1 About this policy
We at Universal Avenue AB appreciate the trust you place in us when you use our products and services. As part of us providing these products and services, we process personal data. This policy applies to all personal data we collect directly and indirectly from you and other sources and applies when we process your personal data for the purposes that we describe in this policy. This policy explains:
Please take the time to read this policy. We’ve tried to keep it simple, but if you have any questions do not hesitate to contact us.
2 To whom, where and when does this policy apply?
This policy applies to all individuals whose personal data we process as part of us providing our products and services (including all customers using our platform as well as sales representatives from partners using Universal Avenues platform in and outside of the European Union (“EU”) and the European Economic Area (“EEA”)).
3 Why do we collect information about you?
In order to provide our products and services we need to process your personal data, as described in this policy. We collect various kinds of information about you when you buy our products and/or services, when you use our apps, portals and websites or otherwise communicate with us. We also collect information about you to improve our apps, portals and websites. Doing so enables us to deliver a better experience to you as a customer, as a sales representative and as a user of our apps, portals and websites.
4 What information do we collect about you?
4.1 Information we collect directly from you as a customer
We collect personal data directly from you when you register as a customer of Universal Avenue, when you place an order or sign up for an account on our apps, portals or websites. This kind of information that you provide us with, as well as the information on products/services and your financial information, is generally required in order for you to enter into a contractual relationship with us. This may include information such as:
4.2 Information we collect indirectly from you as a user of our apps, portals, websites and services
If you use our apps, portals and websites, we also collect information about how you use them, including when and how you log in or interact with content. This information includes device information, location information, usage and preference information and log information.
We collect information about your hardware device, such as:
Usage and preference information
We use various technologies to collect information about how users interact with our apps, portals and websites. This includes cookies, pixel tags, digital fingerprints and other similar technologies. To learn more about these technologies, please see Section 8 below (Cookies and other technologies).
When you use our apps, portals and websites, we collect and store information about you in our server logs. This includes information such as:
Interactions with our portals and websites
When you visit our portal or any of our websites we collect information regarding how you interact with them. This applies to both customers and sales representatives for any of our partner brands. We use this information in order to improve the user experience and to evaluate the use of the individual elements. We collect this information to administrate, protect, operate and maintain our websites, system administration and security and to collect statistics about the site usage, purchases and to improve understanding of our customers preferences. This includes information such as:
Information about how you use your personal hardware
If Universal Avenue provides your company with Mobile Device Management (MDM) we will collect data regarding your hardware device in order to manage mobile devices, tablets and computers. We need to collect this data in order to be able to deliver the MDM support service. This data includes information such as:
We cannot access information stored on the device such as Internet history, Images, text documents, pdf files, contacts etc. We also cannot access or store communication history such as phone calls, SMS or Emails.
4.3 Information we collect from third party sources
We may collect information about you from third party sources. We may combine that information with other information that we collect from you directly or indirectly. For example, we may collect data from credit checks as required by some of the brands for which UA is a reseller. We do this on contractual grounds in the interest of the brands we represent.
4.3.1 Information we collect from your employer
If you are a user of SmartPortal through your employer, we collect information about your hardware devices and software licenses tied to you as an employee. We might also store information about the history of these devices.
5 How will we use the information about you?
All information is used to provide, operate and improve Universal Avenue’s services and our apps and websites. We may also use the information from existing services in order to develop new services. In addition to this, we use your information to:
5.1 Sharing your information
We only share your personal information for the purposes we describe in this section. We may share your information with:
If we share your data a Data Processing Agreement will be signed
If we share your data with any of our partner brands, subsidiaries or external consultants we will sign a Data Processing Agreement (DPA) with them before we hand over your data in order to ensure that your information is stored and processed securely. The DPA complies with the requirements of the current legal framework in relation to data processing and with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
5.2 Automated decision-making
We may use automated decision making based on your personal information for some services in our apps or websites. For example, automated decision making may be used to expose you to particular products or services relevant to you, based on information you have provided us with directly or indirectly, such as purchase history or website usage. You may request a manual review of the accuracy of an automated decision, see Section 9.3 below.
5.3 Third country transfers
We may transfer your personal data to countries outside the EU or EEA, for example if one of our partner brands is located in such an area. Some of these countries may have less protective data protection laws than the EU/EEA. Where this is the case, we will take appropriate measures to protect your personal information.
6 What we DO NOT do with your data
We will not sell your personal details to third parties unless we have your permission to do so. We will thereby ask for your explicit consent to share any personal information.
7 How long do we keep the information about you?
We do not keep your personal data longer than necessary. When the data is no longer needed for the purpose for which it was once collected, it will be deleted. However, legal requirements dictate how long we have to keep some types of information, for example information about payments we have made to you or you have made to us. We do not keep that information longer than required by law. We delete all other information we have about you within 24 months after the end of your contract with us.
8 Cookies and other technologies
Cookies are small text files that our apps and websites store in your browser or on your device when you use our apps and websites. We may also allow other service providers to serve you cookies while you are using our apps or websites.
We also use other technologies that are similar to cookies, for example pixel tags and digital fingerprints. These technologies collect certain information about your device and browser, such as: device type, operating system, browser information, IP address, unique identifiers and other similar information.
We use session cookies that are automatically deleted when the browser window is closed.
You can read more about cookies and other technologies on https://www.youronlinechoices.com.
9 Your rights and your choices
Your privacy rights and choices are important to us. We work hard to respond promptly to all your requests. We may reject requests that are unreasonably repetitive or that require disproportionate technical effort. We will reject requests that put the privacy of others at risk. We handle your requests for free, except where it would require a disproportionate effort.
We put a lot of effort into securing your information and protecting it from accidental or malicious destruction. Therefore, it may take us some time until we delete all residual copies of your information from our active servers and backup systems.
9.1 Access and correct your data
You have the right to request a copy of the information that we hold about you in a structured, commonly used and machine-readable format. You can correct your account information at any time via our apps or websites. If you would like a copy of some or all of your personal information, please email or write to us at the following address: [email protected] or Universal Avenue AB, Attn: Legal, Grev Turegatan 5E, 114 46 Stockholm, Sweden.
9.2 Erase your data
You have the right to request that we erase the personal data we have about you but please note that we must keep some of your data due to legal requirements. If you would like us to erase your personal data, please email or write to us at the following address: [email protected] or Universal Avenue AB, Attn: Legal, Grev Turegatan 5E, 114 46 Stockholm, Sweden.
9.3 Object to automated decision making
Some of the features in our apps, portals and websites are based on automated decision making. You have the right to object to those automated decisions that affect you. If you would like to object to such a decision or if you would like to request a manual review of the accuracy of an automated decision that you are unhappy with, please email or write to us at the following address: [email protected] or Universal Avenue AB, Attn: Legal, Grev Turegatan 5E, 114 46 Stockholm, Sweden.
9.4 Restrict our use of your data
You have the right to restrict us from using your data in certain situations, for example when the data we have about you is inaccurate. If you would like to request that we not use your data, please email or write to us at the following address: [email protected] or Universal Avenue AB, Attn: Legal, Grev Turegatan 5E, 114 46 Stockholm, Sweden.
9.5 Lodge a complaint
You have the right to the right to lodge a complaint about us with the supervisory authority. The supervisory authority for Universal Avenue is the Swedish data protection authority – Datainspektionen.
9.6 Withdraw your consent
You have the right to withdraw your consent for data processing. There are different ways to change your given consent, below are some approaches to managing data collection.
9.6.1 Location information
We collect and use some of your personal data with your consent. You have the right to withdraw this consent at any time. For example, we collect your precise location from your device if you use our apps, portals or websites with your consent. If you initially allow us to collect this information and then change your mind, you can withdraw your consent by changing the location settings on your mobile device. However, this might disable you to use all the functions of the Universal Avenue platform.
9.6.2 Cookies and other technologies
You can choose whether or not to accept cookies on our websites. Most web browsers are set to accept cookies by default, but they allow you to remove or reject browser cookies in the browser settings. Our websites may not function properly if you refuse or remove cookies and you will not be able to log in to your account if you do not accept cookies. For further information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, you can visit https://www.youronlinechoices.eu.
10 Changes to this policy
We may change this policy from time to time. If we do so, we will post the updated policy here and will inform you about the changes via the email address you have provided to us. The updated version will apply to all the information we have about you at that time and will apply to new information going forward.
11 Contact our Data Protection Officer
Universal Avenue employs a Data Protection Officer (‘DPO’) who is responsible for facilitating data protection and data privacy compliance. If you have any questions about this policy, how we use your information, or your data privacy rights, please contact our DPO at the following address:
Data Protection Officer
Grev Turegatan 5E
114 46 Stockholm