Gleedeals.
Introduction
We at Let's deal protect the privacy of our users and we therefore work actively to protect the personal data we process in our business.
This Privacy Policy explains how and why Let's deal processes personal data. It also explains how we work to protect the privacy of our users and what rights you have regarding our processing of personal data.
The personal data controller for the processing of personal data mentioned in this Privacy Policy is, unless otherwise stated, Let's deal AB ( "Let's deal" or "We" ).
Important definitions
Personal data
Any information relating to an identified or identifiable natural person. Examples of personal data are your name, address, phone number, email address, information about your payment card, IP address, etc.
Processing
An action or combination of actions regarding personal data. Examples of processing are collection, storage, publication, use, editing, deletion, etc.
Personal data controller
A natural or legal person who, alone or together with others, determines the purposes and means for the processing of personal data.
Personal data assistant
A natural or legal person who processes personal data on behalf of the personal data controller.
Registered
The identified or the identifiable individual to whom the personal data belongs.
Personal data processor agreement
An agreement or other legal act between the personal data controller and the personal data processor that states the purpose of the processing, the type of personal data processed, categories of registered and the personal data controller's obligations and rights.
Partner
A legal or natural person contracted by Let's deal who offers or sells goods and/or services via Let's deal's platforms.
Legal basis
In order for Let's deal to have permission to process personal data, support is required in the new Data Protection Regulation. We call such support a legal basis.
About the legal basis for our processing of personal data
We process personal data according to law, which means that we have a legal basis for our processing of personal data. Which legal grounds we have depends on the type of processing involved. If you want to know more about which legal bases may be relevant, click here.
The legal bases we use are the following:
Consent
When you as a user give us your consent for a specific processing of your personal data.
Contractual obligations
If the processing is necessary to fulfill an agreement between you and us at Let's deal.
Legitimate interest
If our interests outweigh the infringement a processing entails for the data subject, and if the processing is necessary for the current purpose of the processing.
Legal obligation
When the processing is necessary to fulfill a legal obligation prescribed by either Swedish law or EU law.
Sometimes we have several legal grounds for processing personal data. For example. can we process personal data based on consent while we have a legal obligation to do so. This means that even if the consent is withdrawn, we can continue our processing of the personal data provided that we have another legal basis to rely on.
About Let's deal's role and personal data responsibility
Let's deal is a marketing channel and intermediary of services and goods. There are also cases where we sell goods or services in our own name. Due to this multi-faceted role, it can sometimes be difficult to understand the scope of our personal data responsibility.
When a Partner is listed as the selling party in a deal, we are the personal data controller for the processing that takes place within the framework of our intermediary mission. The partner, on the other hand, is the personal data controller for the processing that takes place to deliver/perform what the customer has purchased. Partner is thus responsible for its processing and that it meets the requirements set by applicable data protection legislation. When we are listed as the selling party in a deal, we are the personal data controller for the processing that takes place in order for you to get your product/service delivered/performed. This means that the actors we employ to, for example, manage packaging and delivery as a starting point act as personal data assistants for us. We enter into special agreements with these parties, among other things to ensure that your personal data is not used for purposes other than that you should receive what you purchased.
Feel free to contact us if you have questions about our or our Partners' personal data responsibility.
Why do we need to process personal data?
We at Let's deal want to continue to be able to offer our users and customers the best possible deals in the future as well. We also want to be able to offer you an optimal user experience when you use our services. In order to do this, we need to process personal data for the following purposes:
1. To be able to provide our service and deliver what you bought
We at Let's deal process personal data to be able to provide our website and our app. In addition, we process personal data in order to deliver products and services that are purchased via Let's deal.
2. To personalize our services
In order for us to be able to adapt the content of our services according to the preferences of our users, we need to process personal data. This means that we are better able to exclude content from our services that you have no interest in.
3. To be able to analyze and improve the use of our services
We want to be able to create the best conditions possible to improve our services. An important part of this is understanding how our users interact with our services. Therefore, we collect data about our users' behavior on our website, app and in our newsletters. We convert this data into aggregated data, which cannot identify individual users. With this aggregated data, we can understand trends, see which products attract customers, identify problems in our services and much more. Ultimately, this leads to a better Let's deal experience.
4. In order to troubleshoot and prevent misuse of our services
We process personal data, including user ID, IP address and email address, in order to troubleshoot our systems. This is done to discover which users have been affected by any errors in our systems and so that we can offer secure services. We also process personal data to prevent misuse of our services. Examples of such abuses may be attempts at unauthorized access to our user accounts, fraud, spam or other types of malicious behavior. The processing of personal data to carry out troubleshooting and to prevent abuse of our services is based on our legitimate interest, unless otherwise stated.
In case of suspicion of fraud or other criminal activity when using our services or services that are closely related to Let's deal, we reserve the right to share the necessary personal data with the relevant authority or Partner to investigate the matter. This processing is based on a legal obligation or legitimate interest. We only share information, including personal data, that is necessary to investigate the specific case.
5. To offer relevant online marketing
In order to be able to offer our users relevant marketing, we collaborate with third parties. By sharing personal data with these actors, the marketing you see on other websites or apps can be adapted to your interests you have shown when using our services. Thanks to this, the risk of being shown irrelevant marketing is reduced.
We are the personal data controller for the personal data collected from you in order to offer relevant marketing when we use Google services (Adwords and Doubleclick) and Facebook's Customized Target Groups where we upload customer lists. With regard to the Facebook Pixel and SDK, Appnexus and Criteo are each personal data controllers for their respective processing. In our Cookie Policy, you can read more about how you can change your settings regarding our use of these functions.
A special case when it comes to marketing is our use of Facebook's Custom Target Groups. With the help of this service, we have the opportunity to create target groups based on what our users seem interested in when they interact with Let's deal and reach out to these people on Facebook. The use of this function does not mean that Facebook takes part in your interests or any data concerning your relationship with Let's deal. The processing that is done to create target groups that will receive relevant marketing takes place locally at Let's deal and the e-mail addresses included in the processing are hashed/anonymized before they are transferred to Facebook. This means that Facebook does not have access to your interests when we use custom audiences. The use of this service is based on Let's deal's legitimate interest. You shall not be part of a customized target group longer than 6 months after your last visit to Let's deal, or 12 months after you made your last purchase at Let's deal. If you want to be exempt from this type of treatment, please contact us.
6. To be able to offer marketing via email
We send out newsletters via email to those who have consented to this and to active users or active customers. The processing of personal data for this purpose is based on your consent or our legitimate interest in marketing Let's deal. If you no longer wish to be subject to the sending of newsletters via email, you can unsubscribe at the bottom of all our mailings.
Sometimes we send out offers via email that we think might suit you. We only do this if you have bought from us recently. The legal basis for this is our legitimate interest in being able to provide you with unique offers. Contact us if you do not wish to receive this type of offer.
7. To measure the effectiveness of our marketing on other websites
We at Let's deal use third-party services to measure the effectiveness of marketing made via other websites and apps. We do this to be able to understand how our marketing campaigns are performing and to be able to learn from this in the future. Within the framework of this use, we collect data on, among other things, how many users came via a specific advertisement or campaign and what the conversion looked like afterwards. In order for us to activate that function, we need your consent.
Which categories of personal data do we process?
The personal data we process can be divided into three categories:
1. Information you provide to us yourself
If you create an account to log in to Let's deal, you need to enter your email address and name.
When you make a purchase via Let's deal, you need to provide certain personal data, among other things so that you can pay for your purchase or so that we can deliver an item to you. The personal data that may be processed for these purposes are your name, email address, address and telephone number. We need this personal data to be able to carry out our contractual obligations towards you as a customer. The processing continues until the purchase or delivery has been completed, with an additional storage period of 36 months for us to be able to handle complaints and other consumer protection-related services. The processing carried out during the additional 36 months is based on a legal obligation. We are legally obliged to save certain transaction data for 7 years. Such data may contain personal data.
If you contact us at Let's deal, for example our customer service, you may share personal data with us, depending on what your case is about. We process this personal data to reach a solution for your specific matter. As a starting point, we base this processing on our legitimate interest. The processing may also be based on an agreement between us at Let's deal and you, depending on the capacity in which you contact Let's deal, as a customer or as a person who has general questions about our services or products. We store your personal data for this purpose for as long as is necessary to handle your matter. We cannot give a general answer as to how long our treatment can last, as it entirely depends on what the case is about.
If you give us feedback, for example for a deal or our customer service's treatment, you may share personal data with us. What you share with us depends on what you choose to include in your feedback. If you choose to share personal data via our feedback functions, we will process these based on our legitimate interest consisting of being able to evaluate our service functions and our customers' satisfaction. The personal data will only be stored until the feedback has been collected and anonymized, which will happen when we have received your feedback.
If you exercise your right of withdrawal or in the event of a complaint, we may need your account number to make refunds to you. We do this to be able to handle your case quickly by avoiding involving our payment provider. Collection and use of your account number is based on the agreement we have with you as a customer. In some cases, that processing is based on a legal obligation, as according to the Consumer Purchase Act we are obliged to make refunds to you, e.g. When exercising the right of withdrawal . The personal data is stored until a refund has been made. After that, the processing ceases, provided that we have no other legal basis for its processing.
2. Information about how our users interact with our services
When you use our services, we collect information about how you interact with our services. This information may include the following personal data:
Information about your device
By using technical logs and other tools, we register information about what device you use, for example which device you use, which browser you have and your IP address. This processing enables us to adapt our services based on your technical user situation. The processing of personal data for this purpose is based on our legitimate interest in being able to offer a properly functioning service.
Information about the use of our services
We collect information about how our users interact with our services for improvement and analysis purposes. Such information includes IP addresses, user behavior and user interests, which are then transformed into aggregated and anonymized data. This processing of personal data is based on our legitimate interest in being able to analyze and improve our services. To help us, we use tools such as Google Analytics 360, Google Analytics for Firebase, Google Optimize 360 and Hotjar. In Google Analytics 360, Google Optimize 360 and Google Analytics for Firebase, we save your personal data for 14 months from the time of collection. In Hotjar, we save your personal data for 12 months from the time of collection. You have the right to be exempted from this type of treatment in our settings, which you can find at the bottom of the desktop and mobile pages or under My pages > Settings > Personal data in the app.
We also process personal data to be able to personalize our services and e-mails to our users and customers, all to give you a tailored experience of Let's deal. The personal data used for this purpose are your email address, your user ID, your IP address, your user behavior and your previous purchase history at Let's deal. This processing is based on our legitimate interest. We only store your personal data for 12 months from the time the personal data was collected. If you do not want to be subject to this type of treatment, you can change this in your privacy settings. You can find these at the bottom of the desktop page and the mobile page, or under My page > Settings > Personal data in the app.
Information about your geographic location
We have the option to adapt our services and content according to your geographic location, but then we need your consent. If you have not given your consent, we will not collect data about your geographic location, unless we have another legal basis to do so.
The personal data covered by this processing is your IP address and your geographic location. The processing continues until you withdraw your consent or until we no longer have a legal basis for the processing. To opt out of the collection of this information, you can disable location services in your mobile or in your browser for the service in question.
Cookies and other local storage of data
We at Let's deal use cookies and other types of local storage of data, among other things to be able to offer a functioning website, to be able to collect and analyze how our users interact with our services and, in the event that you have given your consent, in order to provide you with relevant marketing on other websites. Click here to access our Cookie Policy where you can read more about how we use cookies and other local storage of data.
3. Information from other actors
It happens that we at Let's deal receive personal data from other actors and not directly from our users. This can occur, for example, when authorities contact us or when our payment service provider contacts us about a certain transaction.
Personal data under this category can be data linked to your purchase, for example payment method, purchased product, price, etc. Since the flow of information is not controlled by us, we cannot provide an exhaustive list of the types of personal data that may occur. Therefore, we also cannot state which legal basis will be applied when processing such personal data. If you have questions regarding this type of situation, please contact our customer service and they will help you further.
Who do we share your personal data with?
On certain occasions, we need to share personal data with Partners and other service providers. We will then be transparent with which personal data we share and with whom we share this personal data. We also take precautions on such occasions, adapted to who we share personal data with. This is to ensure that your personal data is not processed for other purposes than intended.
We at Let's deal may share personal data with personal data processors, which means that this party processes personal data on our behalf. Personal data assistants are subject to confidentiality and are not permitted to process personal data on our behalf for purposes other than offering the agreed services to us.
To ensure that our personal data assistants comply with relevant legislation, we enter into special agreements with these parties. Such agreements, called personal data processor agreements, aim to ensure that the personal data processor processes personal data on our behalf only in accordance with the current agreement.
There are also cases where we share personal data with third parties who should not be seen as personal data processors. In such cases, we will be transparent about how and why we share personal data with this party. An example of such a situation is when a customer has purchased a deal that qualifies for Root or Square deductions. Then the partner who will perform the service needs a verification from us that contains personal data. The partner needs this verification to handle matters with the Swedish Tax Agency. In these situations, we share personal data for the sake of customers and partners, namely so that they can benefit from Root or Square Deductions.
How do we ensure task minimization?
We at Let's deal will only process personal data that is adequate, relevant and limited to what is necessary to fulfill the purpose for which it is processed. We work actively and systematically to ensure that redundant personal data is excluded from our processing.
How long do we store your personal data?
We process your personal data for as long as it is necessary to fulfill the relevant purpose or for such a period of time as is necessary to fulfill a legal obligation. Processing to fulfill a legal obligation consists of cases where we need to save accounting information for accounting purposes, or in cases where we need to save customer data in order to satisfy consumer rights.
Where do we process your personal data?
We at Let's deal strive to only process personal data within the EU or within the EEA area. In some cases, it happens that our own or our partners have their servers located outside the EU or EEA area. In such cases, we initiate processes to enter into special personal data processing agreements that are adapted to processing outside the EU or EEA area.
Regardless of where your personal data is processed, we take measures to ensure that your personal data is not processed for purposes other than those agreed upon.
Your rights
You have, with the restrictions that follow from applicable legislation, the following rights:
- To request access to your personal data, which includes the right to request a register extract of which personal data Let's deal processes about you,
- To request editing of your personal data,
- To request restriction of our processing of personal data,
- To have your personal data deleted ,
- Right to object to our processing of personal data,
- To have your personal data transferred to another personal data controller ( data portability )
These rights are fulfilled to the extent that this is compatible with applicable legislation. The rights may therefore be limited.
If you want to exercise any of these rights, please send a request to kundtjanst@letsdeal.se. When submitting such a request, you will be required to identify yourself by submitting a photocopy of either your driver's license, passport, ID card or other documentation proving your identity.
Changes to the Privacy Policy
We will continuously update this Privacy Policy to ensure that it is consistent with the services offered through Let's deal. The latest version will be available at letsdeal.se/integrity
* The last update was made on 2022-06-30
Contact details
If you have any questions about this Privacy Policy or about how we process personal data, please contact our customer service at kundtjanst@letsdeal.se
You can also contact the Swedish Data Protection Authority if you wish to make a complaint regarding Let's deal's processing of personal data.
If you want to get in touch with our Data Protection Officer, you can contact personoppgiftsombud@letsdeal.com .
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