Redeal STHLM AB Privacy Policy

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We reserve the right to amend this Policy from time to time. Print this page for your own records.


Who is Redeal STHLM AB?
Redeal STHLM AB is a company registered in Sweden. Our registered company organization number is: 556943-7089

Our registered office is at: Magnus Ladulåsgatan 3, c/o The Park, 118 65 Stockholm, Sweden.


What does Redeal do?
Redeal helps online businesses (our Clients) operate referral programmes and related services. We act as a service provider and Data Processor to our Clients, and as a Data Controller of data submitted directly to us. Through our technology platform, our Clients can enable their customers to refer their friends to their brand and reward the referrer for his/hers referral and enables the referrer to share deals with their friends.


Key Term Glossary
The following key terms are used in this Policy: 

Client: 
A Client is an online business for whom Redeal operates a referral program. We provide referral services to our Clients and process data in connection with those services on their behalf as their Data Processor. If you are a Referrer or a Referee under a referral program, a reference to a Client will mean the brand or online business whose referral programme you are participating in.

Data Controller:
A Data Controller is the person who determines the purposes for which and the manner in which personal data is processed

Data Processor:
A Data Processor is a person who processes personal data on behalf of a Data Controller

Redeal takes data privacy very seriously. We hold various personal data relating to individuals who have interacted with our services. What data we hold about you and why we hold it will depend on how you interacted with us. You can find all the relevant detail in this privacy policy:


If you are a Referrer in a referral programme:

What data do you hold about me?
We may hold the following personal data about you: 
- Your email address;
- Your mobile phone nr;
- Your first and last name;
- The order details of purchases of goods/services you have made with the Client;
- A record of any correspondence between you and us.

As is true of most websites, we also automatically gather information about your computer such as your IP address, browser type, referring/exit pages and operating system. If you are a Referrer under multiple referral programmes provided by different Clients, then we will hold the above data in respect of each separate referral program you participate in.


Where did you get this data from?
The above data is either: 
- collected from you by our Client (as Data Controller) and shared with us in accordance with their privacy policy so that we can operate their referral programme for them; or
- submitted directly by you if you have entered it into our Referrer registration widget and opted in to this privacy policy. 


What do you do with my data?

We need the above data:
- To allow us to recognize and reward you as a Referrer.
- To send you service and marketing emails in connection with our referral programmes – for example to help you share offers with your friends, to notify you about deals and rewards or beforce a coupon code expires. You can opt-out of receiving these emails at any time by clicking on the unsubscribe link at the footer of any email you receive from us.
- To investigate activity that we suspect as being contrary to the terms and conditions of a referral programme or fraudulent in nature.
- To respond to customer service requests. 

We may hold data either as Data Processor on behalf of our Client or as Data Controller, depending on how it has been submitted.

We hold and process data submitted by our Client as a Data Processor on behalf of our Client, who is the Data Controller. This means that we keep this data strictly confidential and we only ever use your data in accordance with our Client’s instructions.

We hold and process data submitted to us directly by you as Data Controller because you have consented for us to do so, or because it is in our legitimate business interest to process it for the purposes specified above. As Data Controller, we are responsible for keeping your data secure and processing it in accordance with applicable legislation.


How long do you hold my data? 
For data we hold as Data Processor, we will normally hold your data for as long as the Client continues to work with us or such other period as they may specify in their instructions to us. Some Clients will prescribe specific (shorter) retention periods for specific types of data we hold about their customers.

For data we hold as Data Controller, we won't process data for any longer than is necessary for us to do so for the purposes specified above.
Specifically:
- If you have not opted-out of marketing communications from us, but you have also not responded to an email after 12 months of being on our marketing list, we will no longer send you e-mails unless you expressly request us to;
-If you have opted-out of marketing communications we will no longer send you emails and we will retain a copy of your data solely for the purpose of ensuring you are no longer sent marketing communications.
- You may still receive necesseray service e-mails, even after opting-out from marketing communications.


Who do you share my data with?
In the ordinary course, we will only ever share your data with our Client or, on a confidential basis, with our own carefully selected sub-processors who are directly involved in delivering our referral services. Our sub-processors are primarily used for the purposes of hosting our platform and assisting with sending referral service emails and textmessages to referrers and referees.

We may disclose or transfer your personal information:
- as required by law.
- when we (or our Client) believe in good faith that disclosure is necessary to protect our rights, protect your safety or the rights and safety of other third parties (including other Redeal users), investigate fraud, or respond to a government request.
- to a third-party buyer or seller in the event that Redeal is involved in a merger, acquisition, or sale of all or a portion of its assets. 
- to any other third party with your prior consent to do so. 

 

Where is my data stored?
Information we hold about you is stored and processed principally in the Redeal platform. The Redeal platform is hosted in a secure data centre within the European Economic Area (EEA). Your information may be shared with our carefully selected sub-processors who are directly involved with the delivery of our refer-a-friend services.
In the event that the processing of your personal information at any time requires it to be transferred to and/or stored at or accessed from a destination outside the EEA, we will take all steps reasonably necessary to ensure that your data is treated securely, in accordance with this policy and safeguarded in accordance with all applicable legislation.


Do I have a right to object to processing?
You have the right to object at any time to the processing of your personal information.


What other rights do I have over the processing of my data? 
- You have the right to access any information we hold about you. Any request which is manifestly unfounded or excessive may be subject to a reasonable fee to cover our administrative costs in providing you with the necessary details. 
- You have the right to ensure the personal information we hold about you is up to date and accurate. 
- If you have given direct consent to us (or indirectly via the Client) to process any of your personal information you may withdraw that consent at any time. 
- You have the right to opt-out of receiving emails from us at any time. You can do this by managing your privacy settings in the link contained in the footer of any email you may receive from us.

Please note that if you opt-out of receiving Redeal referral emails or text messages:
- We will not be able to send you reminders of any referral rewards such as coupon codes you may be entitled to; and 
- You will not be automatically opted-out of any other communications you may have opted in to receive from our Client. You will need to inform the Client directly if you wish to opt-out of their direct communications.
- You have the right to request that the personal information we hold about you be erased and/or request that the processing of that data be restricted.


How do I exercise my rights?
If you would like to exercise any of the rights listed above, you may submit a request to us on e-mail address: optout@redeal.se or by post to Magnus Ladulåsgatan 3, c/o The Park, 118 65 Stockholm. To exercise your rights in accordance with data stored by our Client as Data Controller, you may submit a request directly to the relevant Client in accordance with the procedures outlined in their privacy policy which will be available on their website.

In case of data held by us as Data Processor on behalf of a Client we will share any request promptly with the relevant Client who is a Data Controller and ultimately responsible for decisions made in respect of personal information we hold about you as Data Processor.


If you have registered by opting in as a Referred Friend in a referral program:

What data do you hold about me?
We may hold the following personal data about you: 
- Your email address;
- Your mobile phone nr; 
- Your first and last name;
- Details of your visits to any referral program you are participating in;
- A record of any correspondence between you and us. 

As is true of most websites, we also automatically gather information about your computer such as your IP address, browser type, referring/exit pages and operating system. 
If you have registered as a Referred Friend under multiple referral programmes provided by different Clients we will hold the above data in respect of each separate referral program you participate in.

 

Where did you get this data from?
The above data is either:
- Submitted by your friend (the referrer) directly when they entered it into our Referee registration widget and shared a deal to your e-mail address or mobile phone nr.
- Submitted directly by you if you have entered it into our referral widget and opted in to this privacy policy.

We only save this data if you have given us consent by opting-in to this privacy policy. 

 

What do you do with my data?
We need the above data:
- To check that you are not the same person as the Referee. 
- To allow us to recognize and reward you as a Referred Friend when you fullfil the conditions necessary to receive a reward under the referral program you are participating in. 
- To send you service and marketing emails in connection with our referral programmes. – for example to email you information about deals and rewards as and when you are eligible to receive them, or before a coupon code expires. You can opt-out of receiving these emails at any time by clicking on the unsubscribe link at the footer of any email you receive from us.
- To investigate activity that we suspect as being contrary to the terms and conditions of a referral programme or fraudulent in nature.
- To respond to customer service requests.

We hold and process data submitted to us directly by you as a Data Controller because you have consented for us to do so, or because it is in our legitimate business interest to process it for the purposes specified above. As Data Controller, we are responsible for keeping your data secure and processing it in accordance with applicable legislation.

 

How long do you hold my data?
We won't process data for any longer than is necessary for us to do so for the purposes specified above.
Specifically:
- If you have not opted-out of marketing communications from us, but you have also not responded to an email after 12 months of being on our marketing list, we will no longer send you e-mails unless you expressly request us to;
- If you have opted-out of marketing communications we will no longer send you e-mails and we will retain a copy of your data solely for the purpose of ensuring you are no longer sent marketing communications.
- You may still receive necessary service e-mails, even after optin-out from marketing communications.


Who do you share my data with?
In the ordinary course, we will only ever share your data with:
- Our Client, if you have given consent by opting in to this privacy policy 
- On a confidential basis, our own carefully selected sub-processors who are directly involved in delivering our referral services. Our sub-processors are primarily used for the purposes of hosting our platform and assisting with sending referral service emails and text messages to referrers and referees.

We may disclose or transfer your personal information: 
- as required by law.
- when we (or our Client) believe in good faith that disclosure is necessary to protect our rights, protect your safety or the rights and safety of other third parties (including other Redeal users), investigate fraud, or respond to a government request.
- to a third-party buyer or seller in the event that Redeal is involved in a merger, acquisition, or sale of all or a portion of its assets. 
- to any other third party with your prior consent to do so.


Where is my data stored?
Information we hold about you is stored and processed principally in the Redeal platform. The Redeal platform is hosted in a secure data centre with the European Economic Area (EEA). Your information may be shared with our carefully selected sub-processors who are directly involved with the delivery of our refer-a-friend services.

In the event that the processing of your personal information at any time requires it to be transferred to and/or stored at or accessed from a destination outside the EEA, we will take all steps reasonably necessary to ensure that your data is treated securely, in accordance with this policy and safeguarded in accordance with all applicable legislation.


Do I have a right to object to processing?
You have the right to object at any time to the processing of your personal information.


What other rights do I have over the processing of my data? - You have the right to access any information we hold about you. Any request which is manifestly unfounded or excessive may be subject to a reasonable fee to cover our administrative costs in providing you with the necessary details. 
- You have the right to ensure the personal information we hold about you is up to date and accurate.
- If you have given consent to us directly (or indirectly via the Client) to process any of your personal information you may withdraw that consent at any time. 
- You have the right to opt-out of receiving emails or text messages from us at any time. You can do this by managing your privacy settings in the link contained in the footer of any email you may receive from us.

Please note that if you opt-out of receiving Redeal referral emails or text messages:
- We will not be able to send you any referral rewards you may be entitled to; and
- You will not be automatically opted-out of any other communications you may have opted to receive from the relevant Client. You will need to inform the Client directly if you wish to opt-out of their direct communications.
- You have the right to request that the personal information we hold about you be erased and/or request that the processing of that data be restricted.


How do I exercise my rights?
If you would like to exercise any of the rights listed above, you may submit a request to us on e-mail address: optout@redeal.se or by post to Magnus Ladulåsgatan 3, c/o The Park, 118 65 Stockholm. For data held by a Client as Data Controller, you may submit a request directly to the relevant Client in accordance with the procedures outlined in their privacy policy which will be available on their website.

In case of data held by us as Data Processor on behalf of a Client we will share any request promptly with the relevant Client who is the Data Controller and ultimately responsible for decisions made in respect of personal information we hold about you as a Data Processor.


If you have visited our website redeal.io, downloaded our content from a 3rd party website or attended one of our marketing events:

What data do you hold about me?
We may hold the following personal data about you:
- Your email address;
- Your first and last name;
- Your title;
- The company you work for;
- The details of any content you have downloaded;
- Details of your visits to our website; and
- A record of any correspondence between you and us.

As is true of most websites, we also automatically gather information about your computer such as your IP address, browser type, referring/exit pages and operating system. 


Where did you get this data from?
We will receive some or all of the above data directly from you if you have: 
- submitted it to us via our website when completing a contact form;
- submitted it to us when downloading content from our website;
- submitted it to us when communicating with us through our website chat feature; or
- submitted it to us when attending one of our hosted events. 

We may also receive certain of the above data from one of our 3rd party partners if you have submitted it to them when downloading any of our content that they publish on our behalf.


What do you do with my data?
We may use the above data: 
- To email you specific content you have requested;
- To keep you up to date with developments at Redeal and to send you marketing communications we think you may be interested in, unless you have opted-out of receiving such messages. You can opt-out at any time by clicking the unsubscribe link in the footer of any email you receive from us;
- To respond to any customer service enquiries; and
- To monitor traffic to our website and website performance. 

We hold and process all of the above data as Data Controller either because you have expressly consented for us to do so, or because it is in our legitimate business interests to process it for the purposes specified above. As Data Controller, we are responsible for keeping your data secure and processing it in accordance with applicable legislation.


How long do you hold my data?
We won’t process your data for any longer than is reasonably necessary for us to do so for the purposes specified above. 
Specifically: 
- If you have indicated to us that you are a consumer or a sole trader, we will not send you emails other than those you expressly solicit from us and we will then delete your data;
- If you have not opted-out of marketing communications from us, but you have also not responded to an email after 12 months of being on our marketing list, we will no longer send you emails unless you expressly request us to;
- If you have opted-out of marketing communications we will no longer send you emails and we will retain a copy of your data solely for the purposes of ensuring you are no longer sent marketing communications. 

Who do you share my data with?
We will only ever share your data, on a confidential basis, with our carefully selected Data Processors who we use in connection with the sales and marketing operations of our business.

We may disclose your data:
- as required by law.
- when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the rights and safety of other third parties, investigate fraud, or respond to a government request.
- to a third-party buyer or seller in the event that Redeal is involved in a merger, acquisition, or sale of all or a portion of its assets.
- to any other third party with your prior consent to do so. 

Where is my data stored?
Information we hold about you is stored and processed on Redeal’s secure servers and may be shared with and stored by our carefully selected Data Processors who we use in connection with sales and marketing operations of our business.The processing of your data may involve it being transferred to and/or stored at or accessed from a destination outside the European Economic Area (EEA). In such circumstances, we will take all steps reasonably necessary to ensure that your data is treated securely, in accordance with this policy and safeguarded in accordance with all applicable legislation.


Do I have a right to object to processing?
You have the right to object at any time to the processing of your personal information. 


What other rights do I have over the processing of my data? 
- You have the right to access any information we hold about you. Any request which is manifestly unfounded or excessive may be subject to a reasonable fee to cover our administrative costs in providing you with the necessary details.
- You have the right to ensure the personal information we hold about you is up to date and accurate.
- If you have given consent to us to process any of your personal information you may withdraw that consent at any time.
- You have the right to opt-out of receiving emails from us at any time. You can opt-out at any time by clicking the unsubscribe link in the footer of any email you receive from us. 
- You have the right to request that the personal information we hold about you be erased and/or request that the processing of that data be restricted. 

How do I exercise my rights?
If you would like to exercise any of the rights listed above, you may submit an e-mail to optout@redeal.se or by post to Redeal STHLM AB, c/o The Park, Magnus Ladulåsgatan 3, 118 65 Stockholm.