Privacy Policy FOCUS
Privacy Policy FOCUS
Last updated 220916
You should always feel safe when you provide your personal data to the Swedish foundation Stiftelsen Dispurse (“ Foundation ” or “ Dispurse Foundation ”) through the FOCUS app (“App” or “FOCUS”). With this privacy policy, the Dispurse Foundation wants to show how the Foundation ensures that, when you download and use the FOCUS App, your personal data is processed in accordance with the EU Data Protection Regulation 2016/679/EC ("GDPR"). The Dispurse Foundation protects your personal privacy and believes that personal privacy is of the utmost importance. The Foundation therefore takes your privacy very seriously.
In this privacy policy, "personal data" means personally identifiable information that specifically identifies or can identify you as an individual.
In cases where you do not choose to share personal data with us, certain services may be limited or not be available at all.
In this privacy policy:
- GENERAL
- PERSONAL DATA CONTROLLER
- PERSONAL DATA STORED AND ON WHICH BASIS
- STORAGE PERIOD
- PROTECTION AND SHARING OF YOUR PERSONAL INFORMATION
- YOUR RIGHT
1. GENERALLY
This privacy policy explains how Stiftelsen Dispurse processes, stores and shares your personal data when you use the Foundation's App FOCUS. This privacy policy also describes your rights and how you can use your rights vis-à-vis the Foundation.
The Dispurse Foundation may change this privacy policy from time to time in response to changing legal, technical or business reasons and developments. If this happens, the Foundation will publish the adjusted privacy policy on our website www.dispurse.org and in the information page for the App in Google Play. If we make material changes, we will notify you by changing the date at the top of this Privacy Policy and, depending on the specific changes, we may provide you with additional notice.
We encourage you to stay up-to-date on changes.
2 . PERSONAL DATA CONTROLLER
The Swedish-registered foundation Stiftelsen Dispurse, organization no. 863500-7340 , is the personal data controller for the processing of your personal data and is thus responsible for your data being handled correctly and securely in accordance with applicable legislation.
If you have questions about how the Foundation handles your personal data or if you want to use your rights, the easiest way to contact the Foundation is via e-mail at kontakt@dispurse.org (for Swedish speakers) and contact@dispurse.org (for other languages).
- PERSONAL DATA PROCESSED AND ON WHICH GROUNDS
Dispurse Foundation's policy means that we save and handle as little of your data as possible. Dispurse Foundation will collect the following personal data from you when you use Dispurse Foundation's App FOCUS.
- First and last name
- Social security number
- IP address
- Information about your use of the App, including but not limited to how you interact with the App and your results
- Other information you provide to the Foundation such as messages, photos or other things.
When you use the FOCUS App
IP address and interaction
When you use FOCUS, the Foundation automatically collects certain information from you and/or your device (which may be considered personal information under applicable data protection laws) such as IP address or interaction in the App. This makes the Foundation, with the legal basis, a legitimate interest where the Foundation has a weighty interest in being able to troubleshoot and take technical measures and develop if needed or desired. The Foundation considers that this interest outweighs the data subject's interest in personal data protection.
Name and social security number
In order for us to be able to provide the service in FOCUS to you, you need to provide us with your first and last name, as well as your social security number. This is based on the legal grounds to fulfill the agreement with you, where we undertake to offer training, follow-up and legal certificates, as well as to fulfill the legal requirements of the Foundation.
Interaction and results
When using the App, the Foundation collects information about how you interact and your results. This is done on the legal basis to fulfill the agreement, which according to above is mainly about offering training, follow-up and legal certificates, with you as well as fulfilling the legal requirements incumbent on the Foundation.
Other content provided by you
In cases where you upload other content in the App, such as a profile picture, the Foundation processes this based on the legal basis of consent.
- STORAGE PERIOD
The Dispurse Foundation stores personal data only as long as it is necessary to fulfill the purposes for which the data was collected or as long as the company is obliged to store personal data in accordance with law such as, for example, the laws required to provide the App and the certificates.
We store your first and last name, social security number, information about your use of the App, including but not limited to, how you interact in the App and your results during the time you use the service and five (5) years after you complete the service or otherwise notify that you do not wish to continue. The storage takes place in order to fulfill the agreement with you to provide certificates. After this time period, your personal data is deleted or anonymized.
Information about your IP address and other technical information about your device is deleted no later than fourteen (14) days after we receive the information.
In some cases, personal data may be stored longer to protect the company's legal interests, or in accordance with applicable legislation. The personal data is then deleted.
- PROTECTION AND SHARING OF YOUR PERSONAL DATA
Generally
In order for you to feel safe when you provide us with your personal data, the Foundation has taken the necessary security measures to protect your personal data against improper access, change and deletion.
The Foundation collects and processes personal data on a voluntary basis and it is not about selling your personal data to third parties. However, personal data may sometimes be disclosed in accordance with applicable legislation and this privacy policy.
The Dispurse Foundation may share personal information with third parties in cases where you have consented or if there is another legal basis for such processing. However, the Foundation admits that this should be done restrictively. In such cases, the Foundation always takes the necessary measures to ensure that your data is handled securely.
Special sharing
Personal data regarding first and last name and social security number will be shared with the Foundation's subsidiary foundation in Peru in order to be able to fulfill the agreement with you as the subsidiary foundation conducts operational activities on behalf of the Foundation. Other actors may also be hired for the same purpose, where personal data may then be shared. The user should be aware that rules outside the EU / EEA may mean less protection for your personal data.
Personal data may also be shared with IT providers and cloud services , which may be based outside the EU/EEA. Personal data may also be shared with authorities to fulfill legal requirements.
Protection when sharing outside the EU/EEA
In cases where your personal data will need to be transferred and stored outside the EU / EEA, the Foundation selects these suppliers with the greatest care and with regard to your privacy. Nevertheless, the Foundation ensures that the personal data is handled in the safest possible way.
The Dispurse Foundation will also take all necessary security measures to ensure that your personal data is handled securely and with an adequate level of protection (for example, using approved standard clauses and additional appropriate safeguards).
You can read more about the Standard Contractual Clauses and obtain a copy at:
- YOUR RIGHTS
Free register extract
Provided that Dispurse Foundation is the controller of personal data, you have the right, at any time, to receive a register extract free of charge with information about what personal data is registered about you, the purposes for the processing of this personal data and information about where this personal data has been obtained, as well as to which recipients the information has been provided or is to be provided. You also have the right to receive information in the register extract about the anticipated period during which the data will be stored or the criteria used to determine this period. You also have the right to find out about the existence of automated decision-making (including profiling). The request to access such information must be in writing and sent to Dispurse Foundation at the address stated below under the heading "Personal data manager".
Data portability
You have the right to data portability, i.e. a right to, under certain conditions, obtain and transfer your personal data in a structured, commonly used and machine-readable format to another personal data controller.
Correct and delete
Dispurse Foundation will, at your request or on its own initiative, correct, de-identify, supplement or delete information that is found to be incorrect, incomplete or misleading. In some cases, the Foundation is obliged to process your personal data even though you have requested that it be removed, for example in the case of the right to freedom of expression and information, to fulfill a legal obligation or to perform a task of public interest.
Limit use
In some cases, you have the right to demand that the processing of personal data be restricted. Restriction means that the data are marked so that they may only be processed for certain limited purposes in the future.
Withdraw consent
In cases where you have previously given consent to the processing of your personal data, you have the right to withdraw that consent both verbally and in writing.
Automatic decision making
You have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.
We do not engage in fully automated decision-making that has a legal or otherwise significant effect using customer data.
Exercise rights, ask questions or make complaints
If you want to exercise any of the above rights, if you have any questions regarding personal data held by the Foundation, if you have questions about this privacy policy or if you are dissatisfied with the Foundation's processing of your personal data, do not hesitate to contact the Dispurse Foundation, whose contact details can be found under point 2 of this policy.
Please note that even if you object to certain processing of personal data, we may still carry out the relevant processing if it is permitted or required by law, for example in order to fulfill legal or contractual requirements.
You always have the right to lodge a complaint with the relevant supervisory authority, particularly where you live, work or where an alleged breach of the GDPR has occurred. You can find the relevant authority in your country here:
http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm