Prgramed respects the privacy and rights of our users and are committed to protecting the information collected through this website and other products (together “Services”). Prgramed has adopted this privacy policy (“Privacy Policy”) to explain how Prgramed collects, stores, and uses the information collected in connection with Prgramed’s Services.
Prgramed is a Swedish company operating under the legal name Prgramed Stockholm AB. We are committed to comply with all applicable laws and regulations, including the General Data Protection Regulation 2016/679 (“GDPR”).
The Data Controller for the processing of personal data is Prgramed Stockholm AB.
The purpose and legal ground for the processing
Prgramed collect and process your personal data for the following purposes:
- Review and respond to e-mails
- Provide customer and technical support
- Managing and providing Services (including user accounts and advertisement serving)
- Analysing the usage of our Services
- Maintain a server log to prevent misuse or hacking attempts etc.
- Maintain, manage and improve our products, optimise the user experience, and to further develop this and other services and products offered by Prgramed
- Help diagnose technical and service issues
Prgramed may combine non-personal data with personal data. Please note that certain features of the Services may be able to connect to your social networking sites to obtain additional information about you. Prgramed will only use your personal data for a specific purpose if we have a legally valid ground to do so. The legal grounds that we rely upon and examples of use based on such legal grounds are:
- Performance of a contract: we rely on this legal ground when we use your personal data in order to maintain and manage your user account and deliver services to you provided in our applications
- Legitimate interests: we rely on legitimate interest as legal ground when processing is necessary in order to pursue a legitimate interest, e.g. in order to prevent misuse and identify hacking. Your privacy interests are always balanced to the legitimate interests pursued. You have the right to object to our processing of personal data that is based on our legitimate interest
- Legal obligation: sometimes we use your personal data to comply with our legal obligations
- Your voluntary and informed consent: we will process your personal data based on your informed and freely given consent to use your personal data for analytics, diagnosing technical issues and bugs and for tailored advertisements.
Please note that you can always withdraw your consent by contacting us at hello@prgramed.com
Personal data that are processed
For purposes of this Privacy Policy, “personal data” means personally identifiable information that specifically identifies or can identify you as an individual. Likely situations where you make personal data available to Prgramed include, but are not limited to:
- registration for Services, contests and special events;
- accessing services using a third party ID, such as social networking sites or gaming services;
- subscribing to newsletters;
- purchasing a product or services through Prgramed’s online stores;
- requesting technical support; and
- otherwise through use of Prgramed’ services where personal data is required for use and/or participation.
The types of personal data may vary depending on the type of activity you are engaged in. The personal data Prgramed may collect and process may include, but are not limited to;
- your name,
- screen/nick name,
- Prgramed Services’ or third party service ID,
- e-mail address,
- phone number,
- photo or other image,
- friend connections,
- contacts from your contact list,
- avatar image,
- device properties, including, but not limited to unique device identifier or other device identifier (“UDID”),
- information you provide through our chat-services in our applications,
- Facebook-ID and location (only if directly identifiable to you, otherwise we treat location as non-personal data).
If you consent to allow your social networking site to make information available to Prgramed and also provided that your social networking site permits it, Prgramed may collect certain information from your social networking profile including but not limited to;
- your name,
- profile picture,
- user ID,
- e-mail address,
- your country, language and time zone,
Prgramed may associate and/or combine as well as use information collected by Prgramed and/or obtained through such social networking sites in accordance with this Privacy Policy.
Your rights
You have several rights according to the GDPR when it comes to our use of your personal data, which are described below. If you want to make use of any of your rights we ask you to contact us at hello@prgramed.com
The right to access and rectification
You have the right to request access to the personal data that we process and that relates to you. This includes the right to be informed whether or not personal data about you is being processed, what personal data is being processed, and the purpose of the processing.
You also have a right, upon request, to access information about any evaluation or assessment of the balancing test we are required to conduct when we process your personal data based on our legitimate interest. You also have the right to rectify or add personal data if the personal data is inaccurate or incomplete.
Right to object
You have the right to object, on grounds relating to your particular situation, to the processing of personal data relating to you. If you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling and legitimate reasons for such processing that overrides your privacy interest.
Right to erasure
You may also request that your personal data be erased if e.g. the personal data is no longer necessary for the purposes for which it was collected, if the processing is based on your consent and you withdraw your consent for a specific process and there is no other legal ground for processing your personal data, if you object to the processing of personal data where we do not have an overriding legitimate interest, the processing is unlawful, or the personal data has to be erased to enable us to comply with a legal requirement.
Please note that we may reject your request if the processing is permitted or required according to law or any other relevant legal ground.
Right to Data Portability
If you request access to personal data about you that you yourself have provided and if the personal data is being processed automatically with your consent or in accordance with a contract (or the terms) between you and Prgramed, you may request that the data is provided in a structured, commonly-used and machine-readable format and you may also request that the personal data is transmitted to another controller, if this is technically feasible.
Right to restrict
You are entitled to request Prgramed to restrict the processing of your personal data in certain cases, pursuant to GDPR article 18.
Right to lodge complaints
If you are concerned or dissatisfied with how we process your personal data, you are always welcome to contact us on hello@prgramed.com. Once we have confirmed your identity, we will handle the request in accordance with applicable law.
Please note that even if you object to certain processing of personal data, we may still conduct the relevant processing if permitted or required to do so by law, for example to be able to fulfil legal or contractual requirements.
You always have the right to lodge a complaint with the relevant supervisory authority in particular where you live, work or where an alleged infringement of the GDPR has occurred. You can find the relevant authority in your country here:
http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
Disclosing and transfer of data
Prgramed collects and processes personal data on a voluntary basis and it is not in the business of selling your personal data to third parties. Personal data may, however, occasionally be disclosed in accordance with applicable legislation and this Privacy Policy.
Prgramed may hire agents and contractors (“data processors”) to collect and process personal data on Prgramed’s behalf and in such cases such agents and contractors will be instructed to comply with our Privacy Policy and to use personal data only for the purposes for which the third party has been engaged by Prgramed, according to applicable data processor agreements. These agents and contractors may not use your personal data for their own marketing purposes. Such data processors might be third party service providers such as credit card processors, e-mail service providers, shipping agents, data analysers and business intelligence providers.
Prgramed may disclose your personal data to third parties as required by law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or Prgramed to legal liability. Prgramed may also disclose your personal data to third parties when Prgramed has a reason to believe that a disclosure is necessary to address potential or actual injury or interference with Prgramed’s rights, property, operations, users or others who may be harmed or may suffer loss or damage, or Prgramed believes that such disclosure is necessary to protect Prgramed’s rights, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on Prgramed. For processing of personal data in relation to Prgramed’s use of analytics, in relation to the placement of ads in our applications as well as in relation to your use of you accounts with social medias to log in with us, se chapters 8, 9 and 10 below.
As Prgramed delivers applications used worldwide, we will store and/or transfer your personal data to our data processors and partners in and outside of EU/EEA member states and the United States in accordance with mandatory legislation and this Privacy Policy.
Data retention, deletion, and correctness
Prgramed retains the data collected pursuant to this Privacy Policy for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Thereafter if the collected data is no longer needed for purposes specified in this Privacy Policy, Prgramed deletes all aforementioned data in its possession. Prgramed does not verify the correctness of personal data. You are at all times entitled to require the deletion of your personal data by sending an e-mail to hello@prgramed.com. If your account is terminated, either by you or by Prgramed, your personal data will be deleted.
If your account is and remains inactive (for example if you have not used the services) for a continued period of 3 years, Prgramed will delete your personal data as well as terminate your account.
Concerning your use of chat services in our applications; chat logs are deleted 72 hours after you have finished the game.
Even if data is changed or deleted, Prgramed may still retain some of the data to resolve disputes, enforce Prgramed user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of Services.
Safeguards
Prgramed follows generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity and privacy of the information in Prgramed’s possession. Only those persons with a need to process your personal data in connection with the fulfilment of their tasks in accordance with the purposes of this Privacy Policy and for the purposes of performing technical maintenance, have access to your personal data in Prgramed’s possession.
Personal data collected by Prgramed is stored in secure operating environments that are not available to the public. To prevent unauthorised on-line access to personal data, Prgramed maintains personal data behind a firewall-protected server. However, no system can be 100% secure and there is the possibility that despite Prgramed’s reasonable efforts, there could be unauthorised access to your personal data. By using the Services, you assume this risk.
Cookies
Our webpage www.prgramed.com does not set cookies.
Third party Terms and Conditions
Please note that your access to and use of the Services may be subject to certain third party terms and conditions and privacy policies, including but not limited to application stores, mobile software platforms, on-line gaming platforms, social networking services and payment providers. Prgramed is not liable for any such third party terms and conditions and their use of your personal data. Prgramed may in its discretion make available links through advertisements or otherwise enable you to access third party products or services. Please note that, while using such products or services, you are using products or services developed and administered by people or companies not affiliated with or controlled by Prgramed. Prgramed is not responsible for the actions of those people or companies, the content of their products or services, the use of information you provide to them, or any products or services they may offer. The fact that Prgramed is linking to those products or services does not constitute our sponsorship of, or affiliation with, those people or companies. Please note that certain Services that Prgramed may offer, such as multiplayer gaming, social networking and gaming console services, may use third party services to provide authentication for the Services with a gaming console ID, social networking ID or gaming network account. When you register to join or use the Services from a third-party gaming or social networking system, certain personally identifiable user and/or membership data may be transferred automatically to and from Prgramed.
Miscellaneous
Please be aware of the open nature of certain social networking and other open features of the Services Prgramed may make available to you. You may choose to disclose data about yourself in the course of contributing user generated content to the Services. Any Data that you disclose in any of these forums, blogs, chats or the like is public information, and there is no expectation of privacy or confidentiality. Prgramed is not responsible for any personal data you choose to make public in any of these forums.
If you are under 15 years of age or a minor in your country of residence, please ask your legal guardian’s permission to use or access the Services. Prgramed takes children’s privacy seriously, and encourages parents and/or guardians to play an active role in their children’s online experience at all times.
In addition, in the event of a merger, acquisition, reorganisation, bankruptcy, or other similar event involving all or a portion of Prgramed, Prgramed’s customer information may be transferred to Prgramed’s successor or assign.
Changes to our Privacy Policy
Due to changes in relevant regulations and administrative practices as well as due to changes in our services, we may from time to time need to modify this Privacy Policy. An updated version will at all times be available here. Please review our Privacy Policy frequently.
Last update: 5 July, 2022
Contact info
Should you have any questions relating to this Privacy Policy or our processing of personal data, please contact us at hello@prgramed.com