PRIVACY NOTICE FOR DIGMAK

Digmak AB, Registration No. 559315-6812, registered address at Östermalmsgatan 26A, 114 26 Stockholm, Sweden (“Digmak”, “we”, “us” or “our”) has primary objective to introduce people to qualified and established tax and accounting experts and facilitate their interactions through the webpage www.digmak.com (the “Webpage”). 


Your privacy is important to us. Under the General Data Protection Regulation (2016/679), we are responsible for the processing of personal data for which we decide the purposes and the means of processing. With “personal data” we mean information which is directly or indirectly referable to a natural living person and which is processed in connection with the Services.


This document contains information about our collection, use and processing of personal data, which parties to whom we may share such data and your rights in relation to personal data about you. When you use the Services, we will process personal data for a number of purposes, as set forth below.


PROCESSED PERSONAL DATA



We collect and use the following types of personal data to deliver and maintain efficient and secure Services, for the purposes stated below:


  1. name; 

  2. email address;

  3. telephone number;

  4. IP address;

  5. birthday; 

  6. picture. 


Please note that we are unable to provide the Services without processing the above stated personal data. 

When you use the Services, certain information will be collected automatically, including; 

  1. information about your use of the Services; 

  2. content that you post, upload and/or contribute to the Services; 

  3. technical data, which may include the URL from which you navigated to the Website, your IP address, unique device ID, network and computer performance, browser type, language and identifying information and operating system.


PURPOSES OF PROCESSING AND LEGAL BASIS

We will process the information set out above for the following purposes: 
  1. to administrate your account, to enable and provide the Services and integration with third party services, and to otherwise provide the Services according to the terms of use. The processing of personal data for this purpose is based on the necessity for the provision of our services to you; 

  2. to personalize and improve your experience of the Services, based on our legitimate interest to provide you with a customised experience that is tailored to your preferences;

  3. to send you alerts or messages by email or otherwise, including to provide you with marketing of our and our related parties’ products and services based on our legitimate interest to send you promotional material about products and services you might be interested in;

  4. to inform you about updates of the Services or the terms of use based on our legitimate interest to keep you posted about developments of the Services such as new features and the terms you agreed to use the Services under;

  5. to improve and develop the Services or new services and products and to analyse your use of the Services on the basis of our legitimate interest of offering you up-to-date Services based on your use of the Services, and to develop new products and services that cater to your preferences and your consent to our use of cookies;

  6. to ensure the technical functioning of the Services and to prevent use of the Services in breach of the terms of use, to be able to provide services to you and based on our legitimate interest to ensure that our Services are not abused for the protection of ourselves and our other users;

  7. to enforce the terms of use, including to protect our rights, property and safety and also the rights, property and safety of third parties if necessary on the basis of our legitimate interest of protecting our business, our Services users and other third parties; 

  8. to fulfil requirements by law, based on our obligation to comply with such laws.



For processing activities that are based on a legitimate interest, we carefully balanced such legitimate interest with your right to privacy, and concluded that our interest can be exercised without interfering with your rights and freedoms in a way that prohibits the processing of personal data about you.



Please note: for each legitimate interest that a processing operation is based on, an assessment of whether those legitimate interests can be exercised in accordance with the GDPR must be documented – this is often referred to as a “legitimate interest assessment”, or a “LIA”. Please do not hesitate to contact Digmak if you have any questions about this.



RETENTION OF PERSONAL DATA


As the main rule, we store your personal data for only as long as necessary to perform the Services, unless there is a legal obligation to store the data for longer. 

After you have closed your account, personal data connected to the account will be stored for 30 days at most. 


Contact information to you, used for sending marketing and information is stored for as long as your account is active, and will be deleted when you unsubscribe from our mailing list (with the link in an email or similar from us).


Personal data used to improve the Services and to develop new services are anonymised as soon as possible, however in no case longer than six months after which the personal data was collected or created. 

Personal data processed pursuant to a legal obligation are stored for as long as the legal obligation warrants that the personal data is stored. This includes when personal data is processed for bookkeeping purposes, where the account details are stored during the current year and until the seventh year after the end of the calendar year which the fiscal year ended.



DISCLOSURE OF PERSONAL DATA


We may share and disclose your personal data to our partners and suppliers and related third parties for the above stated purposes within the EU/EEA.

Your username may be disclosed to other users of the Services.

You understand and agree that the privacy notice of third parties, available here, will govern all use of information provided to third parties in accordance with this Privacy Notice. 


[Please note: if a third party processes personal data as a controller (which for instance is commonplace when the third party is providing payment or checkout solutions for e-commerce) it must be clear for the data subject that there is more than one controller involved. Provide a link to the third party’s privacy information.]



COOKIES, PIXELS AND OTHER SYSTEM TECHNOLOGIES



We collect information through technology like cookies, pixels and local storage (like on your browser or device). For information about how we use system technologies and analytic tools and how you can prevent the use of cookies, please see our Cookie Policy (available here).   



RESPONDING TO LEGAL REQUESTS AND PREVENTING HARM



We may access, preserve and share your information in response to a legal request (like a search warrant, court order or a subpoena or the like), or when necessary to detect, prevent and address fraud and other illegal activity, to protect ourselves, you and other users, including as part of investigations, if we have a good faith belief that the applicable law require us to do so. 


This may include responding to legal requests from jurisdictions outside of the EU/EEA where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. 

Information that we receive about you (including financial transaction data) on the Webpage using our Services, may be accessed, preserved and retained for an extended period of time when it is the subject of a legal request or obligation, government investigation, or investigations concerning possible violations of our terms of use or policies, or otherwise to prevent harm. 



SOME OTHER THINGS YOU NEED TO KNOW


Links to other webpages


You should be aware that when you are on our Webpage you may be directed to other sites operated by third parties where the personal information collected is outside of our control. The privacy notice of the new site will govern the information obtained from you on that site. 



Change of Control



If the ownership of our business changes, we may transfer your information to the new owners so they can continue the Services. The new owner will still have to honour the commitments we have made in this Privacy Notice.



Notice of changes 



If we make changes to this Privacy Notice, we will give you information about changes by clear notice to the email address provided by you. 

If the changes are material, we will provide you additional, prominent notice as appropriate under the circumstances and, where required under applicable law, ask for your consent. 



Your Privacy Rights under EU law



You have an absolute right to object to the processing of your personal data for direct marketing. You also have the right to recall your prior given consent. The withdrawal of your consent does not affect the lawfulness of the processing based on the consent before its withdrawal, and we may continue processing your personal data based on other legal grounds, except for direct marketing. 


You have the right to request access and further information concerning the processing of your personal data, or request that we correct, rectify, complete, erase or restrict the processing of your personal data. You have the right to obtain a copy of the personal data that we process relating to you free of charge once (1) every calendar year. For any additional copies requested by you, we may charge a reasonable fee based on administrative costs.


If the processing is based on the legal ground of legitimate or public interests, you have the right to object to the processing. If you do this, we will no longer be permitted to process the personal data unless we can demonstrate compelling reasons for why our legitimate grounds for the processing override your interests, rights and freedoms – unless the processing is not for the establishment, exercise or defence of legal claims. 

If the processing is based on the legal grounds consent or fulfilment of contract you have the right to data portability. Data portability means that you can receive the personal data that you have provided to us, in a structured, commonly used and machine-readable format, and have the right to transfer such data to other data controllers.


To exercise the aforementioned rights, or if you have any questions about our sharing practices, your rights under EU law, or wish to have your personal information removed, please contact us at the following address: info@digmak.com or Digmak, Östermalmsgatan 26A, 114 26 Stockholm, Sweden. In order to ensure that you receive a swift response, please state your full name and, if applicable, your address, username and the email address used for registration. Note that you should sign the request to receive information of the processing of your personal data yourself.


If you have any complaints regarding our processing of your personal data, you may file a complaint to the competent data protection authority. You can find out more about the local data protection authorities under the following link http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm



CONTACT OUR DATA PROTECTION OFFICER



If you want to contact our data protection officer, you can do so at:

  • amelie@digmak.com

  • Digmak, Östermalmsgatan 26A, 114 26 Stockholm, Sweden