Last update: 11 December 2023 – Version 0.1
Dear User/Visitor,
Your privacy is important to us.
Pitchwise is a product of Bantaba AB, a company registered in Sweden, (Aktiebolag) with organisation number 559320-2640 and having its registered address at c/o Magine Pro, Östermalmsgatan 26A, 114 26 Stockholm, Sweden (“Pitchwise”, “Bantaba”, “we” or “us”).
We provide a web- and mobile-based platform designed to enable customers who have a Pitchwise account (“Users”) to share materials including but not limited to presentations, files, folders, newsletters, and other marketing communications (“Content”) with third-party recipients (“Visitors”) in a controlled application environment provided at www.pitchwise.se (the “Webpage”), (collectively the “Services” or “Service”).
Under the General Data Protection Regulation (2016/679), we are responsible for the processing of personal data for which we decide the purposes and the means of processing. With “personal data” we mean information which is directly or indirectly referable to a natural living person and which are processed in connection with the Service. With “Data Controller” we mean the person or entity that decides for which purposes and in what way the personal data is processed in accordance with Applicable Law. “Processor” is the person or entity that processes personal data on behalf of the Controller and thus may only process personal data in accordance with the Controller’s instructions, this Privacy Policy, and Applicable Law.
This document (the “Privacy Policy”) contains information about our collection, use and processing of personal data, which parties whom we may share such data and your rights in relation to personal data about you. When you use the Service, we will process personal data for a number of purposes, as set forth below.
PROCESSED PERSONAL DATA
We collect and use the following types of personal data to deliver and maintain efficient and secure Services:
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(a) When you register an account as a User, you may be asked to provide personal data including without limitation, your name, phone number, email address and home address. You may also choose to submit personal data to us when you send us an email or use any interactive features that we may make available on the Service. For example, you may ask us to: (a) import your contacts by giving us access to your third party services (such as your email account) or (b) use your social networking information if you give us access to your account on social network connection services.
(b) If you are a Visitor, a User may request that you provide them with information (including personal data) via the Service in order to view that User’s Content. In particular, in order to access Content that a User wants to share with Visitors, a Visitor may be asked to provide personal data including without limitation, the visitor’s name, and email address upon opening User’s link on the Service. A Visitors’ email address may also be provided by a User to grant the Visitor access to content on the Service in which case we store this information on behalf of our User. In the event you as a Visitor provide a User with personal data, you do so in accordance with that User’s privacy practices and policies. Pitchwise is not responsible for the privacy practices of its Users, and only processes this information in accordance with the applicable agreement with each User. If you are a Visitor of one of Pitchwise’s Users and would no longer like to be contacted by such User, please directly contact the User that you interact with.
(c) We process on behalf of Pitchwise Users, information included in the Content that Users (and as appropriate Users’ representatives, employees or other data subjects as elected by Users) upload, download, or access with, share, or send through the Services. If you add Content to your account that has been previously uploaded by you, we may associate all or a portion of the previous Content with your account rather than storing a duplicate.
(d) We may also receive personal data (such as your email address) through other Users, for example, if they have tried to share something with you or tried to refer Pitchwise to you. We may supplement the personal data that we collected from Users and Visitors with additional information obtained from publicly available and third-party databases or services that provide information about business people and companies (including an individual’s name, job title, business contact information, and company information), and display this information to our Users as a part of our Service.
(e) When you use our Service, certain information will be collected automatically from your device, its software and your activity using the Service, including;
a. Information about your use of the Service;
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b. Technical data, which may include the URL from which you navigated to the Website, your IP address, location, unique device ID, network and computer performance, browser type, language and identifying information, operating system, and time stamps associated with the actions;
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c. Metadata about Content you are viewing, and other interactions with the Content and the Services.
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d. For Visitors, we automatically collect information about your interaction with Content shared with you by Pitchwise Users through the Service. Information includes but not limited to date and time you viewed the Content; number of times and length of time Content was viewed; your actions on the Content, for example download clicks, and which parts of the Content were viewed.
PURPOSES OF PROCESSING AND LEGAL BASES
We will process the information set out above for the following purposes:
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(a) We will use your contact information to respond to your request and/or provide information to you. These include when you ask for information about the Service, register to our webinar or event.
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(b) We use personal data provided by Users in connection with the purchase, sign-up, use or support of the User account to administrate your account, to enable and provide access to the Service, integration with third party services, and to otherwise provide the Service according to the terms of use. The processing of personal data for this purpose is based on the necessity for the fulfilment of our agreement with you;
(c) We process personal data relating to Visitors on Users’ behalf for the purpose of providing the Services and to provide our Users with reporting and analytics relating to Visitor’s interaction with Users’ Content and our Service, in accordance with the applicable User contract. Data relating to Visitors that we receive through the Service will be made available to Users who communicate with Visitors via the Service, and may be associated by Users with other information about Visitors including personal data that Users have provided us or that Visitors have provided to Users via the Service. We do not use, or access Visitors’ personal data collected by Users through their use of the Service except with a User’s permission, or to provide the Service.
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(a) To send you alerts or messages by email or otherwise, including to provide you with marketing of our and our related parties’ products and services, and updates of the Service or the terms of use based on our legitimate interest to keep you posted about developments of the Services (such as new features). Where required by applicable law, we will only send you marketing information by email or mail, or contact you by phone, if you consent to us doing so at the time you provide us with your personal data. When you provide us with your consent to be contacted for marketing purposes, you have the right to withdraw your consent at any time by following the instructions to “opt-out” of receiving marketing communication in each marketing email we send you
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(b) To ensure the technical functioning of the Services and to prevent use of the Services in breach of the terms of use to be able to fulfil our agreement with you and based on our legitimate interest to ensure that our Services are not abused for the protection of ourselves and our other users;
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(c) To enforce the terms of use, including to protect our rights, property and safety and also the rights, property and safety of third parties if necessary, on the basis of our legitimate interest of protecting our business, our Services users and other third parties; and
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(d) To fulfil requirements by law, based on our obligation to comply with such laws.
For processing activities that are based on a legitimate interest, we carefully balanced such legitimate interest with your right to privacy and concluded that our interest can be exercised without interfering with your rights and freedoms in a way that prohibits the processing of personal data about you.
RETENTION OF PERSONAL DATA
As the main rule, we store your personal data for only as long as necessary to perform the Service, unless there is a legal obligation to store the data for longer.
After you have closed your account, personal data connected to the account will be stored for 90 days at most.
Contact information to you, used for sending marketing and information is stored for as long as your account is active, and will be deleted when you unsubscribe from our mailing list (with the link in an email or similar from us).
Personal data used to improve the Service and to develop new services are anonymised as soon as possible, however in no case longer than twelve months after which the personal data was collected or created.
Personal data processed pursuant to a legal obligation are stored for as long as the legal obligation warrants that the personal data is stored. This includes when personal data is processed for bookkeeping purposes, where the account details are stored during the current year and until the tenth year after the end of the calendar year which the fiscal year ended.
DISCLOSURE OF PERSONAL DATA
(a) For Users: We will display your personal data on your profile page and elsewhere on the Service according to the preferences you set in your account. You may access your account and change these preferences at any time. Any Personal Data you choose to provide should reflect how much you want others to know about you. When Visitors receive Content from Users, we show a User’s name to the relevant Visitor. We also give our Users the ability to provide their contact information within the document reader to the relevant Visitor.
(b) For Visitors: We show a Visitor’s email address and name to the User who sent the Content through our Service, if the Visitor has provided his or her email address.
(c) We may also share or disclose your information with your consent, for example, if you use a third party application to access your account (example Google or LinkedIn). Through certain features of the Service, you may also have the ability to make some of your information public. Public information may be broadly and quickly disseminated. Please consider carefully what personal data you disclose in your profile page and our Service, and your desired level of anonymity.
(d) We will disclose your personal data to our employees as necessary to deliver the Service, and we may use certain third party companies and individuals to help us provide, support, analyze, and improve the Service (such as providers of data storage services, maintenance services, payment processing, database management, providers of analytics services who help us understand how you use and interact with the Site and the Service, providers of CRM, marketing, and sales software solutions, vendors who assist with recruiting, talent and background checking. These third parties may have access to your personal data for the purpose of performing these tasks on our behalf and pursuant to our instructions, under obligations similar to those in this Privacy Policy
As of the Last Update, these third parties include those listed:
Corporate Name:Â Amazon Web Services
Country:Â Sweden
Purpose:Â Data Storage
Role: Sub-processor
You can find Amazon Web Services’ Privacy Policy at https://aws.amazon.com/compliance/data-privacy
COOKIES, PIXELS AND OTHER SYSTEM TECHNOLOGIES
We collect information through technology like cookies, pixels and local storage (like on your browser or device). For information about how we use system technologies and analytic tools and how you can prevent the use of cookies, please see our Cookie Notice (available here: Cookie Policy).
RESPONDING TO LEGAL REQUESTS AND PREVENTING HARM
We may access, preserve and share your information in response to a legal request (like a search warrant, court order or a subpoena or the like), or when necessary to detect, prevent and address fraud and other illegal activity, to protect ourselves, you and other users, including as part of investigations, if we have a good faith belief that the applicable law require us to do so.
This may include responding to legal requests from jurisdictions outside of the EU/EEA where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.
Information that we receive about you including financial transaction data on the Webpage using our Service, may be accessed, preserved and retained for an extended period of time when it is the subject of a legal request or obligation, government investigation, or investigations concerning possible violations of our terms of use or policies, or otherwise to prevent harm.
SOME OTHER THINGS YOU NEED TO KNOW
Links to other webpages
You should be aware that when you are on our Webpage you may be directed to other sites operated by third parties where the personal information collected is outside of our control. The privacy notice of the new site will govern the information obtained from you on that site.
Change of Control
If the ownership of our business changes, we may transfer your information to the new owners so they can continue the Service. The new owner will still have to honour the commitments we have made in this Privacy Policy.
Notice of Changes
If we make changes to this Privacy Policy, we will notify you by publication here https://pitchwise.se/privacy-policy and/or by notifying you via the Service and your email address. If the changes are material, we will provide you additional, prominent notice as appropriate under the circumstances and, where required under applicable law, ask for your consent.
YOUR PRIVACY RIGHTS UNDER EU LAW Â
You have an absolute right to object to the processing of your personal data for direct marketing. You also have the right to recall your prior given consent. The withdrawal of your consent does not affect the lawfulness of the processing based on the consent before its withdrawal, and we may continue processing your personal data based on other legal grounds, except for direct marketing.
You have the right to request access and further information concerning the processing of your personal data, or request that we correct, rectify, complete, erase or restrict the processing of your personal data. You have the right to obtain a copy of the personal data that we process relating to you free of charge once (1) every calendar year. For any additional copies requested by you, we may charge a reasonable fee based on administrative costs.
If the processing is based on the legal ground of legitimate or public interests, you have the right to object to the processing. If you do this, we will no longer be permitted to process the personal data unless we can demonstrate compelling reasons for why our legitimate grounds for the processing override your interests, rights and freedoms – unless the processing is not for the establishment, exercise or defence of legal claims.
If the processing is based on the legal grounds consent or fulfilment of contract you have the right to data portability. Data portability means that you can receive the personal data that you have provided to us, in a structured, commonly used and machine-readable format, and have the right to transfer such data to another data controllers.
To exercise the aforementioned rights, or if you have any questions about our sharing practices, your rights under EU law, or wish to have your personal information removed, please contact us at the following address: privacy@pitchwise.se or Bantaba AB, c/o Magine Pro, Ă–stermalmsgatan 26A, 114 26 Stockholm, Sweden. In order to ensure that you receive a swift response, please state your full name and, if applicable, your address, username and the email address used for registration. Note that you should sign the request to receive information of the processing of your personal data yourself.
If you have any complaints regarding our processing of your personal data, you may file a complaint
to the competent data protection authority. You can find out more about the local data protection
authorities under the following link http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
CONTACT OUR DATA PROTECTION OFFICER
If you want to contact our data protection officer, you can do so at:
- privacy@pitchwise.se
‍- Bantaba AB, c/o Magine Pro, Östermalmsgatan 26A, 114 26 Stockholm, Sweden.
