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Privacy Policy
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GONNA! Challenge you to change the world – Privacy Policy

Last updated: 2019-08-12

Summary

This privacy policy explains how Gonna Make an Impact AB and its affiliates (collectively “Gonna”), and its third party marketing and advertising partners collect, use, process and share your personal data.

  • Gonna Make an Impact AB, reg. no. 559135-5283, address Vasagatan 16,, 111 20, Stockholm (”GONNA!” “we” “us”) is the data controller of the personal data you submit to us through our Services to you as an end-user, (“you”).
  • This Privacy Policy applies to all of our Services, whether used on your mobile device or via our website www.gonnachallenge.com. It also applies to our Marketing and Advertising activities on all platforms and other services that we may provide to you. In this policy, we refer to our service, website, marketing and advertising activities and other services as our “Services”.
  • This Service is provided to you free of charge. By downloading and accessing our Service, you agree to the collection and use of your personal data in accordance with this policy, including consenting to our and our advertising partners’ use of your personal data for targeted advertising purposes as described in the Marketing and Advertising sections of this Policy. Here you can learn how to withhold or withdraw your consent to the use of your data for targeted marketing. If you have any concerns about providing information to us or it being used as described here, you should not use our Services.

Last modified: 2019-08-12

1. Using our Services

1.1. By downloading, accessing and using our Services, you agree to the collection of personal data about you by us. Most of the data comes from you or your device, such as information you provide in forms, content you upload or technical information about your device operating system, language preferences and information about your use of the Service. We use this data mainly for the purpose to provide you with the services, including the purposes to prevent fraud, customizing in-game offers and verifying purchases. We may also use your personal data for the other purposes set out in the Marketing and Advertising sections.

1.2. Information you provide

  • We collect and use the following personal data from you when you create your user account for the Service such
    as Full name, Mobile phone number, Country of residence, Profile picture.
  • If you choose to connect your account to your social media account.
  • Information you provide us with when you fill out forms, answer questions or complete surveys, invite friends to
    use our Services.

1.3. Personal data we collect
When you use the Service, certain information will be collected automatically by us, including:

  • information about your use of and interact in the Service; and
  • technical data, which may include the URL you are accessing the Website from, your IP address, network and
    computer performance, browser type, language and identifying information and operating system.
  • Furthermore, we use Google ads when providing you with the Service to display ads that are relevant to you.
    Google ads uses cookies to serve ads based on your previous web history. For further information in this regard,
    please see our cookie policy here.
  • When communicating with us through e-mail, mail or any other form of communication, we may save this
    correspondence, including personal data (such as name, e-mail address, contact information and other personal
    data you may share). This information is used to answer or handle your case.
  • Information as further set out in this Privacy Policy, including Marketing and Advertising.

1.4. We (including our suppliers and group companies) may use this information:

  • To provide you with Services you have requested, verify your account and any purchases you have made, and active them on our servers, and provide you with support if requested;
  • For marketing and advertising purposes;
  • Comply with laws, prevent fraud, ensure compliance with our Terms of Use and this Privacy Policy.
  • To anonymize the personal data you provide us to make it de-identified and unable to link it back to you (thus making it not personal data).

1.5. What happens if you do not give us your personal data

  • Please note that we are unable to provide the Service unless you provide us with the personal data stated above.

1.6. Providing our Services
We use your personal data in order to provide you with the Service. We will ask you for information in order to verify the validity of your access to the service through an active subscription.

Legal basis:

  • Processing your personal data in this regard is out of contractual necessity. Without registering your account, we will be unable to provide you with the Service.

1.7. Communication with you – information and marketing
By providing us with your phone number and email we can contact you if there are any issues with the Service, with your account and provide you with news about the Service and any updates, new releases or similar.

When you correspond with us through any kind of communication, we may retain such correspondence and the information contained in it (such as name, email, contact information and any personal identifiable information you provide in free text form) and use it to respond to your inquiry. Your email may also be used to send you your digital receipt, if applicable.

We will send you marketing, newsletters and information about our Services, so you never miss out on new features or releases. You may decline to receiving marketing information and news from us which is not strictly necessary for your use of the Service.

Legal basis:

  • Processing your personal data for the purpose of resolving any issues with the Service or with your account is
    justified since it is necessary for the performance of our contract with you.
  • Processing your personal data for the purpose of communicating with you upon your request is justified by our
    legitimate interests of assisting you with the use of the Service.
  • Processing your personal data for the purpose of providing you with news about us and marketing is justified by
    our legitimate interests.

1.8. Complying with IT security and other requirements
We use personal data to protect the security of our services and customers, to detect and prevent fraud, resolve disputes and enforce our contracts. We may also block delivery of a message or remove content if it violates our terms of use.

Legal basis:

  • Processing your personal data for this purpose is necessary for the legitimate interests pursued by us by having a secure IT environment and protecting our users. The processed data will not be used in a way that overrides the interests or fundamental rights and freedoms of the users of the Service.

1.9. Analytics and Research
We use analytics tools to collect information about how you use our Services. These tools may include cookies and other similar tracking technologies. We use data to do research, surveys or send you communications via email for these purposes. We may also create reports, analysis for our use to trach potential problems with our Services or to test new features and content.

1.10. Social Media Channels and Community
When we communicate with our users, the rules of that social media platform will govern the use of the personal data.

1.11. Promotions and Competitions
When we run promotions and competitions, specific terms and conditions will apply. We will use the personal data you have provided to us in such competition in order to provide you with the competition and the potential to claim a prize. We may also publish the names and profiles of entries of competitions entrants, which can be combined with your account profile and will be used in accordance with this Privacy Policy.

1.12. Serving ads and use of cookies
We collect data stored on your device by us and our advertising partners, such as device identifiers, IP address, country and region. We, GONNA! and our advertising partners, also store data on your device through the use of cookies.

The legal basis is consent, which you provide when you agree to install our application on your device and you can withdraw your consent at any time by uninstalling the application. By accessing and using our Service, you consent to this storage and you can withdraw your consent by updating your cookie preferences, and for targeted marketing purposes (see sections Advertising and Marketing).

1.13. Crime and fraud prevention
We may also share your personal data with third parties if we find it necessary for the following purposes:

  • complying with law, court orders, government decisions or other legal obligations,
  • protect data subjects from, for example, spam and fraud,
  • prevention of death or serious injury,
  • managing and maintaining the security of our Service, including, but not limited to, preventing or stopping attacks on our systems or networks,
  • protecting our legal rights or property.

Legal basis:

  • Legal Obligation.

1.14. Other reasons
If we plan to process personal data in any way that does not comply with this policy, we will inform you accordingly. If applicable, we will collect the appropriate permissions before the new processing begins. We do not sell your personal data to anyone and we only share your personal data when reasonably necessary to maintain and provide the Service, where it is necessary to carry out your instructions.

2. Your Profile and Social Gaming

2.1. You can choose to connect our Services to your account with a third party network (such as Facebook, either in Facebook or Instagram). If you do so, your personal data will be visible to other users and we will also use it for the purposes set out in this Privacy Policy.
Find out more:

2.2. Connecting with a third party network
If you choose to log in to your account using your account details with a third party network, such as Facebook, you will be able to use your account to log into multiple devices and synchronize progress across those devices. Where available, you may also see your friends, inviting friends etc.

2.3. Information we receive from Facebook
If you log in to your account using your Facebook account details, we will receive certain information from your Facebook account information. Exactly what information we receive will depend on your privacy settings in your Facebook account, typically we will receive your basic public profile (user name, email address, age range, gender, chosen language, country, friends list and other public information).

We will also collect the email account linked to your Facebook account and the name and avatar of those of your Facebook friends that are using our Service. You can deny us access to your email address in the dialog box when you first associate your Facebook account to our account. We will use this email to send you marketing emails about our Services, you can opt-out of this any time, see section Opting out of direct marketing from GONNA! below.

We recommend that you read Facebook’s Privacy Policy (https://www.facebook.com/full_data_use_policy) and review your privacy settings from time to time to keep your preferences up to date.

3. Marketing

3.1. Unless you opt-out (as explained below) we and our third party partners use personal data to send you marketing communications abut GONNA! and related services based on your interests. We may send you emails, serve ads within our Services, or place ads on third party websites, apps and internet-connected devices.
Find out more:

3.2. Information we use
We use information about you to serve personalized content in our Services to make your user experience more relevant for you. This includes using information that we have about you such as :

  • Ad-identifiers and other non-personal information collected from your device
  • Games you play and information about your interactions with our Services
  • Age, country, region and gender,
  • Other information we may acquire from our third party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us.

3.3. Marketing partners
We may use various third party marketing partners to promote our Service in media and we may share information we have about you to such partners.

Our marketing partners help to serve ads to you by combining the information with data they have collected about you elsewhere. This additional information is collected when you use their services or websites. Our partners use this information to make assumptions about your preferences to serve you with relevant ads and offers.

Unless you opt-out of interest-based advertising, you consent to our marketing partners collecting and using information about you to improve advertising, targeting and measurement systems as described in their privacy policies.

This Privacy Policy does not apply to the collection and use of information by our marketing partners. Please review their privacy policies for more information. A list of our marketing partners and their privacy policies can be found on www.gonnachallenge.com.

3.4. Opting-out of direct marketing
You can choose whether to accept or opt-out of direct marketing:

  • Opt-pout when we collect your email address or by choosing not to provide your email address to us when you first create your account, and
  • Remove yourself from marketing lists at any time by clicking the unsubscribe link in any direct marketing email we send to you or sending an email to hey@gonnachallenge.com

Note that if you opt-out of receiving interest-based advertising you will not stop receiving ads or marketing. You will still see advertising but they will appear as less relevant.

4. Advertising

4.1. Our Service may include advertising for third party products and services. By accepting this Privacy Policy and unless you opt-out from interest-based advertising as explained herein, you consent to us and to our advertising partners collecting and using information about you to serve personalised ads, targeting and measurement systems so they can show you relevant ads in our Service.
Find out more:

4.2. Information we use
We use information about you to serve personalized content in our Services to make your user experience more relevant for you. This includes using information that we have about you such as:

  • Ad-identifiers and other non-personal information collected from your device
  • Information about your interactions with our Services
  • Age, country, region and gender,
  • Other information we may acquire from our third party marketing partners or other third parties who have
    obtained your consent or have another legal right to share that information with us.

4.3. Advertising Partners
We may use various third party advertising partners to promote our Service in media and we may share information we have about you to such partners.

Our advertising partners help to serve ads to you by combining the information with data they have collected about you elsewhere. This additional information is collected when you use their services or websites. Our partners use this information to make assumptions about your preferences to serve you with relevant ads and offers

4.4. Unless you opt-out of interest-based advertising, you consent to our advertising partners collecting and using information about you to improve advertising, targeting and measurement systems as described in their privacy policies.

4.5. This Privacy Policy does not apply to the collection and use of information by our advertising partners. Please review their privacy policies for more information. A list of our advertising partners and their privacy policies can be found on www.gonnachallenge.com.

4.6. Opting-out of interest-based advertising
If you wish, you can prevent your device’s ad identifier being used for interest-based advertising by updating the settings on your device.

Note that if you opt-out of receiving interest-based advertising you will not stop receiving ads or marketing. You will still see advertising but they will appear as less relevant.

5. Ad identifiers, cookies and similar technologies

5.1. We provide our service, websites and applications free of charge. We finance the services in part by advertising by using ad identifiers, cookies and similar technologies. In this section you can learn about these technologies and how you can manage your preferences.
Find out more:

5.2. Ad identifiers, cookies and similar technologies are used by us to provide our Services to you and in order to collect data from your device. With this technology we, and our advertising partners, may:

  • Recognise you and your device,
  • Provide interest-based advertising to you,
  • Allow our Services to interact with a third party social network or platform (like Facebook) if you have allowed
    interaction,
  • Allow us to understand how you use our Service and website, here we use [Google Analytics cookie] on our
    website,
  • Enables us and our advertising partners to provide you with more customised services, as providing the
    application or website in your preferred language.

5.3. How does cookies work?
See our Cookie Policy, available at www.gonnachallenge.com.

5.4. How to adjust your preferences for interest-based marketing
You may choose to opt-out from receiving customized ad content by preventing your device’s ad identifier being used for such marketing, by changing the settings of your device. Setting vary from device to device, but these can typically be found in the Privacy or Ads section in your device’s settings.

If you live in the USA, Europe or Canada, you may also opt-out from the collection of your information by some or all of our advertising partners who participate in the Digital Advertising Alliance by visiting (http://www.allaboutads.info/cookies) (for US users), http://www.youronlinechoices.com (for European users) or http://www.youradchoices.ca/choices (for Canadian users).

If you choose to adjust your settings in order to prevent these technologies you may find that you cannot enjoy a personalised user experience or the full use of our Services.

Note that you will still receive advertisements if you choose to say no to interest-based advertising, however, the marketing will not be relevant to you or to your interests. We will still use your device’s ad identifier to serve you with ads.

6. Your rights

6.1. You have certain rights under privacy legislation about how your personal data is managed. You can exercise these rights at any time by contacting us via the methods set out in the Contact Us section below.
Find our more:
Your privacy rights include:

  • You have the right to, free of charge, request a registry extract and access a copy of your personal data, as well as correction and, under certain circumstances, deletion of your personal data.
  • You have the right to request restriction of our processing of your personal data, even if we have legitimate reasons to do so.
  • You may opt-out from receiving direct marketing or targeted advertising.
  • You have the right to make a complaint to a data protection supervisory authority. “Datainspektionen” is the authority in Sweden that supervises our compliance with relevant privacy legislation.
  • If our processing of your personal data is based on your consent, you are free to, at any time, withdraw said consent for future processing of your Personal Data.
  • You have the right to request that we transfer your personal data to another organization (data controller) responsible for handling your personal data. This applies when our right to process your personal data is based on either your consent, or the performance of a contract we have entered into with you.
  • You will be provided with reasonable access to your personal data, free of charge, by sending a request to hey@gonnachallenge.com. If we are unable to provide you with your personal data within a reasonable time frame, we will specify a date by which we will be able to do so. If such a request is denied, you will be provided with an explanation.

7. Security measures

7.1. In order to protect your privacy and the personal data you provide through your use of the Service, we maintain physical, technical and administrative safeguards. We continuously update and test out security.

7.2. We restrict access to your personal data to employees who need to know that information to provide you with the Service or benefits to the Service. Furthermore, we educate our employees regarding the importance of secrecy, integrity, and security of your personal data.

7.3. We will take appropriate disciplinary action to ensure that our employees maintain their obligations regarding your personal data.

8. Data storage and retention

8.1. Personal data managed by us will be stored and processed in the region in which you live, in Sweden, or in other countries where we, our affiliates, or suppliers are active. We take steps to ensure that data we collect in accordance with this Privacy Policy is treated in accordance with the provisions of this policy and in accordance with applicable law where the information is made available.
Find out more:

8.2. International transfers
Personal data managed by us will be stored and processed in the region in which you live, in Sweden, or in other countries where we, our affiliates, or suppliers are active. We take steps to ensure that data we collect in accordance with this Privacy Policy is treated in accordance with the provisions of this policy and in accordance with applicable law where the information is made available.
Find out more:

8.3. Data retention
We store your personal data for as long as it is necessary to supply you with the Service, as well as to fulfil the purposes stated in section 3 above. How long personal data is stored depends on different criteria. Criteria that determine how long we store personal data can be, for example:

  • How long do we need to store the personal data in order to supply our Service?
    This includes, amongst other things, to keep and improve the information needed to keep and improve the Service
    functionality, to protect our systems, and manage business and accounting information.
  • Is the personal data sensitive?
    If so, the storage period is generally shorter.
  • Have you consented to a longer storage period of your personal data?
    If so, we will store the information longer, based on Your consent.
  • Do we have a legal, contractual or a similar commitment to store the information?
    Some types of personal data must be stored longer than usual for purposes such as accounting reasons, government
    orders to preserve data relevant to investigations, or information that must be kept in order to solve potential
    disputes.
  • We store your personal data for a period of up to 24 months after our customer relationship has ended,
    alternatively until you choose to delete your user account or request to have your personal data deleted.

8. Data storage and retention

8.3. Data retention
We store your personal data for as long as it is necessary to supply you with the Service, as well as to fulfil the purposes stated in section 3 above. How long personal data is stored depends on different criteria. Criteria that determine how long we store personal data can be, for example:

  • How long do we need to store the personal data in order to supply our Service?
    This includes, amongst other things, to keep and improve the information needed to keep and improve the Service
    functionality, to protect our systems, and manage business and accounting information.
  • Is the personal data sensitive?
    If so, the storage period is generally shorter.
  • Have you consented to a longer storage period of your personal data?
    If so, we will store the information longer, based on Your consent.
  • Do we have a legal, contractual or a similar commitment to store the information?
    Some types of personal data must be stored longer than usual for purposes such as accounting reasons, government
    orders to preserve data relevant to investigations, or information that must be kept in order to solve potential
    disputes.
  • We store your personal data for a period of up to 24 months after our customer relationship has ended,
    alternatively until you choose to delete your user account or request to have your personal data deleted.

9. Excluded

Children
9.1. You must be over a certain age to use our Services, depending on where you live.

Aggregated data
9.2. Aggregated data is collected and processed to follow and evaluate user trends of the Service. This means that information about your use of the Service is collected and anonymized in a way that makes it untraceable to you. We use this information to keep statistics, improve service, and develop the Service. This type of information is completely anonymous and does not constitute Personal Data. Because of this, such information may be stored for longer periods than Personal Data

9.3. By anonymizing data in this way, it is completely disconnected from anything that somehow connect the information to you. This method goes further than pseudonymization regarding integrity protection. Pseudonymization means separating some types of data in order to complicate the identification of an individual through the data.

Personal data uploaded
9.4. This Privacy Policy applies to your account data that enables us to verify your account and provide you with the Service. We are the data controller for that Personal Data.

9.5. We are not, however, responsible for any personal data that you upload in the Service and share with another user of the Service. You are responsible for this data as the data controller and you must have the appropriate permissions to upload and share any personal data, if so required.

9.6. When joining one of our challenges you may share your submission on other social platforms to which we may link. We have no control over such parties and this Privacy Policy does not apply to their use of your personal data. As such, you should review such parties’ privacy policies to understand how they process your personal data.

10. Changes and updates

10.1. We will update this policy when necessary to update the Service, implement customer feedback and changes of the Service. If this policy is updated, the date at the top of this policy will change accordingly. The changes will also be described at the bottom of this policy under “CHANGE HISTORY”. When required by law, we will make contact with you through our website or through e-mail, as appropriate, before the changes take effect. We encourage you to continuously read this Policy in order to stay up do date regarding changes and how we protect Your integrity.

11. Questions, thoughts and concerns

11.1 If you would like to ask questions or have comments about our Policy and our security practices, please contact us at: hey@gonnachallenge.com

Gonna Make an Impact AB

CHANGE HISTORY

[2019-08-12]. Publication of first version when launching the service