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Effective date: 25 May 2020
9291 is firmly committed to the security and protection of personal information of our Users. This Privacy Policy describes how 9291 will collect, use, share and process personal information. Capitalized terms not defined in this Privacy Policy are defined in the 9291 Terms of Service.
If you reside in the European Union (EU), European Economic Area and Switzerland (“Europe”), You are entering into the Terms of Service with True Software Scandinavia AB and True Software Scandinavia AB will be the controller of Your personal information. If you do not reside in Europe the applicable terms are available here.
In simple terms:
We process Your profile data (name, phone number etc.) and information about Your activity on the 9291 application including device information, IP address and location to provide, improve, analyze and personalize the Services for You. We have enhanced our privacy center to provide You with more ability to access and control Your data.
Subject always to obtaining your prior consent, we may:
We do not:
When You create a user profile in the Services and confirm being the holder of a certain number, 9291 will collect the information provided by You. In order to create a user profile, You must register Your first name, last name and phone number. Additional information that may be provided at Your option include, but is not limited to, photo, gender, street address and zip code, country of residence, email address, professional website, Facebook page, Twitter address and a short status message. 9291 may supplement the information provided by You with information from third parties and add it to the information provided by You e.g. demographic information and additional contact information that is publicly available. If You register for a Paid Service, 9291 will collect Your payment and billing information.
When You install and use the Services, 9291 will collect personal information from You and any devices You may use in Your interaction with our Services. This information may include e.g.: geo-location; Your IP address; device ID or unique identifier; device manufacturer and type; device and hardware settings; SIM card usage and details; applications installed on your device; ID for advertising; ad data, operating system; web browser; operator; connection information; screen resolution; usage statistics; default communication applications; access to device address book; device log and event information; logs, keywords and meta data of incoming and outgoing calls and messages; version of the Services You use and other information based on Your interaction with our Services such as how the Services are being accessed (via another service, web site or a search engine); the pages You visit and features you use on the Services; the services and websites You engage with from the Services; content viewed by You, content You have commented on or sent to us and information about the ads You see and/or engage with; the search terms You use; order information and other usage activity and data logged by 9291 servers from time to time. 9291 may collect some of this information automatically through use of cookies
Some information, including, but not limited to, usage information and other information that may arise from Your interaction with the Services, cannot be used to identify You, whether in combination with other information or otherwise and will not constitute personal information for the purposes of this Policy.
You may provide us with Your user identifier information regarding, or to enable Your usage of, certain third party services (together with a mapped photo where applicable) e.g. social networking services and payment services, in order for the Services to interoperate with such third party services. You may use such third party services to create Your user profile or log in to our Services, share information with such third party services, or to connect Your user profile with the respective third party services. Such third party services may automatically provide us with access to certain personal information retained by them about You (e.g., your payment handle, unique identification information and information about the advertisements You have been shown or may have clicked on). You may be able to control the personal information You allow us to have access to through the privacy settings on the respective third party service. We will never store any passwords created for any third party services.
You may provide us with various information in connection with Your interaction with our Services. For example, You may through tagging functionality associate a phone number, that is not registered in the 9291 database or belongs to a User, with a business or name and You may report a phone number as spam or some other attribute to be included in spam blocking directories. 9291 may also from time to time offer You the opportunity to provide information on Your experience from using the Services or to participate in contests, surveys or other promotions. 9291 will collect the information You provide in connection therewith, as well as any other information You provide through the Services or when You communicate or interact with us.
9291 may use the personal information collected to provide, maintain, improve, analyze and personalize the Services to its Users, partners and third party providers. More specifically, 9291 may use such information to:
We use aggregated or anonymized personal information for statistical and analytical purposes. We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise. We may collect, use, transfer, and disclose non-personal information for any purpose.
Subject to the choices You make upon registration and in Your settings at any time, we may use the information collected, as set out above, to provide You with location and interest based advertising, marketing messaging, information and services. We may also use the collected information to measure the performance of our advertising and marketing services. Furthermore, we may contact You for verification purposes or with information pertaining to the Services or special offers, e.g. newsletter e-mails, SMS and similar notifications about 9291 and our business partners’ products and services. We also use the collected information to respond to you when you contact us.
We may use the collected information to comply with applicable laws and to enforce our agreements and protect and defend the rights or safety of 9291, its Users or any other person and verify provided User profile information with third party providers and ensure technical service functionality and data accuracy, perform trouble-shooting and prevent or detect fraud, security breaches or illegal activities.
In addition to the sharing and disclosure of personal information that is included as part of the functionality of the Services as described in section 2, 9291 may disclose personal information if we believe such action is necessary to:
We may disclose and transfer Your Information to our associated or affiliated organisations or related entities and to any third party who acquires, our business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets.
9291 will collect and process Your personal information in order to perform the contract with You (e.g. to deliver the Services), based on Your consent (i.e. the choices You make upon registration and in Your settings) or based on a legitimate interest of 9291 (which is not overridden by your interests or fundamental rights and freedoms). Such legitimate interests of 9291 include to protect and maintain the security of the Services, to create and maintain spam blocking directories, to understand and improve our Services and user relationships and to administer our business and customer support. Where we process data based on Your consent, You may withdraw your consent at any time via Your settings.
9291 will retain Your personal information while You maintain a user profile in the Services. You may at any time choose to delete Your user profile and Your personal information via Your settings. If You make such choices, Your personal information will no longer be visible to others in the Services. We will retain Your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. We may also retain Your personal information in order to accommodate Your choices regarding marketing.
Please note that provision of information from the 9291 database is constitutionally protected under applicable laws on Freedom of Expression, see the Terms of Service. You acknowledge and agree that any phone number and name that you report as spam to 9291 and any phone number and name that You report as being a business is submitted for publication in the 9291 database, for which a Publishing Certificate (Sw: utgivningsbevis) has been issued. Such Publishing Certificate provides for constitutional protection under the Swedish Fundamental Law on Freedom of Expression.
The 9291 Services require by their very nature that Your personal information will be transferred to other Users across the globe. 9291 may also use cloud based services and subcontract storage or processing of Your information to third parties located in countries other than Your home country in order to provide the Services, including e.g. the USA. Information collected within the Europe may, for example, be transferred to and processed in a country outside of Europe, which may not provide the same level of protection for personal data as within Europe. We use Model Contractual Clauses adopted by the EU Commission as a legal mechanism for the international transfer of data to a third party located in a country outside Europe. We take all reasonable precautions to protect personal information from misuse, loss and unauthorized access. 9291 has implemented physical, electronic, and procedural safeguards in order to protect the information, including that the information will be stored on secured servers and protected by secured networks to which access is limited to a few authorized employees and personnel. However, no method of transmission over the Internet or method of electronic storage is 100% secure.
9291 provides many choices for You to control and manage Your personal information via the settings in the 9291 Privacy Center. Subject to applicable law, you may also have the following rights in relation to Your personal information:
Right of access: You may request a confirmation as to whether or not personal information is being processed by 9291 and to obtain a copy of that information. We may decline to process requests that are vexatious or frivolous or extremely impractical, jeopardize the privacy of others, or for which access is not otherwise required by applicable law.
Right to rectification: You may request rectification if Your personal information is inaccurate.
Right to erasure: You may request that your personal information is erased in certain situations e.g. if it is no longer necessary to provide the Services to You.
Right to object: You may object to the processing of Your personal information in certain situations e.g. for use of Your data for ad targeting.
Right to restriction: You may request restrictions of the processing of Your personal information in certain situations e.g. if Your personal information is inaccurate or unlawfully processed.
Right to data portability: You may request to receive personal information provided by You in machine readable format.
You can exercise Your rights above via the 9291 Privacy Center where You e.g. can access, edit, delete and download Your personal information and limit or opt-out of the collection and use of Your information for ad targeting and the provision of special offers or promotions by third parties. You may also contact 9291 for assistance using the contact information below, and we will consider your request in accordance with applicable law.
We do not intentionally or knowingly collect or solict information from children under the relevant age of consent under the laws of their respective jurisdictions or knowingly allow such persons to register for the Services. The Services are not directed at children under the relevant age of consent under the laws of their respective jurisdictions. If you believe that we might have information from or about a child under the relevant age of consent,
9291 may at any time change this Privacy Policy. 9291 will notify the Users of such changes by push notice or via notice in the Services or by other means. If You object to any changes, You may uninstall the 9291 applications and cease using the Services. Your continued use of the Services after 9291 have communicated changes to this Privacy Policy, will mean that the collection, use, sharing and processing of Your personal information is subject to the new Privacy Policy. We may from time to time set out more detailed information on how we process your personal information in relation to particular Services in supplemental Privacy Notices which shall be incorporated into and form part of this Privacy Policy.
For questions or complaints related to this Privacy Policy or the processing of Your personal information, we encourage You to contact our Data Protection Officer frawlla.software@gmail.com.