PRIVACY POLICY

Last updated July 14, 2021

1. Introduction

We are committed to protecting your Personal Data and your right to privacy. In this Privacy Policy, we therefore seek to explain to you in the clearest way possible what Personal Data we Process, how we use it and what rights you have in relation to it.

When you visit our website (the "Website", accessible from adatype.ai and adatype.se), use our mobile application, as the case may be (the "App") and more generally, use any of our services (the "Services", which include both the Website and App), we appreciate that you are trusting us with your Personal Data. This Privacy Policy applies to all Processing of Personal Data collected through our Services (which, as described above, includes our Website and App), as well as any related services, sales, marketing or events.

Adatype is the data controller of all Processing of your Personal Data that Adatype performs in accordance with this Privacy Policy. If you have any questions or concerns about this Privacy Policy (“the Privacy Policy”), or our practices with regards to your Personal Data, please contact us at privacy@adatype.ai.

Please read this Privacy Policy carefully as it will help you understand what we do with the Personal Data that we collect. 

2. Definitions

In this Privacy Policy, the term "Personal Data" means any information relating to an identified or identifiable natural person, such as name, address, date of birth, age, gender, account number, e-mail address, and telephone number.

"Processing" means any operation or set of operations which is performed by us on your Personal Data or on sets of Personal Data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction as described in this Privacy Policy.

3. Summary

In this schedule, we have summarized what Personal Data we Process when you use the Services, for what purposes and with what legal basis. You can read more about our Processing below.

Category of Personal Data

Purpose

Legal basis

Storage

Contact information, such as your name, your e-mail address or your telephone number

Communication with you regarding the Services

 - Our legitimate business interest



Maximum storage of 2 years after finished subscription

Device data, for example your IP-address

- Administration of and facilitating the Services

- Marketing purposes

- Provision of Application

 - Our legitimate business interest

- Your consent

Maximum storage of 2 years after finished subscription

Sensitive Personal Data

Indirect Processing which we could carry out in case you use the Services for writing Sensitive Personal Data

Your consent

Maximum storage of 2 years after finished subscription

Biometric Data

- Adjusting the Services for your usage

Your consent

Maximum storage of 2 years after finished subscription

4. What Personal Data do we Process?

In order to provide the mobile application and the Services in connection therewith, we collect and Process Personal Data. The Personal Data we might Process, depending on your contact with us, are for example:

  • Your name, e-mail address, phone number, gender, your password of choosing and your geographical location;
  • Your behavioral patterns, and statistics following from your usage of our Services;
  • Information regarding your unit which you use in order to use the Services, for example your IP address, your operating system and other technical information;
  • Keystrokes, which is information gathered from your usage of the Services.

Adatype will Process all information written by you using the App. If you use the App for writing Sensitive Data, this Sensitive Data will be Processed by Adatype.  We may therefore, as it might be necessary for usage of the App’s functionalities and usage and/or provision of our products and Services, collect, receive, possess, store, deal or handle, directly or indirectly, the following Sensitive Personal Data from you by virtue of your use of our Services:

  • Password;
  • Financial information such as bank account or credit card or debit card or other payment instrument details;
  • Physical, physiological and mental health condition;
  • Sexual orientation;
  • Medical records and history;
  • Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs;
  • Trade-union membership and
  • Biometric information, which is Processed when your keystrokes are analyzed.

These categories of Personal Data are referred to as (“Sensitive Data”) in this Privacy Policy. Keeping your best interest in mind, we retain and use such Sensitive Data only for as long as is required as per the purpose for which the Sensitive Data is collected or otherwise required to comply with our legal obligations

The Personal Data that we Process, is that which you provide to us in connection with use of the App and other services which are provided by Adatype, including our Website and when you communicate with us in any other way. We do not collect any Personal Data about You from any third party.

Adatype only collects Personal Data that is necessary and relevant for the purposes described in section 5 below. What Personal Data We collect about you depends on the context of your interactions with Adatype.

You can make choices regarding certain Personal Data that we collect. When you are asked to provide Personal Data, you can choose to decline. In those cases that you choose not to provide information necessary to access a particular Service, you might not be able to use the specific Service.

5. How do we use the information we collect, for what purpose and on what legal ground?

We Process your Personal Data for specific purposes and based on one of the following legal bases: legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent. We indicate for what purpose we Process Personal Data and on what legal basis we rely on below.

  • To deliver and facilitate delivery of Services to the user. We may use your Personal Data to provide you with the requested Service. The legal basis for such Processing is to fulfil our obligations towards you following from the contract we have entered into.
  • To maintain and improve the security and operation of our Services, for troubleshooting and our internal analytics and reporting purposes. The legal basis for such Processing is our legitimate interest of developing our Services.
  • To post testimonials. We post testimonials on our Services that may contain Personal Data. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at hi@adatype.ai and be sure to include your name, testimonial location, and contact information. The purpose with such Processing is to market our Services, and the legal basis for such Processing is your consent.
  • Request feedback. We may use your Personal Data to request feedback and to contact you about your use of our Services.
  • To manage user accounts. We may Process your Personal Data for the purposes of managing your user account and keeping it in working order. The legal basis for such Processing is the contract we have entered into, since it is our obligation to provide you with a functional Service.
  • To respond to user inquiries/offer support to users. We may Process your Personal Data to respond to your inquiries and solve any potential issues you might have with the use of our Services. Our legal basis for such Processing is our legitimate business interest.
  • To send you marketing and promotional communications. We and/or our third-party marketing partners may use the Personal Data you send to us for our marketing purposes if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Services, subscribing to marketing or otherwise contacting us, we will Process your Personal Data. Our legal basis for such Processing is your consent. You can always opt-out of our marketing emails at any time (see the section "What are your privacy rights?" below).
  • Deliver targeted advertising to you. We may Process your Personal Data in order to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. Our legal basis for this is our legitimate interest of marketing our products.
  • For other business purposes. We may Process your Personal Data for other legitimate business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing and your experience. Our legal basis for such Processing is our legitimate business interest, and we will therefore perform a balancing of interests before using your Personal Data for this Processing.

6. Will your Personal Data be shared with anyone?

We may need to share your Personal Data with third parties in the following situations:

  • Business transfers. We may share or transfer your Personal Data in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Vendors, consultants and other third-party service providers. We may share your Personal Data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such Personal Data to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data on our behalf about how you interact with our Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity.

Unless described in this Privacy Policy, we do not share, sell, rent or trade any of your Personal Data with third parties for their promotional purposes. When we share your Personal Data to a third party that performs Processing on our behalf, we continue to act as data controllers for this specific Processing. We have contracts in place with our data processors, to safeguard your Personal Data. This means that the data processors cannot do anything with your Personal Data unless we have instructed them to do it. They will also not share your Personal Data with any organization apart from us. They also commit to protect the Personal Data they Process on our behalf and to retain it for the period we instruct. We are fully responsible for the Processing carried out by our data processors.

We only share and disclose your Personal Data with the third parties listed below. We have categorized each third party so that you may be easily understand the purpose of our data collection and Processing practices. If we have Processed your Personal Data based on your consent and you wish to revoke your consent, please contact us using the contact details provided in section 15 below.

  • Cloud Computing Services. We use Google Cloud Platform.
  • Data Backup and Security. We use Google Cloud Storage.
  • Functionality and Infrastructure Optimization. We use Google Cloud Storage, BigQuery and Termly.io.
  • Web and Mobile Analytics. We use Google Analytics, Google Analytics for Firebase, Google Tag Manager, Google Data Studio, HubSpot Analytics, Firebase Predictions and other Firebase services.
  • Website Hosting. We use Tilda.
  • Performance Monitoring. We use Firebase Performance Monitoring and Crashlytics.
  • Website Testing. We use Google Play Console and Firebase Remote Config.
  • Communicate & Chat with Users. We use HubSpot Email and Firebase Cloud Messaging.
  • Advertising, Direct Marketing, and Lead Generation. We use HubSpot CRM, HubSpot Lead Management, Google Ads, Facebook advertising and Facebook Audience Network.

7. International transfers

The Personal Data that we Process may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be Processed by subcontractors or staff operating outside the EEA who work for us or for one of our suppliers. The third-party subcontractors and suppliers may, for example, be software and data storage providers, business consultants or be engaged in the development of the Services, provision of payment processing services and the provision of support services.

We ensure that an adequate level of protection is maintained, and that suitable safeguards are adopted in line with applicable data protection legislation requirements, such as the GDPR, when we transfer your data outside the EU/EEA. These safeguards consist of ensuring that the third party country is subject to an adequacy decision by the European Commission or by implementing the European Commission’s standard contractual clauses (or any replacement thereof) into our contract with the receiving party.

8. Do we use cookies and other tracking technologies?

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

9. How long do we keep your Personal Data?

We will only keep your Personal Data for as long as it is necessary for fulfilling the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this Privacy Policy will require us keeping your Personal Data for longer than 2 years after you have finished your subscription.

When we have no ongoing legitimate business need to Process your Personal Data, we will either delete or anonymize such Personal Data, or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further Processing until deletion is possible.

10. How do we keep your Personal Data safe?

We have implemented appropriate technical and organizational security measures designed to protect the security of any Personal Data we Process. We take such appropriate measures to discover, prevent and limit the risks of a hacking attack etc., and to protect your Personal Data against unauthorised access, misuse, reveals, changes and damages. You should only access the Services within a secure environment.

11. Do we collect Personal Data from minors?

We do not knowingly solicit Personal Data from or market our Services to children under 18 years of age. If we learn that Personal Data from users less than 18 years of age has been collected and are being Processed by us without parental consent, we will deactivate the account and take reasonable measures to promptly delete such Personal Data from our records. If you become aware of any Personal Data we may have collected from children under age 18, please contact us at privacy@adatype.ai.

12. What are your privacy rights?

In some regions (like the EEA), you have certain rights under applicable data protection laws and you can claim these rights by contacting us. Your rights include the right (i) to request access and obtain a copy of your Personal Data, (ii) to request rectification or erasure; (iii) to restrict the Processing of your Personal Data; and (iv) if applicable, to data portability. Under certain circumstances, you may also have the right to object to the Processing of your Personal Data. To make such a request, please use the contact details provided in section 15 below. We will consider and act upon any request, in accordance with applicable data protection laws.

If you are a resident in the European Economic Area and you believe we are unlawfully Processing your Personal Data, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

13. Consent to the Processing of Personal Data

If we are relying on your consent to process your Personal Data, which is the case for example the Processing of Sensitive Data according to section 4 above, you have the right to withdraw your consent at any given time. Please note however that this will not affect the lawfulness of the Processing before your withdrawal, nor will it affect the Processing of your Personal Data conducted in reliance on other lawful bases for Processing than consent.

Contact us in writing and object to the Processing of your Personal Data in order to withdraw your consent.

14. Do we make updates to this Privacy Policy?

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are Processing your Personal Data.

15. How can you contact us about this Privacy Policy?

If you have questions or comments about this Privacy Policy, you may email us at privacy@adatype.ai or by post to:

Adatype AB

Adatype

Videum Science Park

Växjö 351 96

Sweden