We are committed to safeguarding the privacy of our website visitors, service users, individual customers, and customer personnel.
This policy applies to all ChangeAbility AB websites and services where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
In this policy, "we", "us" and "our" refer to ChangeAbility AB and ChangeAbility operating under registered trade names, including DFRNT. For more information about us, see Section 14.
This document was created using a template from Docular https://seqlegal.com/free-legal-documents/privacy-policy).
The personal data that we collect
3.1 In this Section 3 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
3.2 We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you and/or your employer. If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.
3.3 We may process user account data in relation to services provided through our websites on which you have signed up ("account data"). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you and/or your employer, although some elements of the account data may be generated by our website. If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider.
3.4 We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.
3.5 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
3.6 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
Purposes of processing and legal bases
4.1 In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.
4.2 Operations - We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business, and when applicable, the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
4.3 Publications - We may process account data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is consent, namely the publication of content in the ordinary course of our operations OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
4.4 Relationships and communications - We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.
4.5 Direct marketing - We may process contact data, account data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.
4.6 Research and analysis - We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
4.7 Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
4.8 Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
4.9 Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
4.10 Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
4.11 Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
Providing your personal data to others
5.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
5.2 Your personal data will be registered in databases and logs for services we provide on servers located at our hosting services provider Inleed https://inleed.se/ in Sweden.
5.3 We run the Plausible Analytics script to collect anonymous usage data for statistical purposes on our website and services. It does not track any individual people and the provider for our web analytics is https://plausible.io, hosted on servers in Germany.
5.4 Financial transactions relating to our website and services may be handled by our payment services providers, Paypal, Inc and Stripe, Inc. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your orders, payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://www.paypal.com/en/webapps/mpp/ua/privacy-full and https://stripe.com/gb/privacy.
5.5 Your personal data may also be disclosed to our service providers to enable them to provide their services to us. The relevant services providers include Microsoft (user directory services in Azure and email in Office365) hosted in Europe in Sweden, Ireland and the Netherlands; Pipedrive (customer relationship management) on servers located in Frankfurt, Germany; Mixpanel (product analytics) hosted in Europe in the Netherlands; and, in facilities hosted outside of Europe, by Basecamp, Inc (team communications); Mailchimp (newsletter services).
5.5 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
International transfers of your personal data
6.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to a third country under EU data protection law.
6.2 We may transfer your personal data from countries of the European Economic Area (EEA) to the United States and process that personal data in the United States for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so. Transfers to each of these countries will be protected by appropriate safeguards, namely the providers’ use of standard data protection clauses adopted or approved by the competent data protection authorities, a copy of which can be obtained from European Commission Standard Contractual Clauses (SCC).
6.5 The hosting facilities of our email newsletter processing are situated in the United States and operated by Mailchimp. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities, a copy of which can be obtained from European Commission Standard Contractual Clauses (SCC) and more information on Mailchimp’s implementation of the GDPR standard contractual clauses (SCC) can be found at https://mailchimp.com/help/mailchimp-european-data-transfers/. By opting out of the newsletter, your personal data will not be transferred as part of the newsletter service.
6.6 The DFRNT team communications facilities are situated in the United States and operated by Basecamp. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities, a copy of which can be obtained from European Commission Standard Contractual Clauses (SCC) and more information on Basecamp’s implementation of the GDPR standard contractual clauses (SCC) can be found at https://basecamp.com/about/policies/privacy. Personal data will only be processed at Basecamp in exceptional cases, and you can express your wish to explicitly not have your personal data processed at Basecamp by sending an email to email@example.com.
6.6 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
Retaining and deleting personal data
7.1 This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 We will retain your personal data as follows, at the end of which periods it will be deleted or anonymised:
- contact data will be retained up to 7 years following the date of the most recent contact between you and us;
- account data and service data will be retained for so long as the associated account remains open and for a period of up to 7 years following the end of the year during which the corresponding account was closed;
- transaction data will be retained for a period of 7 years following the end of the year during which the transaction occurred;
- newsletter data will be retained for so long as the relevant person remains opted-in to notifications;
- communication data will be retained for a period of up to 7 years following the date of the communication in question; and
- usage data will be retained for a maximum period of 30 months following the date of collection.
7.4 Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8.1 In this Section 8, we have listed the rights that you have under data protection law.
8.2 Your principal rights under data protection law are:
- the right to access - you can ask for copies of your personal data;
- the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
- the right to erasure - you can ask us to erase your personal data;
- the right to restrict processing - you can ask us to restrict the processing of your personal data;
- the right to object to processing - you can object to the processing of your personal data;
- the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
- the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
- the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
8.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
8.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
Cookies used by our service providers
11.4 We use Pipedrive to maintain relationships with customers, partners and vendors. This service uses one cookie from Cloudflare to distinguish between bots and humans as part of our contact form for anomaly detection. It does not correspond to a particular user or person and does not track users from site to site or session to session. More information on this can be found at Cloudflare Cookie Information. The relevant cookies are identifiable as of __cf_bm.
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version
12.2 If you block cookies, you will not be able to use all the features on our website.
13.1 We may update this policy from time to time by publishing a new version on our website.
13.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
14.1 This website is owned and operated by ChangeAbility AB under the registered trade name DFRNT.
14.2 We are registered in Sweden under registration number 559199-4552, and our registered office is at Åbrinksvägen 18, SE-22271 Lund, Sweden.
14.3 Our principal place of business is at Åbrinksvägen 18, SE-22271 Lund, Sweden.
14.4 You can contact us: