Privacy Policy

Last Updated: 12 September 2023

1. Introduction

Mavenoid AB (”Mavenoid”, “we”, “us” or “our”) respects your privacy in the processing of data about you. This Privacy Policy (“Privacy Policy”) provides details regarding the processing of personal data about (i) the authorized users or representatives of companies that are our; (ii) the visitors to our website (the “Site”); and (iii) those who interact or come in contact with us in any other way, e.g. through our customer service. The purpose of this Privacy Policy is to explain how we process your personal data and your rights under applicable data protection laws.

All personal data is collected by or on behalf of us as a data controller:

Mavenoid AB
c/o WEWORK
Malmskillnadsgatan 32
111 51 Stockholm, Sweden

You can find a printable version of this Privacy Policy here.

2. What categories of personal data, for what purposes and on what legal basis is personal data processed?

2.1 Employees/Representatives of Customers or Potential Customers:

If you are a representative of a customer or potential customer of Mavenoid, we will process your personal data in connection with the onboarding of the customer and to administer our relationship with and fulfill our agreement with the company that you are representing. We will collect the following personal data:

Title of the document

Category of Personal Data	Types of Personal Data Collected	Purposes for Collection	Legal Basis for Collection
Identifiers	Name (First, Last), Phone Number, Email Address, Employer or Company Information, Photograph, IP Address	To provide services and support	Our legitimate interest of being able to provide our services and support as per our agreement with the company that you represent
Identifiers	Name (First, Last), Phone Number, Email Address, Employer or Company Information, Photograph, IP Address	To manage our relationship with our customer	Our legitimate interest to manage our relationship with our customer in order to facilitate our business as per our agreement with the company that you represent
Identifiers	Name (First, Last), Phone Number, Email Address, Employer or Company Information, Photograph, IP Address	To administer the agreement with the company that you are representing	Our legitimate interest to be able to administer the agreement with our customer
Identifiers	Name (First, Last), Phone Number, Email Address, Employer or Company Information, Photograph, IP Address	To set-up user accounts and user roles	Our legitimate interest to set-up a user account and user roles for you as the representative of our customer, as per our agreement with the company that you represent
Identifiers	Name (First, Last), Phone Number, Email Address, Employer or Company Information, Photograph, IP Address	To send marketing to you, inter alia, through email. You can opt-out from further marketing by clicking on a link in each message sent through e-mail or SMS/MMS, or by contacting us via the contact information set out below.	Our legitimate interest to send marketing to you as a representative of our customer
Identifiers	Name (First, Last), Phone Number, Email Address, Employer or Company Information, Photograph, IP Address	To fulfil legal obligations (e.g. accounting requirements) and to report criminal activity	Legal obligation
Internet, computer, or other similar network activity	Device Identifiers, Cookies	Obtain statistics over the usage of our services and to test, develop and improve our services and our technical platforms	Our legitimate interest of testing, developing and improving our services and our technical platforms

2.2 Visitors to our Site:

Whenever you visit our Site, we collect information that you choose to submit to us, e.g. name, e-mail address and phone number. We may also collect personal data through cookies.

Title of the document

Category of Personal Data	Types of Personal Data Collected	Purposes for Collection	Legal Basis for Collection
Identifiers and Protected Characteristics	Name (First, Last), Address, Phone Number, Email Address, Age, Gender, Marital Status/Civil Status, Education Details, Business Contact Information, Username/Password (Login Credentials), Cookie IDs, IP Address.	To maintain, provide, test and improve our web pages	Our legitimate interest to maintain, provide, test and improve our web pages
Identifiers and Protected Characteristics	Name (First, Last), Address, Phone Number, Email Address, Age, Gender, Marital Status/Civil Status, Education Details, Business Contact Information, Username/Password (Login Credentials), Cookie IDs, IP Address.	To offer you support when facing a problem with our web pages	Our legitimate interest to provide you the support that you request from us when facing a problem with our web pages
Identifiers and Protected Characteristics	Name (First, Last), Address, Phone Number, Email Address, Age, Gender, Marital Status/Civil Status, Education Details, Business Contact Information, Username/Password (Login Credentials), Cookie IDs, IP Address.	To provide relevant and tailored offerings and advertisements to you	Consent
Identifiers and Protected Characteristics	Name (First, Last), Address, Phone Number, Email Address, Age, Gender, Marital Status/Civil Status, Education Details, Business Contact Information, Username/Password (Login Credentials), Cookie IDs, IP Address.	To send marketing to you, inter alia, through email. You can opt-out from further marketing by clicking on a link in each message sent through email, or by contacting us via the contact information set out below.	Consent
Internet, computer, or other similar network activity	Website Pages Visited, Length of Time Spent on Site, Technical Equipment Used, Timestamps, Metadata.	To offer you support when facing a problem with our web pages	Our legitimate interest to provide you the support that you request from us when facing a problem with our web pages
Internet, computer, or other similar network activity	Website Pages Visited, Length of Time Spent on Site, Technical Equipment Used, Timestamps, Metadata.	To create reports, review the effect of marketing campaigns and create anonymized statistics regarding the usage of our web pages	Our legitimate interest of reviewing our marketing campaigns and anonymize your data in order to create aggregated statistics
Internet, computer, or other similar network activity	Website Pages Visited, Length of Time Spent on Site, Technical Equipment Used, Timestamps, Metadata.	For management, development and testing of our IT systems in order to secure that our web pages uphold high quality as well as identifying and preventing security attacks such as viruses	Our legitimate interest to manage, develop and test our IT systems for quality and security reasons
Internet, computer, or other similar network activity	Website Pages Visited, Length of Time Spent on Site, Technical Equipment Used, Timestamps, Metadata.	To provide relevant and tailored offerings and advertisements to you	Consent
Internet, computer, or other similar network activity	Website Pages Visited, Length of Time Spent on Site, Technical Equipment Used, Timestamps, Metadata.	To maintain, provide, test and improve our web pages	Our legitimate interest to maintain, provide, test and improve our web pages
Inferences / Profiles Drawn from Other Personal Data	Profiling and Movement Patterns, Choices and Purchases Made, Number of Clicks, Location Data, Preferences, Custom Audience/Profile.	To create reports, review the effect of marketing campaigns and create anonymized statistics regarding the usage of our web pages	Our legitimate interest of reviewing our marketing campaigns and anonymize your data in order to create aggregated statistics
Inferences / Profiles Drawn from Other Personal Data	Profiling and Movement Patterns, Choices and Purchases Made, Number of Clicks, Location Data, Preferences, Custom Audience/Profile.	For management, development and testing of our IT systems in order to secure that our web pages uphold high quality as well as identifying and preventing security attacks such as viruses	Our legitimate interest to manage, develop and test our IT systems for quality and security reasons
Inferences / Profiles Drawn from Other Personal Data	Profiling and Movement Patterns, Choices and Purchases Made, Number of Clicks, Location Data, Preferences, Custom Audience/Profile.	To maintain, provide, test and improve our web pages	Our legitimate interest to maintain, provide, test and improve our web pages
Inferences / Profiles Drawn from Other Personal Data	Profiling and Movement Patterns, Choices and Purchases Made, Number of Clicks, Location Data, Preferences, Custom Audience/Profile.	To provide relevant and tailored offerings and advertisements to you	Consent

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2.3 Customer Service Inquiries and Requests:

When you contact us, e.g. with queries to our customer service or when you otherwise interact with us, we process the personal data that you choose to submit to us, including the following:

Title of the document

Category of Personal Data	Types of Personal Data Collected	Purposes for Collection	Legal Basis for Collection
Identifiers	Name (First, Last), Address, Phone Number, Email Address, Cookie ID, IP Address, Details Provided in Customer Service Requests.	To communicate with you and administer your request	Our legitimate interest of being able to communicate with you as per your request
Identifiers	Name (First, Last), Address, Phone Number, Email Address, Cookie ID, IP Address, Details Provided in Customer Service Requests.	To analyse conversations in order to improve our communication and for your and our security	Our legitimate interest to improve our communication for business and security reasons
Internet, computer, or other similar network activity	Usage Information (details related to the use of our services and technical platforms).	To obtain anonymized statistics regarding the usage of Mavenoid's communication channels	Our legitimate interest to anonymize your data for the purposes of statistical analysis
Internet, computer, or other similar network activity	Usage Information (details related to the use of our services and technical platforms).	To maintain, develop, test and improve Mavenoid's services and the technical platforms on which they are provided	Our legitimate interest of testing, developing and improving our services and our technical platforms

2.4 Cookies:

When you visit our Site, our servers automatically collect limited information about your computer, including via “cookies”. A “cookie” is a small text file that is recorded either temporarily or persistently on your hard drive that a website can use in order to recognize visitors and collect certain information to facilitate their ongoing access to and use of the website. This information may include the type of browser software you use, the operating system you are running, the IP address assigned to your computer or Internet connection, and the IP address of the website, if any, that referred you to our Site. We use this information to understand how visitors navigate through our Site, to enhance your experience while using our Site, and to make the materials we post as valuable to visitors as possible. For additional details on our use of Cookies, please see our Cookie Policy.

2.5 Legal Bases for Processing:

To the extent we rely on our legitimate interests as a legal basis for processing of your personal data, we have considered the balance between our own interests (among other things, the lawful and efficient operation of our services) and your interests and we believe that (a) you would reasonably expect us to carry out the kind of processing referenced above and (b) such processing will not cause you any harm and/or will not seriously impact your rights and freedoms with regard to data privacy. At times, we may also collect your personal data where we have your consent to do so or as otherwise necessary for the performance of a contract to which you are a party, and in order to take steps (at your request) to enter into such contract. You have the right to withdraw any consent given to us for the processing of your personal data. We may also collect your personal data as necessary for us to comply with our legal obligations, including to protect your vital interests or those of another.

3. Retention of Personal Data

We will only retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements, unless otherwise permitted by law.

4. Security of Personal Data

The security of all personal data provided to us is important and we take reasonable steps designed to protect your personal data. We maintain reasonable administrative, technical, and physical safeguards designed to protect personal data that we receive against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure or use.

5. Disclosures of Personal Data

We do not sell your personal data; however, Mavenoid engages external partners and suppliers to perform services on behalf of Mavenoid, e.g. to provide IT services and to assist in marketing, analysis or statistics. The performance of these services entail such parties, both within and outside of the EU/EEA, obtaining access to your personal data.

These parties include:

Title of the document

Entity Type	Location
Marketing and customer relationship management service providers	USA
Analytics service providers	USA
Hosting service providers	USA

Depending on what Mavenoid services are being used, data will be shared with different entities.

Companies which are processing personal data on behalf of Mavenoid are obliged to sign an agreement with Mavenoid in order to ensure a high level of protection of personal data. In relation to companies outside of the EU/EES, additional protective measures are undertaken, e.g. by signing an agreement which includes the European Commission's standard contractual clauses for data transfers, which can be found on the European Commission's website, and by implementing additional technical and organisational measures to protect your data.

Mavenoid may transfer personal data to a third party, such as the police or other authority, in the course of an investigation or otherwise when obliged thereto by law or governmental decision.

6. Your Rights and Choices

Depending upon where you reside, certain choices and rights may be available to you under applicable data protection laws. If you have questions about what rights may apply to you, please contact us.

6.1 For California Residents:

Do Not Track: Our websites and apps are not designed to respond to "do not track" requests from browsers.

“Shine the Light” and “Eraser” Laws: Residents of the State of California may request a list of all third parties to which we have disclosed certain information during the preceding year for those third parties’ direct marketing purposes.

California Consumer Privacy Act (CCPA)/California Privacy Rights Act (CPRA): The CCPA, as amended by the CPRA, provides California residents and/or their authorized agents with specific rights regarding the collection and storage of their personal information.

Your Right to Know: California residents have the right to request that we disclose the following information to you about our collection and use of your personal information over the past twelve (12) months. We may ask you to provide certain information to identify yourself so that we may compare it with our records in order to verify your request. Upon verification, we will disclose to you:

The categories of personal information we have collected about you.
The categories of sources for the personal information we have collected about you.
The specific pieces of personal information we have collected about you.
Our business or commercial purpose for collecting or selling your personal information.
The categories of third parties to whom we have sold or shared your personal information, if any, and the categories of personal information that we have shared with each third-party recipient.

Your Right to Opt-Out of Sale or Sharing of Personal Information: Under the CCPA, as amended by the CPRA, California residents have the right to opt-out of the sale of their personal information and/or the sharing of personal information with third parties for the purposes of cross-contextual behavioral advertising or profiling by submitting a request. Please note that we do not sell personal information, including the personal information of any individuals under the age of 16, nor do we share any personal information for the purposes of cross-contextual behavioral advertising.

Your Right to Limit Use of Sensitive Personal Information: California residents have the right to request that we limit our use of any sensitive personal information to those uses, which are necessary to perform the Services or for other business purposes under the CCPA, as amended by the CPRA.

Your Right to Delete: California residents have the right to request that we delete any of the personal information collected from you and retained by us, subject to certain exceptions. We may ask you to provide certain information to identify yourself so that we may compare it with our records in order to verify your request. Once your request is verified and we have determined that we are required to delete the requested personal information in accordance with the CCPA, as amended by the CPRA, we will delete, and direct our third-party service provides to delete, your personal information from their records. Your request to delete personal information that we have collected may be denied if we conclude it is necessary for us to retain such personal information under one or more of the exceptions listed in the CCPA, as amended by the CPRA.

Your Right to Correct: Under the CCPA, as amended by the CPRA, California residents have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes for which we are processing such personal information. We will use commercially reasonable efforts to correct such inaccurate personal information about you.

‍Non-Discrimination: You will not receive any discriminatory treatment by us for the exercise of your privacy rights conferred by the CCPA, as amended by the CPRA.

6.2 For Individuals Located in the European Economic Area (EEA), the United Kingdom (UK) or Switzerland:

You have a number of rights under applicable data protection laws in relation to your personal information. Under certain circumstances, you have the right to:

Have access to your personal information by submitting a request to us;
Have your personal information deleted;
Have your personal information corrected if it is wrong;
Have the processing of your personal information restricted;
Object to further processing of your personal information, including to object to marketing from us;
Make a data portability request;
Withdraw any consent you have provided to us;
Restrict any automatic processing of your personal information; and
Complain to the appropriate Supervisory Authority.

‍Verifying Your Request: Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. In the case of access and deletion, your request must be verifiable before we can fulfill such request. Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information or a person authorized to act on your behalf. We will only use the personal information that you have provided in a verifiable request in order to verify your request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority. Please note that we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive or manifestly unfounded.

7. Third-Party Links

We may provide links to other sites or resources provided by third parties. These links are provided for your convenience only. We have no control over the contents of those sites or resources, and accept no responsibility for them or for any loss or damage that may arise from your use of them. If you decide to access any of the third-party links on the Sites, you do so entirely at your own risk and subject to the terms and conditions of those sites.

8. Children

We do not knowingly collect personal information from children under the age of 13 through our Sites. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce our Privacy Policy by instructing their children never to provide us personal information. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us, and we will endeavor to delete that personal information from our databases

9. Changes to this Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. By accessing and using the Site after we notify you of such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

10. Contact information

If you have any questions regarding this Privacy policy or our privacy practices, please contact us at +1 425 329 4976

Mavenoid AB

Address:
c/o WEWORK
Malmskillnadsgatan 32
111 51 Stockholm, Sweden

Email: legal@mavenoid.com

If you are located in the United Kingdom or EU/EEA and believe we have not adequately resolved any issues, you may contact the Supervisory Authority concerned.

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