INNOVATION360 GROUP AB – PRIVACY POLICY Transformation360©
Introduction
Innovation 360 Group AB, 556990-0904, (“Transformation360” or “We”, “Our” or “Us”) cares deeply about privacy and welcomes the European Union’s General Data Protection Regulation (”GDPR”). We are obliged to collect and process personal data in accordance with the GDPR, regardless whether our customers and users are based within the EU or not. We take our obligations seriously and always collects personal data responsibly and with Your privacy in mind.
We provide an idea management tool consisting of a software application (“App”), web-based content and a user management platform (“Platform”) which can be used by companies and organizations for idea management.
This privacy policy explains how We process information that can be used to directly or indirectly identify an individual (”Personal Data”) collected through use of the App or the Platform.
Personal data is defined in Article 4 (1) of the GDPR:
‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
In this privacy policy We define the term ”Account Owner” as the company, entity or person who registers an account through the App or through Ideation 360’s website http://www.transformation360.com/ (”Website”), the term ”Ideator” for any individual who uses and/or administrates the Platform and enters ideas, comments, or other information in the Platform on behalf of an Account Owner, and the term ”Visitor” for any individual that visits Our Website. Account Owner, Ideator and Visitor may individually or jointly be referred to as “You”.
Collection and Use
Visitor data
Collection
We only collect information about a Visitor which is voluntarily submitted by the Visitor, and certain limited information through the use of cookies. For information regarding Our use of cookies, go to https://innovation360.com/cookie-policy/.
Information that may be voluntarily submitted by a Visitor when visiting the Website is limited to the Visitor’s e-mail address.
Purpose of and legal basis for processing Visitor Personal Data
We use the Visitor Personal Data to:
– send newsletters
Legal basis: Visitor’s explicitly given consent
Account Owner data
Collection
In order to register an account on Our Platform an Account Owner will need to provide mandatory information such as:
– name
– e-mail
– company name, and
– credit card information (if a subscription account)
and optional information such as;
– work title
– place of residence
– photo and
– personal description
Purpose of and legal basis for processing Account Owner Personal Data
Account Owner Data is used to:
– identify the Account Owner, provide Account Owner with support, services and updates regarding Account Owner account (sending e-mails and communicating with the Account Owner in other ways), invoicing and to verify compliance with the contractual obligations of Us and Account Owner
Legal basis: contractual necessity, processing is needed in order to enter and perform Ours and Account Owner’s agreement and contractual obligations towards each other
– market Our services and send newsletters
Legal basis: Our legitimate interest to market Our services to our customers
Ideator Personal Data
Ideator’s account on the Platform is owned by an Account Owner. It is the Account Owner’s responsibility to ensure that the collection and processing of Ideator Personal Data on the Platform is done in accordance with applicable law.
Ideator Personal Data may consist of data submitted by Ideator, Account Owner or Us on behalf of Account Owner. Personal Data may consist of name, e-mail address, submitted ideas etc.
An Account Owner will be the “controller”, as defined in the GDPR. The purpose of processing Ideator’s Personal Data will consequently be defined by the Account Owner and not by Us.
If Ideator wish to inquire about Ideator’s Personal Data that may have been collected through the use of the Platform and App, We recommend that Ideator contact the Account Owner owning Ideator’s account.
Our interaction with an Ideator will mainly consist of that We, on behalf of Account Owner, will send Ideator auto generated follow up e-mails with information and updates regarding the Our services and the ideas Ideator have submitted through the Platform or App.
As We are a ”processor”, as defined in the GDPR, of Ideator Personal Data, except for what is stated below (Marketing and newsletter), We do not control Ideator Personal Data, We processes it on behalf of Account Owner.
Marketing and newsletter
We collect Ideators’ e-mail addresses and We use them to send Ideators newsletters and market Our services by e-mail to Ideators.
Legal basis: Our legitimate interest to market Our services to Our users of ideation360
Sharing and Transfer of Personal Data
We may only disclose Personal Data insofar as reasonably necessary for the purposes set out above in this Privacy Policy and in order to provide You with Our services, to:
– Our employees, agents, suppliers or subcontractors and to any member of its group of companies (this means Our subsidiaries, ultimate holding company and all its subsidiaries)
– third-party hosting suppliers (servers placed within the EU)
We do NOT sell Personal Data to any third party without prior consent.
How long do We keep Personal Data
Personal Data for which We are controller
We will not retain Personal Data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.
Contractual obligations
Personal Data needed in order to fulfill our contractual obligations towards an Account Owner will be kept for the duration of a valid agreement between Us and Account Owner and for a period of ten (10) years thereafter.
Marketing and newsletter
We will hold your data for marketing purposes for a period of 6 years.
You will have the opportunity to opt out or update or delete data at any point should you need to do so.
Personal Data for which We are processor
For Ideator Personal Data, Account Owners have control of the purpose for collecting data, and the duration for which the Personal Data may be kept. For Ideator Personal Data, Account Owners with an active account will therefore have the responsibility to delete data when required. When an Account Owner’s account is terminated or expired, all Personal Data collected through the Platform or App will be deleted or anonymized, as required by applicable law.
Rectification, access and erasure of Personal Data
Personal Data for which We are controller
You may request access to and a copy of the personal data that we process in relation to you if you would like to know and verify the information we have on You.
You have the right to correct inaccurate and/or incomplete information about Yourself.
You have the right to be forgotten, which means you may request the deletion of your Personal Data insofar as this Personal Data is no longer necessary for the purpose it was collected, or We have a legitimate interest to hold it.
You also have a right to withdraw any consent you have given, as well as ask us to cease marketing towards You.
Personal Data for which We are processor
For Ideator Personal Data, Account Owners have control of the Personal Data and sets the routines regarding rectification, access and erasure of Your Personal Data.
Data Portability
It is also Your right to receive the personal data which You have given to us, in a structured, commonly used and machine-readable format and You have the right to transmit such data to another controller.
Cookies and similar technologies
ideation360 use cookies in accordance with Our cookie policy, read more here https://innovation360.com/cookie-policy/
Changes to this Privacy Policy
Please note that this Privacy Policy may change from time to time. If We change this Privacy Policy in ways that affect how We use Your personal information, We will advise You of the choices You may have as a result of those changes. We will also inform You of that this Policy Privacy has changed.
Our Data Protection Officer
Our ”Data Protection Officer” (the person responsible for matters relating to privacy and data protection) may be reached at:
Innovation 360 Group AB, 556990-0904
c/o iOFFICE
Olof palmes gata 11
111 37 Stockholm
dataprotectionofficer@innovation360.se
If You have any complaints regarding this Privacy Policy or in the way We handle Your personal data You may always contact The Swedish Data Security Authority (Sw. Datainspektionen).