DigitalSafety Privacy Policy
Last updated: February 7, 2022 Holmbergs Digital Safety AB, 559270-5882, has developed the app and is the controller for processing operations where we decide the purpose and the means of the processing of your personal data. If you have any questions, please contact us:
This Privacy Policy describes Holmbergs policies and procedures on the collection, use and disclosure of your information when you use the application Holmbergs DigitalSafety and tells you about your privacy rights and how the law protects you.
[xxx] is a child seat manufacturer incorporating devices connected to the App into their products. xxx is not the controller for the processing described in this Privacy Policy. If information from the app will be transferred to xxx and xxx would decide the purpose and the means of the further processing, you will receive information from xxx on how they process your information.
1. Definitions
App means the software program xxx DigitalSafety provided by Holmbergs, downloaded by you on any electronic device.
XXX refers to [XXXX].
Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
GDPR is short for General Data Protection Regulation, which refers to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
Holmbergs (referred to as either “Holmbergs”, “we”, “us” or “our” in this Privacy Policy) refers to Holmbergs Digital Safety AB.
Personal Data is any information that relates to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
2. Collecting and using your Personal Data
What types of data do Holmbergs collect?
While using our App, Holmbergs may ask you to provide us with certain personal data that can be used to contact or identify you. Personal data includes:
Address
Email address
Telephone number
First and last name
Date of birth for child
County of residence
For what purposes do Holmbergs use your personal data?
Holmbergs may use Personal Data for the following purposes:
- To provide the App: It is necessary to enter name and email address in order to create an account in the App.
- To send messages to you: The messages can be notifications and/or emails to you on behalf of us and/or xxx. The messages can be relating to security matter in connection with the child seat, so called security messages (including individual emergency messages). The messages can also be regarding news, special offers and general information about other products, which are related to those that you have already purchased, updates or other offers that may be relevant to you, so called marketing messages. We will provide you with messages unless you have opted not to receive such information.
- To maintain and develop the App: Holmbergs may use your information for purposes related to development based on data analysis, where we identify usage trends and evaluate and improve the App and your experience.
3. Legal basis for processing Personal Data under GDPR
Holmbergs process your Personal Data based on the legal basis performance of a contract. The Personal Data collected from you is necessary for the performance of the contract and we can not provide the service without information regarding who you are.
If you enter Personal Data regarding your child’s/children’s age, Holmbergs process their data based on the legal basis legitimate interest. Before relying on legitimate interest, we have balanced our interests against your child´s interests and made sure that our interests are compelling enough and will not cause an unwarranted harm. Holmbergs process data regarding children´s age for purposes of sending relevant messages and to adjust our information. You can delete this information at any time by changing your account details in the App. We also use the legal basis legitimate interest to send messages to you.
4. How long Holmbergs store your Personal Data
Holmbergs will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Holmbergs will also retain your Personal Data for internal analysis purposes but will to the extent possible render the Personal Data anonymous. Personal Data is generally retained during the period when you have an active account, except when this data is used to strengthen the security or to improve the functionality of our App, or we are legally obligated to retain this data for longer time periods.
5. Who do Holmbergs share your Personal Data with?
Holmbergs may share your personal information with our business partners, such as our cloud service provider Google and, when emergency notification by SMS is necessary, Twilio. Your Personal Data will also be shared with xxx to offer you certain products, promotions, or safety information.
6. Transfer of Personal Data
Holmbergs will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
Under certain circumstances, Holmbergs may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). Holmbergs may further transfer your Personal Data to xxx.
In addition, Holmbergs may disclose your Personal Data in the good faith that such action is necessary to:
- Comply with a legal obligation.
- Protect and defend the rights or property of Holmbergs.
- Prevent or investigate possible wrongdoing in connection with the App.
- Protect the personal safety of users of the App or the public.
- Protect against legal liability.
Holmbergs does not transfer your Personal Data outside of the EU/EEA.
7. Your Rights under the GDPR
You have the following rights regarding the processing of your Personal Data.
- Right to access. You have the right to access the information we have on you. This also enables you to receive a copy of the Personal Data we process about you.
- Right to rectification. You have the right to have any incomplete or inaccurate information we process about you corrected.
- Right to erasure. In some cases, you have the right to have your Personal Data erased. This right is not absolute, and we will assess a request to have your Personal Data erased in each individual case.
- Right to restriction of processing. In some cases, you have the right to have any processing regarding your Personal data restricted. This right is not absolute, and we will assess a request to restrict the processing of your Personal Data in each individual case.
- Right to data portability. You have the right to receive your Personal Data, which you have provided us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller. Please note that this right only applies where we use the information to perform a contract with you.
- Right to object. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Automated decision-making, including profiling. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Please note that Holmbergs may ask you to verify your identity before responding to requests made by you to exercise your rights.
You also have the right to contact or lodge a complaint with the supervisory authority, in Sweden the supervisory authority is Integritetsskyddsmyndigheten. You can visit their website at www.imy.se.
8. Children’s Privacy
Our Service does not address anyone under the age of 13. Holmbergs does not knowingly collect personal data from anyone under the age of 13. If you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers.
9. Emergency Contacts
If you choose to enter information regarding emergency contacts in the App, you are advised to notify the emergency contact that their Personal Data might be processed by Holmbergs and transferred to Twilio. The emergency contact can read more about how Holmbergs process Personal Data in this Privacy Policy. The only Personal Information regarding the emergency contact that Holmbergs process is their name and phone number. Holmbergs process Personal Data regarding emergency contacts on the basis of a legitimate interest and will not use Personal Data regarding emergency contacts unless there is an emergency where it is necessary to do so.
10. Changes to this Privacy Policy
Holmbergs may update Our Privacy Policy. We will notify you of any changes by posting the new Privacy Policy on
https://www.holmbergs.se/privacy/holmbergs
and update the “Last updated” date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on the website.
11. Contact Us
If you have any questions about this Privacy Policy or how Holmbergs process personal data, you can contact us: