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 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 Brand Ambassadors and Mission Agents performing services for Universal Avenue in and outside of the European Union (“EU”) and the European Economic Area (“EEA”)). If you are a Brand Ambassador or a Mission Agent, this policy is part of the contract you enter into when you become a Brand Ambassador or Mission Agent, seeTerms of Service. If you do not accept this policy, you cannot be a Brand Ambassador or Mission Agent at Universal Avenue.
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 and websites or otherwise communicate with us. We also collect information about you to improve our apps and websites. Doing so enables us to deliver a better experience to you as a customer, as a user of our apps and websites or as a Brand Ambassador or Mission Agent.
4 What information do we collect about you?
4.1 Information we collect directly from you
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 or websites. This kind of information that you give us, 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
If you use our apps 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 mobile device, such as:
An essential feature of our apps is to provide our Brand Ambassadors and Mission Agents with information about potential business opportunities. To make this feature work, our apps collect information about the user’s current location. Once you, as a Brand Ambassador or Mission Agent, have granted permission for our apps to access the location of your device, we will collect the precise location of your device when our apps are running in the foreground or background.
Usage and preference information
We use various technologies to collect information about how users interact with our apps. This includes cookies, pixel tags, digital fingerprints and other similar technologies. To learn more about these technologies, please see Section 7 below (Cookies and other technologies).
When you use our apps and websites, we collect and store information about you in our server logs. This includes information such as:
4.3 Information we collect from other 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.
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 also use the information about you as a Brand Ambassador or Mission Agent in order to pay you for the work you have done for us. 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:
We may also share your personal data with other companies in certain situations, such as:
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. 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.
7 How long do we keep the information about you?
We do not keep your personal data longer than necessary. 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
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 http://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. 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 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
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 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, if you do not allow us to collect your precise location, you may not be able to use all the functions of the Universal Avenue platform.
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 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
E-mail: [email protected]