Privacy Policy

Minna Technologies is committed to protecting and respecting your privacy. This privacy policy describes how we collect and use your personal data for this Website and services related to this Website (the “Service”). This privacy policy also describes the choices available to you regarding our use of your personal data. This Policy does not describe how we collect and process your information for other services provided by our organization.

Please read this privacy policy before using the Service. By using the Service, you acknowledge having read and understood this privacy policy and our processing of your personal data. Please note that the Service is not directed to individuals under the age of 18, and we request that they do not provide us with personal data through the Service.

Privacy Policy for Websites

The generic use and disclosure of personal information that is collected from the individuals online, through websites and web based products.

Minna Technologies Privacy Policy

Minna Technologies is committed to protecting and respecting your privacy. This privacy policy describes how we collect and use your personal data for this Website and services related to this Website (the “Service”). This privacy policy also describes the choices available to you regarding our use of your personal data. This Policy does not describe how we collect and process your information for other services provided by our organization.

1. Your personal data are in safe hands

Minna Technologies AB, corporate identity number 556967-5449 (“Minna Technologies”, “we”, “us”, “our”) is the responsible entity (controller) for the processing of your personal data as described herein.

Please do not hesitate to reach out to us if you have any questions or comments on your privacy, preferably through the chat offered in the Service. You can also reach us by sending an email to contact@minnatechnologies.com or contact us at:

Minna Technologies AB
Kungsgatan 20, 411 19 Gothenburg, Sweden
+46 72 341 16 58

Minna Technologies has also appointed a Data Protection Officer, who helps us to ensure that your personal data is processed in a correct and lawful manner. You may contact the Data Protection Officer in all matters that concern Minna Technologies’ processing of your personal data and the exercising of your rights, via email to data-protection-officer@minnatechnologies.com.

Data Protection Officer: Alexander Eatough

Definition of personal data: Personal data is information that relates to an identified or identifiable individual.

2. Personal data that is collected about you

Minna Technologies may process the following categories of personal data about you:

Communication data

We will collect data when you contact us about the Service. Communication data may include user data and other relevant information you decide to share with us about yourself. For example, we collect relevant information about your customer support interactions with us, such as the date, time, method of contact and subject of the conversation. Because email communications are not always secure, we encourage you to not include sensitive data in your emails to us but instead use our support forms or contact forms.

Basic contact information

If you ask us a question or request information, we will process your contact data for the purpose of being able to provide you with and answer or additional information.

Technical data

We may collect technical data from your computer (or mobile device) in connection with your use of the Service, such as IP address, browser type and version, and screen resolution. Technical data may also include information about how you use the Service, and if you encounter any technical errors.

How we gather your personal data

Information you give to us. Some of the information Minna Technologies collects about you on this website is received directly from you when interacting via a contact form. Not providing such personal data may prevent us from being able to process your question or request.

Some information may be shared with partners and used for retargeting advertising. We do not have access to that information but if you are a logged in Facebook or LinkedIn user and have consented to the use of their cookie files the information about you visiting our site is shared with them.

4. How your personal data will be used

Minna Technologies processes your personal data for the following purposes and based on the following legal bases:

To provide the Service to you

We will process your personal data to provide you with the Service (i.e. to fulfill our contractual obligations towards you) and to pursue other legitimate interests, depending on the nature of your request we sometimes have a legal obligation to process your data. Your personal data is used to reply to a question or request for information, and technical data is used to ensure that the Service is presented in the best way for you on the device of your choice.

The legal basis for this processing is to provide you with the Service (i.e. to fulfill our contractual obligations towards you) and/or to pursue our legitimate interests and sometimes to fulfil a legal obligation. For example, your personal data is used to provide you with the information requested in the Service, and technical data to ensure that the Service is presented in the best way for you and your devices.

To develop and improve the Service

We may use technical data, and other aggregated and non-personal information to develop and improve the Service, including troubleshooting, data analysis, research, statistical purposes and testing (such as beta testing and evaluation of new features, in line with the fundamental nature of the Service). For example, we may collect and evaluate technical data about your use of the Service for analytical purposes, to understand how people use the Service in order to make it more intuitive. The legal basis for this processing is our legitimate interest, such as to develop and improve the Service and its features.

The legal basis for this processing is to pursue other legitimate interests, such as to develop and improve the Service and its features.

To protect Minna Technologies’ business interests and legal rights

We may process your shared personal information if required by law or if it is necessary to protect or claim our legal rights and interests or the rights and interests of others. This may for instance be required if you or someone else would direct claims towards us, to enable us to comply with laws, to fulfil auditing obligations and to make disclosures in connection with a divestment of our business.

The legal basis for this processing is to pursue our legitimate interests to protect or claim our legal rights and interests or the rights and interests of others.

5. How we share your personal data

Minna Technologies aims to deliver a great service and user experience. This means sharing information with trusted individuals and companies:

Our employees and consultants

Your personal data will when appropriate be processed by people who work for us, but only by those who are authorized to process your personal data. This means that your personal data only will be processed by people who need it to perform their jobs, for example to provide you with customer or sales support. Our employees and consultants are of course subject to confidentiality.

Our service providers

We may transfer to or share your personal data with our suppliers and subcontractors who help us provide the Service to you and to manage our daily operations. Our suppliers and subcontractors are not authorized by us to use or disclose your personal data except as necessary to perform services on our behalf or to comply with legal requirements.

Legal purposes

Sometimes legal obligations may require us to share information about you, for example to respond to lawful requests from law enforcement agencies, regulatory agencies, and other public and government authorities. We may also disclose information if needed to detect and prevent fraud or in connection with a legal process, for example to enforce our terms and conditions or to protect our rights, or the rights of our affiliates, you or others.

Business transfers

We may share or transfer your personal data in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. However, please note that we will never sell your personal data to third parties, unless we have your permission to do so.

6. Where we process your personal data

Minna Technologies always strives to process and store your data within the EU/EEA. In certain situations your data may be transferred to, and stored at, a destination outside of the EU/EEA territory. Please note that privacy laws in countries outside of the EU/EEA may not be the same as, and in some cases may be less protective than, privacy laws in your country. However, we always ensure that we adopt adequate safeguards, such as EU standard contractual clauses and, where necessary, supplementary measures that, so far as possible, afford the data transferred to third countries a level of protection essentially equivalent to that guaranteed within the EU.

You can always contact us for information about the applicable safeguards.

7. How long we keep your personal data

Minna Technologies keeps your personal data only as long as necessary to fulfil the purposes for which it was collected. How long this is depends on the type of information. We regularly review our need to keep data, taking into account applicable legislation.
For information requests we keep your contact information for the duration of the request and if applicable the following conversation. For customer service questions we keep your data for 90 days and for other questions between 30 and 1 year depending on the type of request.

But sometimes longer

Sometimes we may need to keep your data if and to the extent it is necessary to protect or claim our legal rights. Your data may also be stored for a longer period if required under law, such as accounting and tax legislation.

8. Cookies

Like many companies, we use “cookies” and similar technologies in the Service in order to make it more useful to the visitor.For more information about our use of cookies, pixels and similar technologies, please see our Cookie Policy.

9. Changes in this privacy policy

This privacy policy may be updated periodically to reflect changes in the Service or our collection and use of your personal data. We will remain diligently aware of any recommendations, such as those given by the EU Commission and the European Data Protection Board, and implement such guidance as appropriate. We recommend that you review this privacy policy when sharing personal data with us to ensure you are aware of any made amendments. We will indicate at the bottom of this privacy policy when it was most recently updated.

10. Your rights

Right to object

You have the right to object to processing based on legitimate interest. This means we may no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests. You can always contact us for more information on the balance test that has been made. You may also object to your personal data being processed for direct marketing purposes by turning off notifications in your account settings or by following the deregistration instructions included in emails from us.

Right to access and transfer your data

You have the right to request a transcript of personal data processed by us, and additional information on how the data have been collected, processed, shared, etc. You may, in certain cases, also have the right to transfer your personal data to another controller.

Right to rectification

You have the right to correct inaccurate or incomplete information about yourself. You can change many of your personal details under your account settings in the Service.

Right to erasure (‘right to be forgotten’)

You have the right to request that we delete personal data about you, for example if the data is no longer necessary in relation to the purposes for which it was collected or otherwise processed, or if there is no legal basis for processing the data.

Right to restriction

You are entitled to request that the processing of your personal data should be limited until inaccurate or incomplete information about you has been corrected, or until an objection from you has been handled.

Right to withdraw your consent

You may at any time withdraw any consent you have given us. However, please note that it will not affect any processing that has already taken place.

Right to data portability

You may have the right to access personal data that you have provided to us. In such instances will provide you with your data in a structured, generally accepted and machine-readable format. You may also have a right to transfer the personal data to another data controller.

11. Complaints

You have the right to lodge a complaint to the Swedish Data Protection Authority if you believe that we have not complied with our obligations regarding your personal data.
Read more on IMY website. You may also contact the supervisory authorities in the country where you live or work.

12. Changes in this privacy policy

This privacy policy may be updated periodically to reflect changes in the Service or our collection and use of your personal data. We will indicate at the bottom of this privacy policy when it was most recently updated. Current version: 2021-02-15

Appendix

A.1 For Individuals Based in California

This section provides additional specific information for consumers based in California as required by the California Consumer Privacy Act of 2018 (“CCPA”).

A.1.1 Collection and Use of Personal Information

In the last 12 months, we have collected the following categories of personal information:

Identifiers, such as your name, mailing address, email address, zip code, telephone number or other similar identifiers
California Customer Records (Cal. Civ. Code § 1798.80(e)), such as username and password, company name, job title, business email address and department
Internet/network information, such as your browsing history, log and analytics data, information about the device(s) used to access the services and information regarding your interaction with our websites or services and other usage data
Geolocation data, such as information about your location (at country and city level) collected from your IP address
Sensory Information, the content, audio and video recordings of conference calls between you and us that we record where permitted by you and/or the law
Profession/employment information that you send to us when applying for a position included in your CV and cover letter
Other personal information, such as personal information you provide to us in relation to a survey, comment, question, request, article download or inquiry and any other information you upload to our application

We collect personal information directly from you, from your browser or device when you visit our websites, from third parties that you permit to share your information or from third parties that share public information about you, as stated above.

See the section above, “How We Use Personal Information,” to understand how we use the personal information collected from California consumers.

A.1.2 Recipients of Personal Information

We share personal information with third parties for business purposes. The categories of third parties to whom we disclose your personal information may include: (i) our service providers and advisors, (ii) marketing and strategic partners; (iii) ad networks and advertising partners; (iv) analytics providers; and (v) social networks.

Please see the “How We Share Information” section of the Privacy Policy above for more information.

A.1.3 California Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):

The right to know any or all of the following information relating to your personal information that we have collected and disclosed in the last 12 months (upon verification of your identity):

The specific pieces of personal information we have collected about you
The categories of personal information we have collected about you
The categories of sources of the personal information
The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed
The categories of personal information we have sold and the categories of third parties to whom the information was sold, and
The business or commercial purposes for collecting or selling the personal information.

The right to request deletion of personal information we have collected from you, subject to certain exceptions.
The right to opt-out of personal information sales to third parties now or in the future. However, we do not sell your personal information.

You also have the right to be free of discrimination for exercising these rights.

Please note that if exercising these rights limits our ability to process personal information (such as a deletion request), we may no longer be able to provide you with our products and services or engage with you in the same manner.

A.1.4 How to Exercise Your California Consumer Rights

To exercise your right to know and/or your right to deletion, please submit a request by contacting us at data-protection-officer@minnatechnologies.com.

We will need to verify your identity before processing your request.

In order to verify your identity, we will generally require sufficient information from you so that we can match it to the information we maintain about you in our systems. Sometimes we may need additional personal information from you to be able to identify you. We will notify you.

We may decline a request to exercise the right to know and/or right to deletion, particularly where we cannot verify your identity or locate your information in our systems or as permitted by law.

You may choose to designate an authorized agent to make a request under the CCPA on your behalf. No information will be disclosed until the authorized agent’s authority has been reviewed and verified. Once an authorized agent has submitted a request, we may require additional information (i.e., written authorization from you) to confirm the authorized agent’s authority.

If you are an employee/former employee of a Minna Technologies client that uses our application and services, please direct your requests and/or questions directly to your employer/former employer.

If you are a third party (auditor, business associate, etc.), who was given access to the Minna Technologies application by a Minna Technologies client, please direct your requests and/or questions directly to the Minna Technologies client that gave you access.

Minors Under Age 16

Our application and services are intended for business use, and we do not expect them to be of any interest to minors. We do not intentionally collect any personal information of consumers below the age of 16. We do not sell the personal information of California consumers.

16 December 2022