Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
1. Who we are
We are a technology company which, through our Services and thanks to a keyword-searchable friend finder, helps you meet like-minded people nearby. Whether you've just moved to a new city, you're traveling solo, you've discovered a new hobby, or just want a new friend, Panion is here to help. For more information about our Services, please visit the Panion blog: https://panion.com/blog.
We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation (“GDPR”) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
How to contact us
Our office is located at: Panion Tech AB, Bredgatan 4 211 30 MALMÖ, Sweden
You can write to us regarding privacy matters by sending an email to: firstname.lastname@example.org
2. Our Services
Throughout our Website and App, we may link to other websites or mobile applications owned and operated by certain trusted third parties to make additional products and services available to you, such as downloads from the App Store or from Google Play. These other third-party websites and applications may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third-party websites, please consult their privacy policies as appropriate.
Use of our Services by children
Our Services (Website and App) are intended for users who are at least 16 years of age. We only collect personal information from persons under the age of 16 if they have obtained parental or guardian consent, which will be verified on sign-up to our Services. We encourage parents and guardians to spend time with their children online and to be familiar with the websites they visit and the apps they use. If you have reason to believe that we may have accidentally received information from a person under the age of 16 without parental or guardian consent, please contact us immediately at email@example.com. If we become aware that we have inadvertently received personal information from a person under the age of 16 without parental or guardian consent, we will delete such information from our records.
3. Our collection and use of your personal information
We collect personal information about you when you access our Website, our App, register with us, contact us, send us feedback, use our Services and complete customer surveys or participate in competitions via our Services or have any other interaction with us.
We collect this personal information from you either directly, such as when you register with us, contact us or use our Services or indirectly, such as your browsing activity while using our Website or App when you have provided your consent allowing us to do this. For more information, see the section, ‘Cookies and other tracking technologies’ below.
The personal information we collect about you depends on the particular activities carried out through use of our Services.
Information you provide directly to us
We collect information you provide directly to us, such as in the following situations:
when you fill out forms or fields through our Services
when you register for an account with our Services
when you order products from, or through our Services
when you sign up for any newsletters or other materials through our Services
when you provide information to us through a third-party application, service or website
when you communicate with us or request information about us or our Services, whether via email or other means
when you participate in online surveys
when you participate in any of our marketing initiatives, including, contests, events, or promotions
when you participate in forums, reviews or provide user generated content or other submissions.
This information may include, without limitation:
date of birth
contact details, such as e-mail address, physical address, business address, phone number
your marital status
details of any feedback you give us by phone, email, post or via social media
information about the Services we provide to you
your account details, such as username, login details or other personal information you choose to provide.
Information provided to us from third parties
Information we do not collect
We do not collect or store payment information, including credit/debit card details or billing information. However, we may facilitate the transfer of your payment information to third party payment processor gateways. All payments are handled by the third-party secure payment provider gateway.
We do not collect any sensitive data about you (also known as special categories of personal data), such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data, nor do we collect any information about criminal convictions and offences, unless you expressly consent to share this this information with us directly or where you decide to make such information manifestly public – for example by freely stating your interests in such matters via use of our Services or when you share such data yourself via your public profile.
4. Our legal basis for how we use your personal information
When we use your personal information, we are required to have a legal basis for doing so. We will only request information that is needed to provide you with our Services. There are various different legal bases on which we may rely, depending on what personal information we process and why. The legal bases we may rely, and when we rely on them, include:
Consent: where you have given us clear consent for us to process your personal information for a specific purpose? For example, if you supply any sensitive data to us, or opt-in to any direct marketing.
Contract: where our use of your personal information is necessary for a contract, we have with you, or because you have asked us to take specific steps before entering into a contract? For example, to verify your identity, create your account, resolve problems and disputes or enforce our Terms of Service.
Legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations)? For example, to resolve problems and disputes, and engage in other legal and security matters.
Legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information, which overrides our legitimate interests)? For example, to create and manage your account with us, contact you, verify your identity, provide Services to you, customize our Services and their content to your particular preferences, notify you of any changes to our Services that may affect you, improve and analyze our Services or for customer support including, but not limited to, confirming emails related to our services, reminders, confirmations, requests for information and transactions, to verify your identity and prevent impersonation, spam or other unauthorized or illegal activity including, without limitation, infringement of intellectual property rights of third parties.
5. Who we share your personal information with
Panion does not sell, rent or lease your personal information to third parties.
Some of those third-party recipients may be based outside the European Economic Area (“EEA”). For further information including on how we safeguard your personal data when this occurs, see the section ‘Transfer of your information out of the EEA’.
Internal Third Parties:
Such as with Panion subsidiaries and affiliated entities that provide services or conduct data processing on our behalf, or for data verification, data centralization and/or logistics purposes, as well as our own staff, who may have access to your personal information on a need-to-know basis in order to carry out their functions.
External Third Parties:
Service providers: Service providers acting as processors based inside and outside of the EEA so that they may provide support for our internal and business operations, including for the processing of payments, handling of data processing, data verification, data storage, surveys, research, internal marketing, marketing partners delivery of promotional, marketing and transaction materials, and maintenance of our Services and security.
Professional advisers: acting as processors or joint controllers or separate controllers including lawyers, bankers, auditors and insurers based in and outside of the EEA who provide consultancy, banking, legal, insurance and accounting services.
Official authorities: including tax authorities, regulators and other authorities acting as processors or joint controllers or separate controllers based in Sweden (where we are established) and who require reporting of processing activities in certain circumstances.
Compliance with law: We will share personal information with law enforcement or other authorities if required by applicable law.
Third parties at your request:
We may share your personal information when you request us to do so, for example:
When you engage in certain activities through our Services that are sponsored by third parties, such as purchasing products or services offered by a third party, electing to receive information or communications from a third party, or electing to participate in contests, sweepstakes, games or other programs sponsored, in whole or in part, by a third party.
When you use other apps or websites that integrate with our API or Services, or those with an API or service with which we integrate.
With the general public if you submit content in a public forum, your reviews, comments or other features of our Services that are viewable by the general public.
Please note that any information or content that you voluntarily disclose for posting publicly to our Services or the social sharing service becomes available to the public, as controlled by any applicable privacy settings that you set within the social sharing service. Once you have shared user content or made it public, that user content may be re-shared by others. If you remove information that you posted to our Services or the social sharing service, copies may still remain viewable in cached and archived pages, or if other users or third parties, using our Services or the social sharing service, have re-shared, copied or saved that user content.
Social Sharing Features
Our Services may now or in the future integrate with social sharing features and other related tools which let you share actions you take on our Services with other Apps, sites, or media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Where possible, we will only share information about you in an aggregated and/or anonymized form which cannot be used to identify you. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. Transfer of your information out of the EEA
Some of our external third parties and members of the Panion group of companies are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Cookies and other tracking technologies
Cookies help us to recognize you and your device and store some information about your preferences or past actions. These technologies help us to better understand how our Services are being used by visitors and allows us to administer and customize the Services to improve your overall experience. They also improve our marketing, analytics, or App/Site functionality, and to document your consent to receiving products, services or communications from us or our partners.
Third party cookies
We would like to send you information about our Services, promotions, news, and events of Panion and other companies, which may be of interest to you. Where we have your consent, we may do this by post, email, telephone, text message (SMS) or automated call or by display advertising, including advertising that is targeted to you based on your location, interests, as well as your Panion activities.
We would also like to share your information with selected third parties from time to time so that they may send you information about their products or services, depending on what you agree with us.
We will only ask whether you would like us and other businesses to send you marketing messages when you tick the relevant boxes on our Website or within our App.
If you have previously agreed to being contacted in this way, you can unsubscribe or “opt-out” at any time by:
using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
updating your marketing preferences within the App
by following the instructions in any marketing messages.
It may take up to 30 days for this to take place. Please note, when you opt-out, we may still send you non-promotional communications regarding your account, about Services you have requested, or about our ongoing business relations with you.
Third party re-marketing services
You can opt-out of remarketing by visiting the links below:
For Facebook: https://www.facebook.com/ads/website_custom_audiences/
For more information on your rights in relation to marketing, see the section ‘Your rights’ below.
9. Links to Third Party Websites
10. Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Please remember that the nature of the Internet means that transmission of your personal information online is inherently insecure. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org.
11. How long we keep your data for
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. Therefore, we will keep your information for as long as you have an account with us to allow us to provide you with friend-matching services. Your information can be deleted at any time, including when you choose to deactivate your account. In the event of longer inactivity, we will erase data on a regular periodic basis. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you as well as for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Whenever possible, your data will be anonymized.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In some circumstances you can ask us to delete your data: see the section ‘Your rights’ below for further information.
12. Your rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. In summary, those include rights to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data's accuracy.
Where our use of the data is unlawful, but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
13. How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in Sweden is the Data Protection Authority (Datainspektionen) who may be contacted at https://www.datainspektionen.se/kontakta-oss/, by email: firstname.lastname@example.org or by telephone: (+46) (0) 8-657 61 00.
Last updated: 18 February 2020