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Privacy Policy

Effective as of 1 September 2022

Fredacar AB’s, the company behind tod and in the sequel referred to as “tod”, access to your personal data according to this Privacy Policy is a prerequisite for your use of tod’s services through tod’s application(s) for smartphone(s) or through tod’s website ahead as well as a prerequisite for our provision of the Services and for us to provide you with further features in order to improved experience of our Services. This Privacy Policy refers to the Services or to the Service.

If you don’t approve of how tod processes your personal data according to this Privacy Policy or if you cannot accept our Terms of Services we ask you to please refrain from using the Services. To summarise, the policy is in place mainly to:

- Explain the way we collect, retain and by other means process personal data that you provide us with when you use our apps or website, when you register in the apps or ahead at the website, when you advertise a task, when you accept a teaching session or when you perform other activities within the Services;

- Ensure that you understand what information we collect in order to provide the Services to you, with your consent or after a balancing test of our legitimate interest and to explain how we use data that you share with us in order to allow us to give you a fantastic experience of our Services;

- Hold us accountable for protecting your rights and your privacy according to the data protection legal framework and to only process personal data for the purposes described in this privacy policy.

Data Controller

tod is the data controller of the company’s processing of personal data.

Legal basis and purposes of the processing

Two main categories of data are collected and processed by us. The first category covers data that we must have in order for you to be able to use the Services, i.e. data that is necessary for the performance of our contract with you. The second category covers data that enable us to provide you with further features with the aim of providing you with an optimised experience of the Services. Some data in this category is processed based on our legitimate interest after a balancing test and some data is processed based on your consent.

The first category includes:

Registration information, including your first and last name, date of birth, profile picture, contact information (address, e-mail address and telephone number) and country, that you provide when you sign up with tod and the anonymized customer ID that is generated when you register.

Non-specific location gathered from your device or you mobile device (for example by using GPS). Some information in the Services are location-specific, so we need to know what country you’re in.

The photo(s) you specifically choose when you advertise a task with tod.

Technical and sensor information, including the type of browser and device you use, data from the touch screen and information from your device’s accelerometer and gyroscope sensors. This enables us to provide an optimised experience of our Services. Technical data can also include URL-information, cookie-data, your IP-address, the kind of device you use to access or to connect to the Services, the unique device-ID, device attribute, type of network connection (for example WiFi, 3G, LTE) and provider, network and device performance, browser type, information on language, information enabling digital rights management, operating system and tod application version.

Payment data. When you advertise a task for the tod application enables your credit or debit card information (such as card type, expiration date and certain digits of your card number) and other financial data to be collected and retained by the payment processor Stripe or such other payment processor that we work with. When your personal data is collected and retained by a company that is considered as an independent controller of such processing, that company’s privacy policy applies to its processing. We are normally provided with some limited information from the payment processor, such as the unique token enabling you to make additional purchases by using the data already stored by the payment processor. If you have completed a teaching session and are eligible to receive payment from another user, the payment processor transferring the amount to your bank account may need to collect and to process further information such as, your bank and account number, date of birth or national identity, and your telephone number.

The purposes of the processing are to provide and administer the Services, to communicate with you for purposes related to the Services and to administrate your payment and to discover abuse or fraud.

The second category includes:

Your specific location: We will never gather or use your specific device location (for example by using GPS) without first getting your explicit consent. This information enables us to provide you with features, information, ads and other content depending on your current location and your location in relation to other tod users. If you choose to share your specific location but later change your mind, you will always have the possibility to withdraw your consent by changing your settings in your device’s operating system.

Special promotions and offers: Based on our legitimate interest to share your perception of our Services, to market our Services, and to add value to you as user, tod may offer you the opportunity to participate in promotions such as sweepstakes, contests, offers and surveys through the Services or through email/text messages (SMS). You will always have the possibility not to participate in such promotions by changing the settings in your device for notices or by contacting us at the address stated under the heading ”Company information” below.

Other information: Based on our legitimate interest after a balancing test tod may process information on your interactions with the Services, for example your interactions with yours and other users’ advertised tasks as well as requests related to them, other tod users, data related to your searches as well as the date of and time for your task, the user generated content that you advertise with the Services, including messages that you send or receives thought chat functions that may be available at tod ahead. We may also collect limited information related to you such as your transaction history. Our processing in these cases is based on our legitimate interest to develop and improve our Services and to understand how you use our Services.

The processing of information within this second category requires your prior consent or, that we after a balancing test can motivate our processing with a legitimate interest. If you have consented to our processing you can withdraw your consent at any time by changing your settings in the operating system of your device or by changing your account settings at your tod account, if applicable. Withdrawal of your consent does not affect the processing of your personal data that took place before your consent was withdrawn. Please contact us at the address under the heading “Company information” below if you have any questions.

We process information with the purpose to examine, develop and to improve our Services by personalising (for example by providing adopted and localised content, recommendations, features, notices and advertised tasks in or outside of the Services) and improving your experience of the Services, to communicate with you, to market and advertise, or to be able to conduct your participation in contests or events.

In addition hereto another category of personal data such as name, contact details (e.g. address, email and phone number) and correspondence may be processed to fulfil our legal obligations. It implies such management as is necessary to fulfil our legal obligations under legal, judicial or administrative decisions.

Cookies

tod use cookies and other technologies to collect data. You can find more information on our use of cookies in our separate Cookie policy.

Categories of recipients of the personal data

tod may need to share your personal data with service suppliers and business partners that we work with. Our payment processor Stripe handles payments for us. In order for you to be able to make and receive payment through the Services, Stripe or such other payment processors that we work with, may need to collect and retain basic information related to you through the Services.

We may also share your personal information with service suppliers in order for them to perform services on our behalf and to help provide the Services. For example we work with analytics providers to help us understand the use of the Services and with service providers to host data on our behalf. These recipients may only process your personal data for the purposes stated above and we take all reasonable legal, technical and organisational measures to ensure that your information is processed in a secure way and that it is subject to an adequate level of protection when transferring or when being shared with such suppliers.

We may share your personal information in a de-identified format with our partners that help us market the Services as well as with our advertising partners in order to send you promotional communication about tod or to show you more tailored content, including relevant advertising for products and services that may be of interest to you, and to understand how users interact with advertisements.

When you choose to advertise or share an advertised task or a teaching session or tod’s app on your Facebook account or another third party application, information may be shared with that third party application and with other persons through the third party application.

In addition, we may need to share your personal data should our business, or part of our business, be transferred to or merged with the acquiring legal entity.
tod may also need to share your personal data with entities that are independent data controllers, for example governmental authorities (the police, the tax authority and such other authorities), if we are legally obliged to do so or if there is a suspicion of crimes, with companies offering payment solutions (such as card redemption companies, banks and other payment service providers). When your personal data is shared with a company that is an independent controller the privacy policy of that controller applies to the processing.

tod may need to share your personal data with service suppliers and business partners that we work with. Our payment processor Stripe handles payments for us. In order for you to be able to make and receive payment through the Services, Stripe or such other payment processor that we work with, may need to collect and retain basic information related to you through the Services.

Retention and deletion of personal data

Some of your personal data will be deleted or anonymised in connection with the termination of your tod account. If you have not terminated your tod account, your personal data may be deleted manually or automatically after a period of 24 months of inactivity on your account. Information collected to administrate and handle communication from and with you is deleted or anonymized 12 months after the issue has been resolved. Information collected to prevent, investigate and limit abuse of the Service is deleted within 24 months of collection. Your personal data may be retained after the above time limits if there are legal and regulatory exceptions which may require documentation to be held for longer periods, for example according to accounting regulations.

Your personal data will be retained for special promotions during the period of the promotion.

Transfer to third countries

tod may need to transfer your personal data to third countries. Our payment processor, Stripe, has undertaken appropriate security measures by its Privacy-Shield certification and thereby ensures an adequate level of protection for your personal data, please see https://stripe.com/privacy-shield-policy.

Your personal data may also be transferred to such third countries should a service provider of tod in its turn contract a subcontractor for the performance of the Services. Our service providers will in such cases ensure that the transfer is made according to the data protection regulations and that a sufficient level of protection is ensured thereby.

Right of access to the personal data, rectification etc.

You are entitled to receive information on, and a copy of, your personal data that is being processed by tod. You are also entitled to request that tod rectifies your personal data that in your opinion is inaccurate or incomplete, or that tod blocks, restricts or erases your personal data.

You are entitled to obtain your personal data that is being processed by tod in a commonly used machine-readable format. If technically possible, which is decided by tod, you also have the right to have your personal data that is processed by tod transmitted to another controller, if you for example switch to another service similar to the Services.

In order to exercise your above mentioned rights or if you have questions regarding our processing you may contact us at the address or e-mail address provided under the heading ”Company information” below.

The right to lodge a complaint

After the (EU/UK) General Data Protection Regulations entered into force you may lodge a complaint to the supervisory authority in your Country, should you consider tod’s processing of your personal data to be in conflict with the data protection legislation. For further information please see e.g. Swedish Datainspektionen’s website www.datainspektionen.se or United Kingdom's Information Commissioner's Office’s website www.ico.org.uk.

Changes of the privacy policy

We may from time to time update and change our privacy policy. Updates of this policy are posted through the Services and the latest version of the Terms of Service and this policy is always available through the Services. Before an update becomes effective you will be informed through the Services or by e-mail. If the changes are of significant importance you will be informed in due time before they become effective and we will explain any effects hereof. Should you not wish to continue to use the Services under such updated policy you can at any time terminate the Services by contacting us at privacy@fredacar.com with the name that you used to create your account and the word “termination”, and we will help you to terminate your account.