OUR PRIVACY POLICY

GENERAL INFORMATION
1. 1. This document describes how Howwe Technologies AB (publ), company registration number 556655-7509, having its registered address at Skeppsbron 44 4TR, 111 30 Stockholm, Sweden (“Howwe Technologies“ “we” or “us”) collects, uses and processes personal data (“Privacy Policy”). This Privacy Policy is applicable when you use our website and/or the Howwe-platform (collectively the “Services”).
  2. All definitions in this Privacy Policy shall be interpreted in accordance with applicable data protection laws which refers to the General Data Protection Regulation (Regulation no. 2016/679) and the Directive on Privacy and Electronic Communications (Directive 2002/58/EC), as well as the national implementations and related national legislation.
PERSONAL DATA PROCESSED
1. 1. We will process the following personal data when you use the Services:
    1. Name;
    2. email address;
    3. telephone number; and
    4. technical data, which may include the URL you are accessing the Services from, your IP address, unique device ID, network and computer performance, browser type, language, and identifying information and operating system.
  2. We are unable to provide you with the Services unless you provide us with the personal data above.
PURPOSES OF PROCESSING
1. 1. We will process the personal data set out above for the following purposes:
    1. To administer your account, to enable and provide the Services and integration with third-party services to you, and to provide, personalize and improve your experience with the Services; and
    2. to send you alerts or messages by email or otherwise, including to provide you with marketing of our products and services.
LEGAL GROUND
1. 1. The processing of your personal data for the purposes of personalizing and improving your experience with the Services and to send you alerts or messages by email or otherwise, including to provide you with marketing of our products and services, is conducted on the basis of our legitimate interest.
  2. The processing of your personal data to administer your account, to enable and provide the Services and integration with third-party services to you, is conducted on the basis to fulfill our customer agreement with you.
DISCLOSURE OF PERSONAL DATA
1. 1. We will disclose your personal data to Intercom (support service provider) and Upsales (CRM service provider) to be able to provide the Services to you.
  2. Intercom is located in the U.S. In the event your personal data is transferred to the U.S. upon our usage of Intercom, we will apply the Standard Contractual Clauses issued by the European Commission (available at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en) in order to safeguard your personal data.
  3. When using the Services you may be directed to other websites and/or services where the personal data collected is not in our control. The privacy policy of the other website and/or services will govern the personal data obtained from you on that website and/or services.
RESPONDING TO LEGAL REQUESTS AND PREVENTING HARM

We may access, preserve and share your personal data to comply with applicable law, in response to a legal request (like a search warrant, court order or a subpoena or the like), or when necessary to detect, prevent and address fraud and other illegal activity, to protect ourselves, you and other users, including as part of investigations.

RETENTION

If we have a customer agreement with you, we will store your personal data under the term of such agreement and for three (3) continuous months following your termination thereof. If we do not have a customer agreement with you and you visit our website, we will store your personal data for fourteen (14) months and thereafter delete your personal data.

COOKIES
1. Our website, like most other websites, uses cookies to give you the best possible user experience. Cookies are small text files that are added to your computer or mobile phone when you use our website.

Our cookies allow us to:

Ensure that the website works as you expect.
Improve your download time and security when you use the website.
Gather anonymous statistics in order to improve the website’s performance and functionality, as well as evaluate and improve marketing efforts.

We do not use cookies to:

Save any personal information about you without your consent.
Gather any sensitive information.
Forward personal information to third parties.

If the settings in the browser you use to visit our website are set in such a way that they allow cookies, we interpret this as accepting cookies on our website.

Cookies can be deleted or completely turned off if desired. However, we cannot guarantee that the website and Howwe® will work satisfactorily then. Cookies can be turned off by adjusting your browser’s security settings. How this is done varies somewhat between different browsers and versions of browsers but is described if you search in your specific browser’s help page.

Further information on cookies is available on The Swedish Post and Telecom Authority’s website.

YOUR RIGHTS
1. 1. You have an absolute right to object to the processing of your personal data for direct marketing.
  2. You have the right to request access and further information concerning the processing of your personal data, or request that we correct, rectify, complete, erase or restrict the processing of your personal data. You have the right to obtain a copy of the personal data that we process relating to you free of charge once (1) every calendar year. For any additional copies requested by you, we may charge a reasonable fee based on administrative costs.
  3. If the processing is based on the legal grounds of consent or fulfillment of contract you have the right to data portability. Data portability means that you can receive the personal data that you have provided to us, in a structured, commonly used, and machine-readable format, and have the right to transfer such data to other data controllers.
CONTACT INFORMATION
1. 1. To exercise your rights, or if you have any questions regarding our processing of your personal data, please contact us at the following address: stina.robb@howwe.io. In your communication with us please state your full name and contact details. Note that you should sign the request to receive information on the processing of your personal data yourself.
  2. If you have any complaints regarding our processing of your personal data, you may file a complaint to the competent data protection authority. You can find out more about the local data protection authorities under the following link https://edpb.europa.eu/about-edpb/board/members_en.
CHANGE OF CONTROL

If there is a change of control in our business, we may transfer your personal data to the new owners for them to continue to provide the Services.

NOTICE OF CHANGES TO THE PRIVACY POLICY

If we make changes to this Privacy Policy, we will notify you on our webpage. If your consent is required due to the changes, we will provide you additional prominent notice as appropriate under the circumstances and, ask for your consent in accordance with applicable law.

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