PRIVACY POLICY

This Privacy Policy was last updated on May 31, 2022.

INTRODUCTION

Fragsheet AB (“Fragsheet”) respect your privacy and comply with applicable privacy legislation. Fragsheet is controller of the data submitted by you, or collected by Fragsheet, when you open an account and use our Services (as defined in the General Terms of Service).

In addition to this Privacy Policy, please see our Cookie Policy and the at all times applicable General Terms of Service, which also apply to you when you use our Services.

The purpose of this Privacy Policy is to explain how we collect, store, use, transfer, disclose or otherwise process your personal data when you open an account or use the Services provided by Fragsheet. Our Services are provided on www.fragsheet.com, the Fragsheet mobile app, Fragsheet pro, or any related product or service provided by Fragsheet (the ”Service” or “Services”).

CHILDREN

The Services are not directed to children under the age of 13. We do not knowingly collect personal data from children under 13 years old in the Services or in connection therewith. If you are under 13 years, please do not use or access the Services.

We believe it is important to safeguard the privacy of children and encourage parents to regularly monitor their children’s use of online activities. If you are a parent and believe that your child under the age of 13 has accessed and/or used the Services and provided personal data to us, please contact us.

If we learn that we have collected and processed personal data of a child under the age of 13 years, we will take reasonable steps to ensure the erasure of the personal data from our systems and to inform our partners thereof as well. This may require us to delete the child’s account to the Services.

THE DATA WE PROCESS AND THE LEGAL BASIS FOR PROCESSING

Data necessary for accessing the Services

In order to be able to use the Fragsheet Services, you need to provide the information necessary to open an account (username, password and your e-mail address). The basis for this processing is for the performance of a contract with us to which you are a subject (GDPR, article 6.1 b). Fragsheet cannot provide you with the Services if you do not provide us with that personal data.

Data that is voluntary to submit

In addition, you may if you wish, provide additional information, such as your general location (country), age, statistics and the languages you master.

We use the data that you voluntarily provide to generally enhance your experience with our Services, such as to better match you with other users of similar level of experience and knowledge of the subsequent interactions within our Service or with third party providers, such as in our community or by connecting your account to a third party social media. The information which you voluntarily provide is processed based on your consent (GDPR, article 6.1 a). Any such data submitted by you may at any time be deleted by you.

You consent by explicitly accepting this Privacy Policy when opening the account. You may at any time withdraw this consent.

Data which you provide to other users

You may choose to share your personal data in your interactions with other users. Fragsheet cannot be held accountable for how other users may or may not use the data which you disclose in this way, so please be careful with what information you give away.

Fragsheet collect and process this data to better understand user interactions and to help us understand how to better grow our communities and thereby enhancing our Services and your experience. The information which you voluntarily share with others is processed based on your consent (GDPR, article 6.1 a).

You consent by explicitly accepting this Privacy Policy when opening the account. You may at any time withdraw this consent.

Data we collect from you

We may also collect data from you by means of cookies, such as IP-adress, MAC-adress or other information (please see the Cookie Policy for more specific information regarding the data we collect from you when you use our Services).

In addition, we process data on how you use and interact with the Services, such as the links you click on, what communities you interact with, the amount of time you spend on certain activities, etc. We also analyze how you interact with our Services and draw conclusions from that analysis. Such processing is done by aggregating our user’s data in a non-identifiable way. The purpose of processing is to enhance your experience of using the Services and to improve our Services. The processing set forth hereunder is based on the weighing of interest in GDPR art 6.1f), where the processing is necessary for the purpose and legitimate interests set forth herein pursued by Fragsheet, which overrides the interests and fundamental rights of our users.

Data collected for information and marketing purposes

Fragsheet will process personal data by sending occasional emails about, but not limited to, promotions, competitions, sponsors, new features, newsletters, and important updates to keep you up to date of our Services. We will also use other marketing channels such as, but not limited to, push notifications, text messages, platform messages and future means of communication to send the types of messages described above. We will also use your information to show you ads that are relevant to you to improve your online experience.

Some personal data is sold to third-party advertisers, to personalize the advertisements you receive, and to help us monetize the Services. Such third-party advertisers may use that personal data for advertisements outside the Services. Third parties may be partners to Fragsheet or other parties which may offer their products and services by means of advertising shown adjacently to our Services.

Most personal data shared is collected via cookies – please visit our Cookie Policy for more information.

The processing described herein is based on the weighing of interest in GDPR art 6.1f), where the processing is necessary for the purpose and legitimate interests set forth herein which is pursued by Fragsheet and which overrides the interests and fundamental rights of our users.

RECIPIENTS OF PERSONAL DATA AND TRANSFER TO THIRD COUNTRIES

Fragsheet transfers and shares your information to third parties (including service providers operating on our behalf) which are located in countries inside and outside the European Union (“EU”) and/or the European Economic Area (“EEA”) which may not have the same level of data protection.

Such third parties are processors we assign to aid with the provision of our services or partners or third party advertisers.

Where your data is sent to a country outside the EU/EEA that is not subject to an adequacy decision by the EU Commission, the transfers will only occur if we have implemented appropriate safeguards in accordance with the GDPR, such as EU Commission approved standard contractual clauses and supplementary measures to safeguard your personal data.

Fragsheet do not transfer data outside the EU/EEA unless we determine that your Personal Data enjoys equivalent protection as if in the EU/EEA. Please contact us if you want more information on the transfer to countries outside the EU/EEA and a copy of the suitable safeguards.

We also share aggregated data with third-party partners and service providers, which do not identify our users, for the purpose of improving our Services.

Please note: In our Services we display and/or link to games, advertisements, livestreams, etc. from a variety of sources not related to us. If you visit such a third party or click on an advertisement provided by a third party, please note that you are leaving our Services. The third party is solely responsible for the processing of your data and we encourage you to review the privacy policy of that third party. Fragsheet cannot be held liable for these third parties’ privacy practices or content.

RETENTION OF DATA

We will process the personal data you submit to Fragsheet until you close your account and cease using our Services, or if you withdraw your consent. It will thereafter be irrevocably deleted. If you remove certain personal data or withdraw your consent regarding our processing of certain data, Fragsheet will cease processing that data and delete it irrevocably.

We will process your personal data for marketing purposes or in order to personalize your use of our Services, as long as necessary, however not longer than 3 years from when you submit the data or when we collect the data. If you do not use your account for a period of 3 years, all personal data except such you have submitted yourself will be deleted. If you account is inactive for a period of 3 years, we will delete the account and all your data irrevocably.

However, we may still retain information where we have a legitimate interest to use your Personal Data. For example, to resolve disputes, enforce our user agreements such as our General Terms of Service, or to comply with legal requirements.

YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

You have certain rights, and Fragsheet has the corresponding obligations, concerning the processing of your personal data.

- You have the right of access (the right to obtain from Fragsheet confirmation as to whether or not personal data concerning you is being processed, and, when that is the case, access to the personal data and certain information as set forth in the GPDR, article 15).
- You have the right to rectify inaccurate personal data concerning you, as set forth in the GDPR, article 16.
- You have the right to be forgotten to the extent set forth in the GDPR, article 17.
- You have the right to restriction of processing to the degree set forth in the GDPR, article 18.
- Fragsheet shall inform you of rectification or erasure of personal data, or restriction of processing, as set forth in the GDPR, article 19.
- You have the right of data portability (the right to receive the personal data concerning you which you have submitted to Fragsheet, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller) in accordance with the GDPR, art 20.
- You have the right to object to the processing performed based on article 6.1 f), including profiling based on that provision in accordance with the GDPR, art. 21. Please note that you may without cost delete any voluntary data provided by you at any time.
- You have the right to lodge a complain to the applicable supervisory authority (in Sweden; www.imy.se).

WITHDRAWAL OF CONSENT

You may at any time withdraw your consent to the processing of any Personal Data based on your consent. However, please note that the withdrawal does not affect the lawfulness of any processing done before you withdraw your consent.

KEEPING YOUR DATA SAFE

Fragsheet implement the appropriate technical and organizational measures to ensure that your personal data is collected, processed and stored as securely as possible.

Fragsheet have implemented various policies including such as encryption, pseudonymization, access and retention policies to guard against unauthorized access and unnecessary retention of Personal Data.

AMENDMENT OF PRIVACY POLICY

Fragsheet reserves the right to change this Privacy Policy due to new legislation, recommendations or legal practices. The at all times applicable version is published online at www.fragsheet.com. Fragsheet asks you to review the Privacy Policy from time to time to ensure you are aware of any changes. If we make a substantial change to the Privacy Policy, we will provide you with a notice through the Services or by email.