- The controller of your personal data
- Purpose of the collection of your personal data
- What kind of personal data is collected
- The way we collect your personal data
- Storage of your personal data
- Transfer of your personal data
- Legal basis for processing your personal data
- Securing your personal data
- Your rights
- Contact details
1 The controller of your personal data
For the purpose of compliance with the data protection legislation, the data controller is Ellmount Interactive AB, Kungsbron 2, 111 22 Stockholm, Sweden.
2 Purpose of the collection of your personal data
We will ensure that personal data collected is processed only for one of the following purposes:
- to register you as an Affiliate to us (e.g. filling in requested KYC-data),
- to provide the products and services related to acting as an Affiliate to us,
- to provide customer service, including answering your questions or complaints,
- to notify you about changes to our products and services,
- to communicate with you about promotions and other news about products and services offered by us, including via email in accordance with any marketing consent provided by you,
- to facilitate product development and to operate, maintain and improve our products and services, and to comply with our legal obligations and for establishing, exercising or defending legal rights.
We will not use your personal data for direct marketing purposes unless you have specifically consented hereto.
3 What kind of personal data is collected
Information You Provide: We collect information that you voluntarily provide when you use the Services, such as when you register as an Affiliate to Ellmount Interactive AB. The types of information that you provide are based on the specific function of the services that you use, and you won’t be able to register your account without providing the following information:
- Contact information: your name, surname, address, email address, phone number, zip code & County+ Other contact methods like MSN, Skype etc.
- Financial information: in order to operate online payments, we collect your banking details and transactional information, such as the payments to and from your account with Us.
- Furthermore, due to Anti Money Laundering & KYC legal requirements we will at times ask you for supplementary documents such as identification documents including your photo, documents regarding your source of wealth, utility bill and others.
Information We Receive from Third Parties: We may combine the information we collect from you with information that we receive about you from other sources, such as public databases, providers of demographic information and other third parties. Due to regulatory requirements We collect know your customer (KYC) information from specialised third parties. Such information is collected only when it is reasonably necessary for the organisation’s activities.
Information collected automatically from your device: We and our third-party service providers may collect information automatically from your device in a variety of ways, including:
- Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your IP, device type, language and the Internet browser type you are using. We use this information to ensure that Our services function properly.
- Through your use of an app: When you download and use one of our apps, we may track and collect app usage data, such as the date and time the app on your device accesses our servers and the information and files that have been downloaded to the app.
4 The way we collect your personal data
We collect personal data in various ways including:
- identifiable personal data that you provide to us through our website by filling in forms on our website, including information you provide when you use our website, products and services
- identifiable personal data that you provide to us when corresponding with us by phone, email or otherwise
- automatically when you interact with us and/or visit our website.
We will only process personal data in relation to the purposes set out in Section 2 above.
5 Storage of your personal data
We will only store the personal data we collect about you for as long as 1) it may be necessary for us to fulfil our contractual obligations (during and after your subscription to our products or services) in respect of the products and services requested by you, 2) it may be necessary for us to facilitate product development and to operate, maintain and improve our website, products and services, but in this respect no longer than 1 year, or 3) it is required by applicable law. We will in any case only ask for your personal data where necessary for the purposes set out in Section 2.
When we finish processing your personal data for the stated purpose, we will erase it from our system to ensure your privacy.
6 Transfer of your personal data
We will never transfer or sell personally identifiable information about you to a third party without your explicit consent, unless as specified below:
- We may transfer personal data to affiliate or subsidiary companies, as well as professional advisors, including accounting firms and law firms
- We may transfer personal data to employees, agents, business partners, vendors, suppliers and providers of analytics tools who assist with our business activities
- We will transfer personal data in order to comply with legal requirements.
The transfer of personal data takes places in compliance with legal requirements, including data processor agreements where relevant, to ensure that data is not processed for other purposes than clearly stated and to ensure adequate security measures.
The personal data that we collect from you may be transferred to and stored at a destination outside the European Economic Area (“EEA”). If personal data is transferred outside of the EEA, we ensure an adequate level of security by transferring to countries approved by the EU Commission as having an adequate level of protection, or by entering into an appropriately-drafted contract (such as the standard data protection clauses adopted by the European Commission) between us and the non-EEA entity receiving the data.
7 Legal basis for processing your personal data
- for the performance of or entering into a contract with you, including in order to provide our products and services to you, process your payment, register and process claims and to respond to enquires made by you
- for compliance with our legal obligations, including in respect of payment processing and financial account management, or
- for the purpose of furthering our legitimate interests, including in respect of improving our products, services and website, to operate our website, to facilitate direct marketing, and to provide customer services.
We also process your personal data on the basis of any consent provided by you, for instance in order to send you product offers, information about services or other marketing.
8 Securing your personal data
We will ensure that appropriate security measures (such as technical and organizational physical, electronic, and procedural safeguards) are implemented to protect the personal data collected against unauthorized or unlawful processing and against accidental loss, damage, destruction, alteration or disclosure.
9 Your rights
If you have any questions regarding our processing of your personal data, please contact us using the contact details described below under Section 11.
You have the following rights in accordance with data protection legislation, however, please note that some of the rights may only apply under certain circumstances:
- the right to obtain a copy of the personal data we have collected about you and to transmit said copy to another data controller
- the right to update or amend the personal data we have collected about you if it is inaccurate or incomplete
- the right to erase, or restrict the processing of, the personal data we have collected about you
- the right to object to the processing of the personal data we have collected about you, including in respect of any data processed for direct marketing purposes, and
- the right to withdraw any consent you have provided in respect of our processing of your personal data.
11 Contact details