We are responsible for the processing of your personal data as described herein, as a data controller (as defined in the GDPR). Please do not hesitate to reach out to us if you have any questions or comments on your privacy and our processing of your personal data. You can reach us by sending an email to firstname.lastname@example.org or contact us at:
Equestrian Insights AB
Södra Larmgatan 2
411 16, Göteborg
With respect to the joint processing activities, we and Universe Software, Inc. jointly determine the purposes and means of processing. In an agreement on joint controllership we and Universe Software, Inc. have determined how the respective responsibilities in the processing of personal data are allocated in regard to who fulfills which data protection obligations. Notably, we jointly decided on an appropriate level of security upheld by each party, a common way to ensure your data protection rights and to provide you with relevant information, as well as a common framework to address personal data breaches, including reporting and notification obligations of each party. This joint controllership agreement also incorporates appropriate safeguards regarding the transfer of your personal data, such as the EU Commission Standard Contractual Clauses (see point 6 for more details), to ensure an adequate level of data protection.
Nevertheless, Equestrian Insights AB remains at your disposal as your central contact point.
1. PERSONAL DATA THAT WE PROCESS
We process the following categories of personal data about you:
1.1. Contact information and user data
During the registration process where you become a user, you will provide us with your name and email address. Once the application is installed on your device we will collect user data such as your gender, age, user relationships such as added friends and safety contacts including their phone numbers.
1.2. Additional information provided through Facebook Login
If you log in through Facebook Login, your name, gender, age calculated from your date of birth and potential interests/hobbies you have entered into your Facebook account will be collected and added to your account in the Application. We will also collect information regarding users of the Service amongst your Facebook friends.
1.3. Information provided through Google Analytics
During the registration process, we will collect information gathered by Google Analytics. This information is non-identifiable and without reference to account-information.
1.4. Health information and individual training goals
Information regarding your weight will be processed to calculate the energy consumption of you and your horse. Information regarding energy consumption, your training-goals, your notes and performance such as speed and distance will also be stored and available to you in the Service. We will only process information regarding your health and individual training goals if you provide us with this information. You may at any time withdraw your consent and request that we delete this information. For further information regarding your rights, see section 9.
1.5. User activity data
We save and process posted comments and likes you have made, performed trainings you have logged, activities in your calendar and notes posted by you.
We furthermore save information about your activity in the Service in order to analyze users’ use of the Service for improving the Service, but also to enable customer support and for marketing purposes.
1.6. Images and videos
We save images and videos posted by you in the Service (including its meta data).
1.7. Location data
We collect your location data when you have the application installed on your device to track your route as a rider, give you information on nearby stables, show your location on the map in the application, give you information on nearby friends on the application and adapt the language in the application to the language of the country you are located in. Furthermore, location data is collected to compile aggregate statistics of the geographical spread of our users.
1.8. Communication data
We collect data when you contact us regarding the Service. Communication data may include user data and other relevant information you share with us about yourself. For example, we collect relevant information about your customer support interactions with us, such as the date, time, method of contact and subject of the conversation.
1.9. Survey data
We may contact you to participate in online customer satisfaction surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
1.10. Technical data
We collect technical data from mobile device in connection your use of the Service, such as IP address, browser type and version, screen resolution, preferred language, operating system and computer platform. Technical data may also include information about how you use the Service, and if you encounter any technical errors. Even though we do not normally use technical data to identify individuals, sometimes individuals can be recognized from it.
1.11. Subscription data
We save data regarding your subscription including receipt data from App Store and Google Play Store if you choose to make purchases within the Service.
2. HOW WE GATHER YOUR PERSONAL DATA
2.1. Information you give to us
Most of the information we collect about you is received from you. You may directly or indirectly give us information about yourself in different ways, for example during the registration process as explained above. You can always choose not to provide us with certain information. However, some personal data is necessary in order for us to provide you with our Services. Not providing such personal data may prevent you from becoming a user or take full advantage of all features of the Service.
2.2. Information we collect about you
If you log in through Facebook Login we will collect above mentioned information from Facebook. Moreover, we will gather information through cookies, Google Analytics and similar technologies, such as pixels.
3. PURPOSES OF OUR PROCESSING AND LEGAL GROUNDS
We process your personal data for the following purposes and based on the following legal grounds:
3.1. To register your account
We will process your name and email-address to register your account. This is necessary to enter into a contractual relationship with you regarding the Service and to pursue our legitimate interests, such as our interest in simplifying the registration process for our users and administering the contractual relationship.
3.2. To provide you with a social feed in the application
We will process your personal data (location, social activities within the application and information regarding your Facebook friends as well as friends within the application) to provide you with information regarding users of the Service amongst your Facebook friends and your friends’ activities in the application. Furthermore, we process such data to enable communication between you and your friends within the application as well as other equestrians in your stable. This is necessary for us to fulfil the agreement we have entered into regarding our provision of the Service, i.e. the Terms of Service, and our legitimate interest of upholding our commitments towards you as set out in the Terms of Service.
3.3. To provide you with information regarding your performance
We will process your personal data including health information (information regarding your weight, speed and distance of your training sessions) in order to track the energy consumption and performance of you and your horse. Your health information including energy consumption is processed based on your consent. Information regarding speed and distance is processed based on the agreement we have entered into regarding our provision of the Service, i.e. the Terms of Service, and our legitimate interest of upholding our commitments towards you as set out in the Terms of Service when this information cannot reveal information regarding your health. We will only process information regarding your health if you provide us with this information. You may at any time withdraw your consent and request that we delete this information. For further information regarding your rights, see section 9.
3.4. For the functionality of the Service
We will process your personal data to manage your account and to provide you with the Service. For example, your personal data is used to confirm your identity when you sign in, and technical data to ensure that the Service is presented in the best way for you. This is necessary for us to fulfil the agreement we have entered into regarding our provision of the Service, i.e. the Terms of Service, and our legitimate interest of upholding our commitments towards you as set out in the Terms of Service.
Location data is processed to provide you with additional features in the Service, based on your consent.
3.5. To communicate with you
Your contact information will be used to send you reminders, confirmations, application messages and other relevant information about the Service. This processing is either necessary to fulfil the Terms of Service and to provide you with the Service (e.g. send important administrative messages required) or otherwise necessary for our legitimate interests, such as our interest in enhancing and maximizing your use of the Service and to communicate effectively with you.
3.6. For marketing our services
Your contact information will be used to send newsletters or other information regarding the Service and Equilab and updates of the Service to you. We and Universe Software, Inc. will also use information gathered by cookies, Google Analytics, Pixels and similar technologies to market our Services to you on other platforms, such as Facebook. This processing is based on our shared legitimate interest of being able to market the Service and Equilab to our existing customers. Feel free to set or turn off notifications in your account settings, or you can follow the unsubscribe instructions contained in the email received from us.
3.7. For marketing our collaborations
Your personal data (e.g. name, e-mail, interests, age, gender, technical data relating to your use of the service, survey data and other contact information) may be used by us and Universe Software, Inc. to send you information about our collaborations with other companies and offers from our partners based on your interests/hobbies and your use of the Service. This processing is based on our shared legitimate interest of being able to market our collaborations. Feel free to set or turn off notifications in your account settings, or you can follow the unsubscribe instructions contained in the email received from us.
3.8. To provide customer support
Your personal data (e.g. user data such as name and email, technical data) may be used to investigate, respond to and resolve complaints and problems with the Service (e.g. bugs). This processing is necessary to provide you with the Service and upholding our obligations towards you as set out in the Terms of Service and for our legitimate interest in the functionality of the Service.
3.9. To conduct customer surveys
Your contact information may be used to conduct customer surveys. By continuously collecting qualitative feedback from you and other users, we can gain a deeper understanding of our users’ problems and needs. This processing is necessary to pursue legitimate interests, such as our interest in developing and improving the Service. Participation in customer surveys is optional.
3.10. To develop and improve the Service
We use technical data, survey data and other aggregated and non-personal information to develop and improve the Service, including troubleshooting, data analysis, research, statistical purposes and testing (such as beta testing and evaluation of new features, in line with the fundamental nature of the Service). For example, we may collect and evaluate technical data about your use of the Service for analytical purposes e.g. to understand how people use the Service in order to make it more intuitive. This processing is partly necessary to provide the Service to you but mainly to pursue legitimate interests, such as our interest in developing and improving the Service and its features.
3.11. To fulfil our legal obligations
We are obligated to follow applicable laws. This means that your personal data is processed, including transferred and retained, to the extent necessary for us to uphold our obligations under applicable laws or other legal obligations, e.g. bookkeeping and reporting to the authorities. Our financial information is also shared with Universe Software, Inc., which uses the information for the purposes of financial analysis, which in turn benefit us, meaning that we have a shared legitimate interest with Universe Software, Inc. for this processing. The financial information processed by Universe Software, Inc. may contain incidental personal data.
3.12. To protect our legitimate business interests and defend us against or enforce legal claims
Your personal information will be used where we believe it is necessary to protect ours, yours or others legal rights, or other legitimate interests. Processing for this purpose can become necessary to defend us against or enforce legal claims. The legal ground for this processing is our legitimate interest to protect us, you and others and for us to defend against or enforce legal claims.
3.13. In connection with a merger or acquisition
In connection with, due to strategical or business-oriented reasons, a potential merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company, the personal data we retain about you may be processed, shared or transferred, to parties involved in the process. This processing is based on our legitimate interest of being able to develop our business.
4. CHILDREN'S PRIVACY
Equilab does not knowingly collect any personal data from any individual under the age of 13 or knowingly allows such individuals to register for the Service. The Service and its content are not directed at children under the age of 13. If we become aware that Equilab has collected personal data from a child under the age of 13 without parental consent, we will delete that personal data as quickly as possible. If you believe that we may have collected any personal data from or relating to a child under the age of 13, please contact us.
5. HOW WE SHARE YOUR PERSONAL DATA
We aim to deliver a great service and user experience. This means sharing information with trusted third parties:
5.1. Our employees and consultants
Your personal data will, when appropriate, be shared with some of our employees and consultants. However, we will restrict access to those of our employees and consultants who need it to perform their jobs, for example to provide you with customer support. Our employees and consultants are of course subject to strict confidentiality.
5.2. Our service providers
We provide personal data to third parties solely for the purpose of delivering the Service and to manage our daily operations including developing and improving the Service, marketing our Service and Equilab as well as our collaborations, providing you with customer support and communicating with you. Our suppliers and subcontractors are not authorized by us to use or disclose your personal data except as necessary to perform services on our behalf or to comply with legal requirements.
5.3. Authorities and other public actors
5.4. Merger, acquisition or other business transfer
We may share or transfer your personal data in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. In this regard, we continually share and transfer personal data concerning you as described above in section 3.6, 3.7, and 3.11, to our parent company Universe Software, Inc.
However, please note that we will never sell your personal data to third parties, unless we have your permission to do so. If you have questions about the sharing of your personal data, always feel free to reach us at email@example.com or contact us at:
Equestrian Insights AB
Södra Larmgatan 2,
416 16, Göteborg
5.5. Other users of the Service
Your personal data (e.g. name, Facebook Profile, profile picture and the stable you are a member of) will be public in the application and thereby shared to other users of the Service. Other personal data (e.g. posts in the social feed, location data, images and videos, calendar events) may be shared with users you are connected to.
6. WHERE WE PROCESS YOUR PERSONAL DATA
We always strive to process and store your data within the EU/EEA. However, your data may in certain situations be transferred to, and stored at, a destination outside of the EU/EEA territory. This can occur for example, when we transfer your personal data to our parent company Universe Software, Inc. in its capacity as a joint controller or when we engage with a service provider that is established in a country outside the EU/EEA.
Please note that privacy laws in countries outside of the EU/EEA may not be the same as, and in some cases may be less protective than, privacy laws in your country. However, we always select our Service providers carefully and take all the necessary steps to ensure that your personal data is processed with adequate safeguards in place in accordance with the General Data Protection Regulation 2016/679 (GDPR). These safeguards are either that we sign the EU Commission Standard Contractual Clauses or ensure that the Service provider is established in a country which the EU Commission has deemed as having adequate data protection.
You can always contact us for information about the applicable safeguards at firstname.lastname@example.org or contact us at:
Equestrian Insights AB
Södra Larmgatan 2
411 16, Göteborg
7. HOW LONG WE KEEP YOUR PERSONAL DATA
We keep your personal data only as long as necessary to fulfil the purposes for which it was collected. How long depends on the type of information and why we process it. We regularly review our need to keep data, taking into account applicable legislation.
We keep your personal data until you delete your account or, regarding the personal data we process based on your consent, when you withdraw your consent. Normally, we need to keep most of your information for as long as you have an account. Personal data processed on the basis of your consent will be deleted when your consent is withdrawn or upon expiry of the purpose for which your consent was given.
And sometimes longer. Even if you delete your account or withdraw your consent, we keep your data if and to the extent we believe it is necessary to protect our legal rights, legitimate interests and the interests of others. For example, we will retain your contact information for marketing purposes in up to one year after you have deleted your account. Your data may also be stored for a longer period if required by applicable statutory retention periods, such as applicable periods for customer claims from consumers and accounting rules. Furthermore, we save a back-up of all information stored which is deleted once every month.
We furthermore keep location data and statistics regarding user behavior without reference to an account (anonymized) after the account has been deleted. Information kept is stored and processed without reference to account-information. If you would like us to delete this aggregate, non-identifiable information, please contact us at email@example.com.
In order to obtain aggregated statistics regarding our users’ activity in the Service we use Google Analytics. All information we receive through the use of these cookies is aggregated and anonymous and is used to analyze and improve the Service and to develop the products and Services we offer. For more information on Google Analytics and personal data protection, please follow this link. If you do not accept cookies for Google Analytics, we will not know when you have used the Service and cannot analyze the performance of the Service.
Moreover, we use “Facebook Pixel” in our application for retargeting purposes, which enables us to market us and the Service on Facebook based on how you as a user have used the Service and to create marketing campaigns towards a certain group of Facebook-users. To read more about Facebook’s processing of personal data in relation to the use of “Facebook pixels”, please follow this link.
9. YOUR RIGHTS
9.1. Right to access your data
You have the right to request a transcript of personal data processed by us, and additional information on how the data have been collected, processed, shared, etc. The first transcript may be requested free of charge. However, upon repeated and unreasonable requests we might charge you with an administrative fee.
9.2. Right to transfer your data
You also have, under certain circumstances, the right to transfer your personal data to another controller.
9.3. Right to object
You have right to object to processing based on legitimate interest. This means we may no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests. You can always contact us for more information on the balance test that has been made.
You may also object to your personal data being processed for direct marketing purposes.
9.4. Right to rectification
You have the right to correct inaccurate or incomplete information about yourself.
9.5. Right to erasure (‘right to be forgotten’)
You have the right to request that we delete personal data about you, for example if the data is no longer necessary in relation to the purposes for which it was collected or otherwise processed, or if there is no legal basis for processing the data.
9.6. Right to restriction
You are entitled to request that the processing of your personal data should be limited until inaccurate or incomplete information about you has been corrected, or until an objection from you have been handled.
9.7. Right to withdraw your consent
You may at any time withdraw any consent you have given us. However, please note that it will not affect any processing that has already taken place.
9.8. Right to complain
You have the right to lodge a complaint to the supervisory authority (as defined in the GDPR) in the country you live or work in, if you believe that we have not complied with our obligations regarding your personal data. For Swedish purposes, such authority is Integritetsskyddsmyndigheten, whose website is available here.
Please note that legal rights or obligations (such as confidentiality, accounting and tax legislation) may prevent us from disclosing or transfer all or part of your information, or from immediately deleting your information.