Privacy Policy & Terms of Service

English Privacy Policy & Terms of Service

Overview of our Privacy Notice

1 Summary

Your privacy is very important for us at Coly Technologies AB ("Coly"). Our aim is for you to feel safe with our processing of your personal data.

Coly is the Data Processor responsible for the processing of your personal data as described in this privacy notice (“Privacy Notice”). By way of this Privacy Notice, we want to inform you about how we ensure that your personal data is processed in accordance with applicable laws. This Privacy Notice describes, amongst other things, the information what personal data the Data Controller collects, how the personal data is processed and for what purposes the personal data is collected. This Privacy Notice also describes your rights and how you can enforce them.

To make it as easy as possible for you to understand how and why your personal data is collected, we have summarized the most important information about our processing on this page. More information on our processing can be found here at the end of the page.

If you have any questions about this Privacy Notice, about our processing of your personal information or if you wish to exercise your rights, you are welcome to contact the Data Controller direct or via us using the contact details you find below.

2 Material scope

This Privacy Notice applies to Coly’s processing on instruction of the Data Controller of personal data in relation to you. This is done through Coly’s services.

3 Collected personal data

The personal data is all information which directly or indirectly can be referred to you as an individual. Information regarding you which we may process is for example contact details, date of birth, gender, results from Coly’ personality and values tests, survey data and service usage data.

The personal data that is collected and processed about you is mainly the information that you provide us with when you use our services, i.e., perform our different tests and assessments on i.e. your personality and values, when your account has been created by the Data Controller. Your personal data about you come from the Data Controller (company/landlord) you are applying to, such as information about the shared living space you are applying for or at whose shared living space you currently are staying at.

5 Our use of your personal data come to us by the Data Controller

At Coly, we process your personal data by the instruction from the Data Controller, your first contact. To be able to conduct the Data Controller’s business in the best and most appropriate way. We process your personal data for you and the Data Controller for the following purposes:

  • Assess the personal data to produce individual reports on personality and values in relation to a shared living context. 
  • Assess the personal data to match your profile with other individuals’ profiles for a shared living context with the company/landlord you are applying for/evaluating or at whose shared living space you currently are staying at.
  • Provide you with individual reports on personality and values in relation to a shared living context.
  • Evaluate the efficiency of the application process and procedures within the Data Controller (company/landlord) you are applying for/evaluating or at whose shared living space you currently are staying at
  • Maintain the integrity, increase accuracy and safety of our assessment processes.
  • To provide you with user-support through your Data Controller.
  • Anonymize your personal data for product development to analyse end-user behaviour.
  • Perform data analysis for product development and product testing.
  • Enable internal research and create statistical models of estimation of end-user experience in different shared living contexts.
  • Enable external research, for example through universities or other organizations.
  • Fulfilment and compliance with applicable laws and regulations.
  • Evaluation for a merger or acquisition.
  • Protect the data in accordance with legal rights.

We do not use your personal data for any other incompatible purpose.

6 Our sharing of your personal data

We will share your personal data with the Data Controller (company/landlord) you are applying to/evaluating or at whose shared living space you currently are staying at or with your current Data Controller (company/landlord), whichever is applicable.

We are using the following Data Sub-Processors:

• Amazon Web Services, a company from the US, storing data in the EU, using European Standard Contractual Clauses.

• Typeform, a company from Spain, storing data in the EU, using European Standard Contractual Clauses for processes to the UK and other third countries.

For updates of Data Sub-Processors, see this Privacy Notice.

We do not sell your personal data to any third party.

7 For how long will we process your personal data?

We keep your data for up to two (2) years. We only keep your personal data for as long time as it is necessary to achieve the purposes for which they were collected in accordance with this Privacy Notice. When your personal data no longer are needed, your personal data will be removed from our systems, databases, and backups.

We will anonymize your personal data for the purpose to improve the service.

We may also be required to keep your personal data for other reasons, such as to comply with legal obligations or to safeguard your legal interests, or for any other important public interest.

8 Your rights

You have the right to receive information regarding which personal data is processed about you and what is done with that data. You also have the right to a certain degree of control over your personal data. Therefore, in certain cases you have the right to receive your personal data, to have inaccurate data rectified or erased and request restriction of our processing. Furthermore, under certain conditions you have the right to object to the processing of your personal data. If you consider that your personal data is processed in an unlawful manner, you are always entitled to lodge a complaint with the Data Controller or the supervisory authority.

9 Contact details

If you have any questions regarding this Privacy Notice, our processing of your personal data, or if you want to exercise your rights, you can contact the Data Controller, or us, in any of the following ways and we will direct you to the right Data Controller:

Postal and visiting address: Fleminggatan 18, 112 26. Stockholm, Sweden

Email: privacy@coly.io

Webpage: www.coly.io/

PRIVACY NOTICE

1. About Coly

This privacy notice (“Privacy Notice”) applies to Coly’s processing of personal data in relation to the Data Controller you first were in contact with, as a user of Coly’s processing services, whose personal information we obtain in connection with our services.

It describes how Coly Technologies AB, reg. no. 559289-0890, ("Coly", “Coly Technologies”), as a Data Processor processes, discloses, stores, and otherwise processes your personal data.

We respect your right to privacy, and we are committed to comply with applicable data protection rules and to safeguard your rights. We want to make sure that you are aware of what types of information we process about you, how this information is used and how we protect it.

This Privacy Notice describes, amongst other things, what information is collected about you, how your personal data is processed and for what purposes data is collected and how it is used. This Privacy Notice also describes your rights and how you can enforce them.

2 Data Processor

Coly is the Data Processor for the processing of your personal data and is responsible under the Data Controller for ensuring that the processing follows applicable laws. You find our contact details at the end of this Privacy Notice.

3 What personal information do we use?

3.1 Information that is provided to us

You may provide your personal data when the Data Controller is using any of our Products of Services.

Depending on which Services are used, this information may include:

Contact identification information: name, e-mail address.

User identifier: UserID, session ID.

Information about personality and values: Personality, values, test results, survey results, etc.

Demographic information: native language, age, gender, country of residence.

3.2 Information that is provided to us

Depending on which Services you use, the following information about you, either the Data Controller or such as the company/landlord you are applying/evaluating or at whose shared living space you currently are staying at:

Contact identification information: name, e-mail address.

User identifier: UserID, session ID,

Information about personality and values: Personality, values, test results, survey results, etc.

Information about applications/landlords: information related to the application such as application id, process id, organization ID, etc.

IP address: IP address

Device information: information related to your device and your usage. This data may include technical data and related information about the device being used for our services, including device ID, unique push ID, browser type, operating system, application software and peripherals, usage patterns and page visits.

4 How is Your Information used, for what purposes and with what legal basis?

4.1 Our use of your personal data come to us by the Data Controller

At Coly, we process your personal data by the instruction from the Data Controller, your first contact. To be able to conduct the Data Controllers business in the best and most appropriate way. We process your personal data for you and the Data Controller for the following purposes:

  • Assess the personal data to produce individual reports on personality and values in relation to a shared living context. 
  • Assess the personal data to match you with other individuals for a shared living context with the company/landlord you are applying for/evaluating or at whose shared living space you currently are staying at.
  • Provide you with individual reports on personality and values in relation to a shared living context.
  • Evaluate the efficiency of the application process and procedures within the Data Controller (company/landlord) you are applying for/evaluating or at whose shared living space you currently are staying at.
  • Maintain the integrity, increase accuracy and safety of our assessment processes.
  • To provide you with user-support through your Data Controller.
  • Anonymize your personal data for product development to analyse end-user behaviour.
  • Perform data analysis for product development and product testing.
  • Enable internal research and create statistical models of estimation of end-user experience in different shared living contexts.
  • Enable external research, for example through universities or other organizations.
  • Fulfilment and compliance with applicable laws and regulations.
  • Evaluation for a merger or acquisition.
  • Protect the data in accordance with legal rights.

We do not use your personal data for any other incompatible purpose.

In the table below, you are provided with more information about e.g., why we process your personal data, which personal data we keep fulfilling the purposes of the processing and for how long we keep your personal data.

In the tables above, you will find more information about for how long we process your personal data for different purposes.

Upon termination of your account, your data will be deleted. For technical reasons, your data might however be stored until 30 days after the termination.

At the latest, we keep your personal information for two (2) years after your last activity with one of our Products or Services.

We may be required to keep your personal data for other reasons, such as to comply with legal obligations or to safeguard our legal interests, or for any other important public interest.

6 With Whom Do We Share Your Personal Data?

Your personal data will be processed by carefully selected service providers, e.g. providers of IT-services, or companies we cooperate with.

We may also in certain cases be required to share your personal data with public authorities or other third parties in connection with audits, court proceedings or similar reasons.

We are using the following Data Sub-Processors:

• Amazon Web Services, a company from the US, storing data in the EU, using European Standard Contractual Clauses.

• Typeform, a company from Spain, storing data in the EU, using European Standard Contractual Clauses for processes to the UK and other third countries.

For updates of Data Sub-Processors, see this Privacy Notice.

We will not sell your personal data to any third party.

7 Where do we process your personal information?

Coly processes your personal data primarily with companies within the EU/EEA. In some cases, we may transfer your personal data to companies outside of the EU/EEA. If personal data is transferred to any such country, we will ensure that your personal data is protected and that the transfer is carried out in accordance with applicable law.

When carrying out any transfer to a country that lacks an adequacy decision by the European Commission, we will use the standard contractual clauses issued by the European Commission as legal basis for the transfer. You find these here: https://ec.europa.eu/info/law/law-topic/data-protection_en

8 Your Rights

You may at any time contact us to exercise your rights, and our contact details can be found at the last page of this Privacy Notice. We will then redirect you to the right Data Controller.

You have upon written request the right of access to the data relating to you. You also have the right to get data rectified, and under some circumstances the right to have your data deleted before the retention period expires. Contact your Data Controller for further information.

The Data Controller is responsible for responding to your request to exercise your rights within one month from the Data Controller’s receipt of your request. The Data Controller is entitled to extend this period by two further months when necessary, considering the complexity of your request or if the Data Controller have received many requests. The Data Controller will inform you of any such extension within one month of receipt of your request, together with the reasons for the delay and information about your right to lodge a complaint with a supervisory authority.

At Coly, we will take all reasonable and possible actions to notify any recipients of your personal data as regarding any rectification, erasure or restrictions carried out by us. We will forward your requests to the Data Controller. At your request, we will also inform you of which third parties we have shared your personal data with.

All information and communication, and all actions we carry out, is at no cost for you. If the action you request is manifestly unfounded or excessive, we are entitled to charge you an administrative fee to provide you with the requested information or carry out the requested action or refuse to meet your request.

8.1 Access to your personal data

You have the right to request information on the Data Controller’s use of your personal data. You also have the right to request a copy of the personal data being processed by the Data Controller, at no cost. However, you may be charged a reasonable administrative fee to provide you with additional copies of such information. If you make your access request by electronic means such as email, we will provide you with the information in a commonly used electronic format.

8.2 Right to data portability

You have the right to receive the personal data that we process which you have provided to the Data Controller, in a structured, commonly used, and machine-readable format and the Data Controller has the right to transmit those data to another controller if:

The Data Controller bases our processing of that data on your consent, or we base it on the fulfilment of a contract with you, and the processing is carried out by automated means. If technically feasible, you will also have the right to have that personal data transmitted directly from the Data Controller to another Data Controller.

8.3 Human intervention

You have the right to obtain human intervention about what happens with the Data Controller’s administrative decision, to express your point of view, and to obtain an explanation of the decision reached after such assessment and to challenge the decision.

8.4 Rectification of your personal data.

We will at your request, or at the Data Controller’s own initiative, rectify, anonymize, erase, or complement personal data that you or the Data Controller discover is inaccurate, incomplete, or misleading. You also have the right to complete the personal data with additional data if relevant information is missing.

8.5 Erasure of your personal data.

You have the right to request that the Data Controller erases your personal data, and the Data Controller must erase it if:

the personal data is no longer necessary for the purposes for which it was collected, the Data Controller uses your personal data with your consent, you withdraw your consent and there is no other legal ground for the processing, you object to the processing of your personal data based on the Data Controller’s legitimate interest and there is no overriding legitimate ground for the processing, the personal data has not been lawfully processed, or the Data Controller is required to erase the personal data due to a legal obligation. However, there might be requirements under an applicable law, or other compelling reasons, that prevents the Data Controller from immediately erasing your personal data. In such case, the Data Controller will stop using your personal data for any other reasons than to comply with the applicable law, or the relevant compelling reason.

8.6 Right to restrict processing:

This means that the Data Controller can temporarily restrict the processing of your personal data. You have the right to request restriction of the processing when:

you have requested rectification of your personal data, during the period of time the Data Controller is verifying the accuracy of the data, the processing is unlawful, but you do not want the personal data to be erased, when the Data Controller no longer needs the personal data for the purposes for which it was collected, but you require the Data Controller to retain the information for the establishment, exercise, or defence of a legal claim, or you have objected to a processing activity and the basis of the lawfulness, during the time it is determined whether the basis of lawfulness override your privacy rights.

8.7 Your right to object to the processing

You have the right to object to the processing of your personal data that the Data Controller bases the process of the lawfulness. If you object to such processing, the Data Controller will only continue with the processing if the compelling lawfulness for the processing that outweighs your interests, rights, or freedoms, or if continued processing is necessary for the establishment, exercise, or defence of a legal claim. You can always contact the Data Controller for more information on the balance test that has been made.

8.8 Your right to withdraw your consent

When processing your personal data based on your consent, you always have the right to withdraw such consent at any time by contacting the Data Controller, or contacting us (our contact details are at the end of this Privacy Notice).

8.9 Your right to lodge a complaint with the supervisory authority

You have the right to lodge a complaint regarding the processing of your personal data with the supervisory authority in the country you live or work in.

In Sweden, the Supervisory Authority is Integritetsskyddsmyndigheten, which also is our lead supervisory authority, and you can find more information at their website: https://www.imy.se/.

9 How we protect your personal information

We protect your personal data against unauthorised access, alteration, and erasure.

You shall always feel safe when providing us with your personal data. Therefore, Coly has implemented appropriate security measures to protect your personal data against unauthorised access, alteration, and erasure.

In the case of a security breach that may significantly affect you or your personal data, e.g. when there is a risk of fraud or identity theft, we will contact and inform the Data Controller about what we will do and what can be done do to reduce the risk.

10 Cookie Notice

Coly uses cookies and similar technologies, e.g. pixels. We use the data collected through cookies to be able to analyse the usage statistics on our website, to improve our services and to be able to provide our services. In our cookie notice, we provide you with more detailed information on how we use cookies. You will find the notice here.

11 How do we update or amend this Privacy Notice?

This Privacy Notice may be updated periodically to reflect changes in our collection and use of your personal data. You will be informed of any significant changes with reasonable prior notice (e.g. by email, or in the platform), but we also recommend that you review this Privacy Notice from time to time to ensure you are aware of any amendments.

If you do not accept these changes, you have the right to object to the processing before the changed Privacy Notice enters in effect.

The latest version will always be available on our website (https://coly.io/).

12 Contact Information

Do not hesitate to contact the Data Controller, or us at Coly, if you have any questions regarding this Privacy Notice, our processing of your personal data, or if you want to exercise your rights.

Coly Technologies AB, reg.no. 559289-0890

Postal and visiting address: Fleminggatan 18, 112 26 Stockholm, Sweden

Email: privacy@coly.io

Web page: www.coly.io

Access specific Privacy Policy applicable for older Coly products (Pipeline, Brain)

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