time |
Service purchase | To deliver the services | Contact and invoicing information | Clients | Contract | Contract duration + 1 year |
Subscription services | To create an account in order to allow access to the services | Login information, invoicing and contact information | Clients | Contract | Contract duration + 1 year |
Visiting the website | Analysis and follow-up | Cookies, IP address | Website visitors | Weighing of interests | 14 months |
Registering for seminars etc. | To deliver the services | Contact information |
Clients, potential clients |
Contract, consent | Contract duration + 1 year |
Direct marketing | To offer services, information | Contact information | Clients | Weighing of interests |
Contract duration + 1 year |
Registration for newsletter online | To deliver the services | Contact information |
Clients, potential clients |
Consent | Contract duration + 30 days |
Email address for direct marketing | Marketing | Email address | Potential clients | Weighing of interests | 30 days |
Subcontractor registration | To contact subcontractors for purchases/support | Contact information | Subcontractors | Contract + weighing of interests | Contract duration + 1 years |
Contact via telephone, email, social media | Information for, and completion of, contacts | Contact information | All categories |
Contract + weighing of interests |
2 years |
Storing data in the cloud | For data controller purposes and to store data | All personal data categories | All categories |
Contract + weighing of interests |
Contract duration + 1 year |
Backup of stored data in the cloud | To secure data access in case of intended or unintended loss | All personal data categories | All categories |
Contract + weighing of interests |
1 year after the contract ends |
* Contact information includes name, occupation, address, telephone number and email address
** Billing information includes company name, VAT number, billing address, reference person and ref. ID
Changes to the Privacy Policy
If minor changes are made to this Privacy Policy, RewardSmarter will publish the amended policy on the website with information regarding when the changes take effect. If significant changes are made to the Privacy Policy, all persons who are affected by the change will be informed via email.