PURPOSE OF THIS POLICY
Epassi takes the protection of your personal data very seriously.
We developed this policy to inform you of the conditions under which we collect, process, use and protect your personal data. Please read it carefully to familiarize yourself with the categories of personal data that are subject to collection and processing, how we use these data and with whom we are likely to share it. This policy also describes your rights and how you can get in touch with us to exercise these rights or to ask us any questions you might have concerning the protection of your personal data.
This policy may be amended, supplemented or updated, in particular to comply with any legal, regulatory, case law or technical developments that may arise. However, your personal data will always be processed in accordance with the policy in force at the time of the data collection, unless a compulsory legal prescription determines otherwise and must be enforced retroactively.
This policy forms an integral part of the Terms and Conditions of the Application.
IDENTITY AND CONTACT DETAILS OF THE CONTROLLER
The personal data controller is: ePassi Benefits & Rewards Sweden AB (registration number 556649-1444), Kungsgatan 54, 111 35 Stockholm
“Personal data” means any information relating to an identified natural person or one that can be directly or indirectly identified by reference to an identification number or to one or more factors specific to this person.
“us” or “our” ePassi Benefits & Rewards Sweden AB (hereinafter “Epassi”),
“you” an individual cardholder permits to use the Services under the Cardholder Terms and Conditions
“App” the App of Google Pay.
COLLECTION AND SOURCE OF PERSONAL DATA
We will most likely collect your personal data directly (in particular via the data collection forms on our App) or indirectly (in particular via our service providers and/or technologies on our App).
We undertake to obtain your consent and/or to allow you to refuse the use of your data for certain purposes whenever necessary.
You will in any event be informed of the purposes for which your data are collected via the various online data collection forms.
TYPES OF PERSONAL DATA COLLECTED AND USED BY US
We may specifically collect and process the following types of personal data:
Personal data identified by an asterisk in the data collection forms are compulsory as these are necessary to fulfill any orders placed. In the absence of this compulsory information, these transactions cannot be processed.
PERSONAL DATA THAT WE AUTOMATICALLY COLLECT
We collect some information automatically when you visit the App in order to personalize and enhance your experience. We collect this information using various methods such as:
An IP address is a unique identifier used by some electronic devices to identify and communicate with each other on the internet. When you consult our App, we can use the IP address of the device used by you to connect you to the App. We use this information to determine the general physical location of the device and to know in which geographical areas visitors are located.
The App uses Google Analytics to generate statistical reports. These reports tell us, for example, how many users consulted the App, which pages were visited and in which geographical areas App users are located. The information gathered via the statistics may include, for example, your IP address, the App from which you arrived at our site and the type of device that you used. Your IP address is hidden on our systems and will only be used if necessary to resolve a technical problem, for App administration and to gain insight into our users’ preferences. App traffic information is only accessible to authorized staff. We do not use any of this information to identify visitors and we do not share this information with third parties.
PURPOSES FOR WHICH WE USE PERSONAL DATA
We use your personal data specifically for the following purposes:
LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA
We process your personal data as part of the performance and management of our contractual relationship with you, in our legitimate interest to improve the quality and operational excellence of the services we offer to you or in compliance with certain regulatory obligations.
Your personal data may also be processed based on your prior consent in the event that under certain circumstances, your consent would be requested.
DISCLOSURE OF PERSONAL DATA
The security and confidentiality of your personal data are of great importance to us. This is why we restrict access to your personal data only to members of our staff who need to have this information in order to process your orders or to provide the requested service.
We will not disclose your personal data to any unauthorized third parties. We may, however, share your personal data with entities within the Epassi group and with authorized service providers (for example: technical service providers [hosting, maintenance], consultants, etc.) whom we may call upon for the purpose of providing our services. We do not authorize our service providers to use or disclose your data, except to the extent necessary to deliver the services on our behalf or to comply with legal obligations. Furthermore, we may share personal data concerning you (i) if the law or a legal procedure requires us to do so, (ii) in response to a request by public authorities or other officials or (iii) if we are of the opinion that transferring these data is necessary or appropriate to prevent any physical harm or financial loss or in respect of an investigation concerning a suspected or proven unlawful activity.
STORAGE PERIOD OF YOUR PERSONAL DATA
We will store your data only for as long as necessary to fulfill the purposes for which it was collected and processed. This period may be extended, if applicable, for any amount of time prescribed by any legal or regulatory provisions that may apply.
SENSITIVE PERSONAL DATA
As a general rule, we do not collect sensitive personal data via our App. “Sensitive personal data” refers to any information concerning a person’s racial or ethnic origins, political opinions, religious or philosophical beliefs, union membership, health data or data relating to the sexual life or the sexual orientation of a natural person. This definition also includes personal data relating to criminal convictions and offenses.
In the event that it would be strictly necessary to collect such data to achieve the purpose for which the processing is performed, we will do so in accordance with local legal requirements for the protection of personal data and, in particular, with your explicit prior consent and under the conditions described in this Confidentiality Policy.
PERSONAL INFORMATION AND CHILDREN
The App is for use by adult persons who have the capacity to conclude a contract under the legislation of the country in which they are located.
Children users under the age of 16 years or without legal capacity must obtain consent from their legal guardians prior to submitting their data to the App.
The 16-year age limit may be reduced to 13 years depending on the local legislation in your usual place of residence.
TRANSFER OF PERSONAL DATA
As Epassi is an international group, your personal data may be transmitted to internal or external recipients that are authorized to perform services on our behalf and that are located in countries outside the European Union or the European Economic Area which do not offer an adequate level of personal data protection.
To guarantee the security and confidentiality of personal data thus transmitted, we will take all necessary measures to ensure that these data receive adequate protection, such as signing standard European Commission contractual clauses or other equivalent measures.
In accordance with the applicable law, you have certain rights relating to the processing of your personal data.
Right of access
You have the right to request access to your personal data. You may also request rectification of inaccurate personal data or request that incomplete data be completed.
You also have the right to know the source of the personal data.
Right of erasure
Your right to be forgotten entitles you to request the erasure of your personal data when:
(i) the data are no longer necessary to achieve the purposes for which they were collected and processed;
(ii) you choose to withdraw your consent (if your consent was obtained as the legal basis for processing), without such a withdrawal affecting the lawfulness of any processing carried out prior to the withdrawal;
(iii) you object to the processing;
(iv) your data were processed unlawfully;
(v) your data must be erased to comply with a legal obligation; or
(vi) erasure of the data is required to ensure compliance with current legislation.
Right to restriction
You may also request restriction of processing of your personal data if:
(i) you dispute the accuracy of your data;
(ii) we no longer need these data for processing purposes; and
(iii) you are opposed to the processing of the data.
The right not to be the subject of a
automated data processing
You have the option not to be the subject of a decision based exclusively on automated processing that has legal effects concerning you or that has a significant impact on you.
Right of portability
You may request that we provide your personal data in a structured, commonly used, machine-readable format or you may request that it be transmitted directly to another controller on condition that:
(i) the processing is based on your consent or necessary to fulfill a contract with you; and
(ii) that it is done via automated means.
Right to lodge a complaint with a supervisory authority
If you have any concerns or complaints with regard to the protection of your personal data, you have the right to lodge a complaint with the Integritetsskyddsmyndigheten at https://www.imy.se/
However, please address any requests to us beforehand by contacting us at the address given below so that we can deal with your request and find an amicable solution.
To exercise your rights, you can contact us by writing to us at the following address: email@example.com stating your surname, first name and the reason for your request. We will most likely ask you for additional information in order to identify you and to enable us to deal with your request.
We implement all possible technical and organizational security measures to ensure security and confidentiality in processing your personal data.
To this end, we take all necessary precautions given the nature of the personal data and the risks related to its processing, in order to maintain data security and in particular to prevent distortion, damage or unauthorized third-party access (physical protection of the premises, authentication procedures with personal, secured access via identifiers and confidential passwords, a connection log, encryption of certain data, etc.).
LINKS TO OTHER SITES
UPDATES OF OUR CONFIDENTIALITY POLICY
This policy will become effective on May 1st, 2021. We may update or amend this confidentiality policy as and when needed. In this case, amendments will only become applicable after a period of 30 business days from the date of the amendment. Please consult this page from time to time if you want to be informed of any possible changes.
If you have subscribed to certain services via our App and you no longer want to receive emails, please consult the “unsubscribe” page corresponding to the service you are subscribed to.
HOW TO CONTACT US
If you have any questions or comments with regard to this policy, please do not hesitate to contact us at the following address: LDPPC@epassi.se
Last updated: 31st of March 2021