PRIVACY POLICY

Your integrity is important to us at Upotential AB (”we”, “us”, “our”). Therefore, we wish to be transparent in the processing of your personal data. The purpose of this privacy policy is to inform you about why and how we gather and use your personal data, as well as your rights. You are always welcome to contact us on legal@upotential.se should you have any questions.

CONTROLLER

Upotential AB, reg. no. 559161-8672, is the responsible controller for any processing of personal data in connection with the Services. ("Services" means the mental fitness training services provided by Upotential and other services provided by Upotential through www.upotential.se.)

CATEGORIES OF PERSONAL DATA

We gather information that you provide when registering for the Services. In order to continuously improve, we also gather information when you order and use the Services and other information about your traffic on our website.

The following categories of personal data may be processed:

- Personal and contact information (e.g. name, address, e-mail address, phone number, whether you are a private or corporate client).

- Information about the usage of the Services (e.g. information about your traffic on our website, your training, training progress and technical data such as IP-address).

- Payment and billing information (e.g. name, civic number, organisation number, order history, billing address)

PURPOSE AND LEGAL BASIS FOR PROCESSING PERSONAL DATA

Below you will find the purpose and legal basis for our processing of your personal data.

SHARING OF PERSONAL DATA

We work with service providers that may need to access certain personal data in order to provide their services to us. These service providers include companies that operate the technical infrastructure that we need to provide the Services and assist in protecting and securing our systems and the Services.

We will share your personal data with our payment processors as necessary to enable them to process your payments.

We work with advertising partners to enable us to customize the advertising content you may receive in connection with the Services. Our advertising partners may process certain personal data to help Upotential understand your interests or preferences so that we can deliver advertisements that are more relevant to you.

We share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a court order or a subpoena. We also share your personal data where we in good faith believe that it is necessary for the purpose of law enforcement, litigation, criminal investigation or protecting the safety of any person.

PLACE OF PROCESSING OF PERSONAL DATA

Your personal data will primarily be processed within the EU/EEA but where necessary to fulfil the purpose of the personal data processing, processing may also be made in other countries, also outside the EU/EEA. The personal data may also be stored on servers outside the EU/EEA. If so, it will be ensured that the processing of the personal data is protected in an adequate manner and that processing is made in accordance with terms and conditions set out herein. Protection could for instance include appropriate contractual clauses such as model clauses approved by the EU Commission and other appropriate security measures.

STORING OF PERSONAL DATA

We only keep your personal data as long as we have to in order to fulfill our agreement(s) with you or as long as it is necessary for legitimate purposes. Your personal data will be stored for a maximum of twelve (12) months from when you terminate your agreement(s) with us, after which we will erase your personal data. Personal data processed in order for you to receive our newsletter will be stored for as long as you subscribe to this.

SECURITY

The security, integrity and confidentiality of your personal data is important to us. We have implemented technical, administrative and physical security measures aimed to protect the personal data. However, please note that no system is ever completely secure.

COOKIES

Cookies are small text files that are downloaded to your unit when you visit a website, and which make it possible for us to recognize your unit. We use cookies in order to improve your customer experience on our website. The types of cookies we use and their purpose are set out in our cookie policy: https://www.upotential.se/cookies

You may at any time choose not to receive cookies by changing your browser settings. Please note that some cookies are necessary in order for us to fully provide our services. You can visit www.allaboutcookies.org for more information about cookies.

YOUR RIGHTS

- You have the right to request access to your personal data that we process.

- You have the right request to have any inaccurate personal data concerning you rectified and have incomplete personal data completed.

- You have the right to request to have your personal data erased, and we are required to erase such personal data if it for example is no longer necessary in relation to the purposes for which they were collected and there is no other legal basis for processing the personal data.

- You have the right to request that our processing of your personal data is restricted.

- You have the right to withdraw your consent to the extent consent is the legal basis for our processing of your personal data. Such withdrawal will not affect the legality of any previous processing.

- You have the right to request to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transfer this data to another controller.

- Under certain circumstances you will have the right to object to the processing of personal data.

If you wish to exercise your rights, please contact us on the address provided below.

You also have a right to express your complaint to the relevant supervisory authority (in Sweden, this is the Swedish Authority for Privacy Protection (IMY)) if you are dissatisfied with how we process your personal data.

CHANGES TO THE PRIVACY POLICY

We reserve the right to make changes to this privacy policy at any time. If we make any significant change to the privacy policy, we will inform you by e-mail, SMS or through the Services before the changes take effect.

CONTACT INFORMATION

If you wish to exercise your rights or if you have any questions regarding the processing of your personal data or this privacy policy, please contact us on legal@upotential.se or Upotential AB, Östermalmsgatan 26A, 114 26 Stockholm, Sweden.