Privacy Policy

Privacy Policy

Last updated: January 11, 2025

This Privacy Policy describes Our policies and procedures on the collection, use, and disclosure of Your information when You use Our services (“Service”) and informs You of Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

Words whose initial letters are capitalized have meanings defined under the conditions below. These definitions apply whether they appear in singular or in plural.

Definitions

For purposes of this Privacy Policy:

• Account: A unique account created for You to access our Service or parts of our Service.

• Business (CCPA/CPRA context): Refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected.

• Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to:

  • Rekommenda,

  • A part of Olof K AB (org. no. 5568927098, tax no. SE556892709801),

  • Ystadsgatan 47 e, 214 44 Malmö, Sweden.

  • Phone: +46 790967796

  • Email: support@rekommenda.com

• For purposes of the GDPR, the Company is the Data Controller.

• Consumer (CCPA/CPRA context): A natural person who is a California resident (including individuals in the state for other than a temporary or transitory purpose, and those domiciled in the state but temporarily outside the state).

• Cookies: Small files placed on Your computer or other device by a website, containing details of Your browsing history among many uses.

• Country: Sweden (although this Privacy Policy is also intended to meet requirements in other jurisdictions, including the USA and Canada).

• Data Controller (GDPR context): The legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

• Device: Any device that can access the Service, such as a computer, cellphone, or digital tablet.

• Do Not Track (DNT): A concept promoted by US regulatory authorities (particularly the FTC), encouraging the Internet industry to develop a mechanism for allowing internet users to control the tracking of their online activities across websites.

• Facebook Fan Page: A public profile (example name used: “Rekommenda Official Page”) created by the Company on the Facebook social network.

• Personal Data: Any information that relates to an identified or identifiable individual.

  • Under GDPR: Any information relating to You, such as a name, identification number, location data, online identifier, or factors specific to Your identity.

  • Under CCPA/CPRA: Any information that identifies, relates to, or could reasonably be linked, directly or indirectly, with You.

• Sale (CCPA/CPRA context): Selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a Consumer’s personal information for monetary or other valuable consideration.

• Service: Refers to the website(s) or services offered by Rekommenda.

• Service Provider: Any natural or legal person who processes data on behalf of the Company. Under GDPR, they are considered Data Processors.

• Third-party Social Media Service: Any website or social network website that allows a user to log in or create an account to use the Service.

• Usage Data: Data collected automatically, generated by the use of the Service or from the Service infrastructure itself (e.g., page visit duration).

• Website: Refers to Rekommenda’s main website, accessible from https://www.rekommenda.com (example domain for illustration).

• You: The individual accessing or using the Service, or the company or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR, You can be referred to as the Data Subject or User.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide certain personally identifiable information that can be used to contact or identify You, which may include:

• Email address

• First and last name

• Phone number

• Address (including State/Province, ZIP/Postal code, City)

• Usage Data

Usage Data

Usage Data is collected automatically when using the Service (including IP address, browser type, pages visited, time/date of visit, etc.).

Information from Third-Party Social Media Services

You may be able to create an account and log in through:

• Google

• Facebook

• Twitter

If You decide to register through or grant access to a Third-Party Social Media Service, We may collect Personal Data that’s already associated with that account (e.g., name, email address, contact list, activities).

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies (beacons, tags, scripts) to track activity on Our Service and store information. This includes:

• Cookies or Browser Cookies

• Flash Cookies

• Web Beacons

Cookies can be “Persistent” or “Session.” We use both for various purposes, including:

• Necessary / Essential Cookies (Session)

• Cookies Policy / Notice Acceptance Cookies (Persistent)

• Functionality Cookies (Persistent)

• Tracking and Performance Cookies (Persistent)

For more details, see Our Cookies Policy or relevant sections in this Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for:

• Providing and maintaining the Service (including monitoring usage).

• Managing Your Account as a registered user.

• Performance of a contract (for purchase of products, items, or services).

• Contacting You (via email, phone, SMS, push notifications).

• Providing You with news, special offers, and general information unless You opt out.

• Managing Your requests sent to Us.

• Delivering targeted advertising to You.

• Business transfers (e.g., mergers, reorganizations).

• Other purposes such as data analysis, usage trends, and service improvement.

We may share Your personal information with:

• Service Providers (analytics, advertising, payment processing, etc.).

• Affiliates (parent company, subsidiaries).

• Business partners (for product/service/promotional offers).

• Other users in public areas (when You share personal info publicly).

• With Your consent for any other purpose.

Retention of Your Personal Data

We retain Your Personal Data only as long as necessary for the purposes set out in this Privacy Policy and for compliance with legal obligations. Usage Data is retained for a shorter period, except when needed for security or improving Our Service, or as legally required.

Transfer of Your Personal Data

Your information may be processed at the Company’s operating offices and elsewhere. By submitting Your information, You agree to such transfer. We ensure that no transfer takes place to an organization or country unless there are adequate controls in place, including data security.

Disclosure of Your Personal Data

Business Transactions

In a merger, acquisition, or asset sale, Your Personal Data may be transferred. We will notify You accordingly.

Law Enforcement

We may disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities.

Other Legal Requirements

We may disclose Your Personal Data in good faith when necessary to:

• Comply with a legal obligation

• Protect and defend the rights or property of the Company

• Prevent or investigate wrongdoing

• Protect the personal safety of users or the public

• Protect against legal liability

Security of Your Personal Data

While We strive to use commercially acceptable means to protect Your Personal Data, no method of transmission or storage is 100% secure. We cannot guarantee absolute security.

Detailed Information on the Processing of Your Personal Data

Service Providers may access Your Personal Data to perform tasks on Our behalf. They are obligated to not disclose or use it for other purposes.

Analytics

We may use third-party analytics providers like Google Analytics, ClickMagic, Improvely, LinkTrackr, trck.me, etc. for usage monitoring and analysis.

Email Marketing

We may use Your Personal Data for newsletters or promotional materials. You can opt out at any time. We often use providers like Mailchimp, AWeber, or GetResponse.

Payments

For paid products/services, We use third-party payment processors (e.g., Stripe, PayPal, Klarna) which adhere to PCI-DSS standards. We do not store or collect Your payment card details.

Behavioral Remarketing

We use remarketing services (e.g., Google Ads, Twitter, Facebook, Pinterest, AdRoll) to advertise on third-party websites. These third parties use cookies to inform, optimize, and serve ads based on Your past visits to Our Service.

Usage, Performance, and Miscellaneous

We may use third-party tools for improvements, such as Invisible reCAPTCHA (by Google) or Mouseflow.

GDPR Privacy

Legal Basis for Processing

We may process Personal Data when:

• Consent: You have given consent for specific purposes.

• Performance of a contract: Provision is necessary for an agreement with You.

• Legal obligations: Compliance with a legal obligation.

• Vital interests: Protection of vital interests.

• Public interests: Task carried out in the public interest.

• Legitimate interests: For Our legitimate interests.

Your Rights under GDPR

You have the right to:

• Request access to or erasure of Your Personal Data

• Rectify inaccurate data

• Object to processing

• Request transfer of Your data

• Withdraw consent

Contact Us to exercise these rights. We may request You verify Your identity. You can also complain to a Data Protection Authority within the EEA.

Facebook Fan Page

Where We operate an official Facebook Fan Page, We may be Joint Controllers with Facebook. Facebook may place a cookie on users’ devices for Insights. See Facebook’s Privacy Policy for details.

CCPA/CPRA Privacy

Categories of Personal Information Collected

We collect or may have collected the following categories within the last 12 months (as defined by California law):

• A. Identifiers (e.g., real name, email, IP address)

• B. Personal information categories listed in Cal. Civ. Code § 1798.80(e)

• D. Commercial information (records of products/services purchased)

• F. Internet or other network activity

We do not knowingly collect information under categories such as C (Protected classification), E (Biometric), G (Geolocation), etc., unless specifically needed.

Sources of Personal Information

• Directly from You (forms, preferences)

• Indirectly from You (observing activity)

• Automatically (cookies)

• From Service Providers

Use of Personal Information

Examples include operating and providing Our Service, fulfilling requests, legal compliance, and detecting security incidents.

Disclosure of Personal Information

In the last 12 months, We have disclosed (for business/commercial purposes) categories A, B, D, and F. We contractually require recipients to keep it confidential and use it only for contractual purposes.

Sale of Personal Information

We may sell (as defined by CCPA/CPRA) categories A, B, D, and F, typically in the context of behavioral advertising. We do not knowingly sell personal information of minors under 16 years of age without consent.

Your Rights under CCPA/CPRA

• Right to Notice

• Right to Know/Request (categories of Personal Data collected, sources, business purposes)

• Right to Opt-Out (if applicable)

• Right to Delete (with certain exceptions)

• Right not to be Discriminated Against for exercising these rights

Contact Us to exercise any of these rights. Only You or an authorized agent can make a verifiable request.

Do Not Sell My Personal Information

You can opt out of the sale of Your Personal Data by contacting Us or using provided links (NAI, EDAA, DAA). Note that the opt-out is browser-specific.

“Do Not Track” Policy

Our Service does not respond to Do Not Track signals. Please adjust your browser settings accordingly if you wish to enable DNT.

Children’s Privacy

We do not knowingly collect personal information from anyone under 13. If You become aware of such collection, contact Us to remove the data. If parental consent is legally required in Your country, We may require it before processing children’s data.

Your California Privacy Rights (Shine the Light Law)

Under Cal. Civ. Code § 1798, California residents with an established relationship with Us can request information on personal data shared with third parties for direct marketing. Contact Us for details.

California Privacy Rights for Minor Users

California residents under 18 who are registered users can request and obtain removal of posted content. Contact Us for such requests. Note that removal may not be complete or comprehensive.

Links to Other Websites

We may link to external sites. We have no control over their privacy practices. Please review the Privacy Policy of any site You visit.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated version on this page and update the “Last updated” date. We may also notify You via email or prominent notice before changes take effect.

Contact Us

If You have questions about this Privacy Policy, You can contact us:

• By email: support@rekommenda.com

• By mail: Rekommenda, Ystadsgatan 47 e, 214 44 Malmö, Sweden

• By phone: +46 790967796