Flyt digital coaching platform is a brand of The Roll AB. We at TheRoll AB care about your privacy, and therefore take it very seriously. This Privacy Policy describes how we collect, use, process, and disclose yourinformation, including personal information, in conjunction with your access toand use of the The Roll website, e-coaching platform or the services in anymatter. When thispolicy mentions "The Roll", we, us, or our, it refers to the The RollAB company or affiliates that is responsible for your information under thisPrivacy Policy (the Data Controller).
Data Controller
The entityresponsible for the processing of your personal information is:
The Roll AB
Eriksbersgatan 10, 114 30,STOCKHOLM, SWEDEN
Company number: 556845-3764
Telephone: +46(0)70025 54 20
Email: inca.whyte@theroll.com
Information we collect
There are three general categories of information we collect.
Information you gave to us
Information that is necessary for the use of the The Roll website, e-coaching platform or the services in any matter. We ask forand collect the following personal information about you when you use the TheRoll website and/or e-coaching platform. This information is necessary for theadequate performance of the contract between you and us and to allow us tocomply with our legal obligations. Without it, we may not be able to provideyou with all the requested services.
Account information
When yousign up for an The Roll Account, we require certain information such as yourfirst name, last name, email address, and date of birth.
Communications with The Roll
When youcommunicate with The Roll, we collect information about your communication andany information you choose to provide.
Information you choose to give us
You maychoose to provide us with additional personal information in order to obtain abetter user experience when using The Roll website and e-coaching platform.This additional information will be processed based on your consent.
Additional Profile Information
You maychoose to provide additional information as part of your The Roll profile (suchas gender, preferred language(s), city) and coaching experience. Some of thisinformation as indicated in your Account settings is part of your profile page,and will not be publicly visible to anyone other then a coach and peers if youmay have one and/or the others.
Address Book Contact Information
You maychoose to import your address book contacts or enter your contacts’ information manually to access certain features of the The Roll e-coaching platform, likeinviting them to use The Roll e-coaching platform.
Other Information
You mayotherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your The Roll Account, respond to surveys,post to community forums, participate in promotions, or use other features of the The Roll website and e-coaching platform.
Information we automatically collect from your use of the The Roll website and e-coaching platform.
When youuse the The Roll website or e-coaching platform, we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for the adequate performance, to enable us to comply with legal obligations and given our legitimate interest inbeing able to provide and improve the functionalities of the The Roll website and e-coaching platform.
Geo-location information
When youuse certain features of the The Roll website and e-coaching platform, we maycollect information about your precise or approximate location as determinedthrough data such as your IP address or mobile device’s GPS to offer you animproved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. TheRoll may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
Usage information
We collectinformation about your interactions with the The Roll website and e-coaching platform such as the pages or content you view and other actions on the TheRoll website and e-coaching platform.
Log data and device information
Weautomatically collect log data and device information when you access and use the The Roll website and e-coaching platform, even if you have not created an TheRoll Account or logged in. That information includes, among other things:details about how you’ve used the The Roll website (including if you clicked onlinks to third party applications), IP address, access dates and times,hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’veviewed or engaged with before or after using the The Roll website.
Cookies and similar technologies
We usecookies and other similar technologies, such as web beacons, pixels, and mobileidentifiers. We may also allow our business partners to use these trackingtechnologies on the The Roll website, or engage others to track your behavioron our behalf. While you may disable the usage of cookies through your browsersettings, the The Roll website currently does not respond to a Do Not Tracksignal in the HTTP header from your browser or mobile application due to lackof standardization regarding how that signal should be interpreted. For moreinformation on our use of these technologies, see ourCookie Policy.We useHotjar in order to better understand our users’ needs and to optimize thisservice and experience. Hotjar is a technology service that helps us betterunderstand our users experience (e.g. how much time they spend on which pages,which links they choose to click, what users do and don’t like, etc.) and thisenables us to build and maintain our service with user feedback. Hotjar usescookies and other technologies to collect data on our users’ behavior and theirdevices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers),browser information, geographic location (country only), preferred languageused to display our website). Hotjar stores this information in a pseudonymizeduser profile. Neither Hotjar nor we will ever use this information to identifyindividual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites byfollowing this opt-out link.
Information we collect from third parties
The Rollmay collect information, including personal information, that others provide about you when they use the The Roll website and e-coaching platform, or obtain information from other sources and combine that with information we collect through the The Roll website and e-coaching platform. We do not control,supervise or respond for how the third parties providing your informationprocess your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such thirdparties.
Third Party Services
If youlink, connect, or login to your The Roll Account with a third-party service(e.g. Google, Facebook), the third party service may send us information suchas your registration and profile information from that service. Thisinformation varies and is controlled by that service or as authorized by you via your privacy settings at that service.
Other Sources
To theextent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive fraud warnings from service providers like identity verification services for our fraud prevention and riskassessment efforts. We may receive information about you and your activities on and off the The Roll website and e-coaching platform through partnerships, orabout your experiences and interactions from our partner ad networks.
How we use information we collect
We use,store, and process information, including personal information, about you toprovide, understand, improve, and develop the The Roll website and e-coachingplatform, create and maintain a trusted and safer environment and comply withour legal obligations.Provide,improve, and develop the The Roll website and e-coaching platform.Enable youto access and use the The Roll website and e-coaching platform.Operate,protect, improve, and optimize the The Roll website and e-coaching platform andexperience, such as by performing analytics and conducting research.Providecustomer service.Send youservice or support messages, updates, security alerts, and accountnotifications.If youprovide us with your contacts’ information, we may process this information:(i) to facilitate your referral invitations, (ii) send your requests forreferences, (iii) for fraud detection and prevention, and (iv) for any purposeyou authorize at the time of collection.To operate,protect, improve, and optimize the The Roll website and e-coaching platformexperience, and personalize and customize your experience (such as makingListing suggestions or ranking search results), we conduct profiling based onyour interactions with the The Roll website and e-coaching platform, yoursearch, your profile information and preferences, and other content you submitto the The Roll website.We processthis information given our legitimate interest in improving the The Rollwebsite and e-coaching platform and our Members’ experience with it, and whereit is necessary for the adequate performance of the contract with you.Create andmaintain a trusted and safer environmentDetect andprevent fraud, spam, abuse, security incidents, and other harmful activity. Conductsecurity investigations and risk assessments.Comply withour legal obligations.Resolve anydisputes and enforce our agreements with third parties.Enforce ourTerms & Conditions and other policies.Inconnection with the activities above, we may conduct profiling based on yourinteractions with the The Roll website and e-coaching platform, your profileinformation and other content you submit to the The Roll website and e-coachingplatform, and information obtained from third parties. In limited cases,automated processes may restrict or suspend access to the The Roll website and e-coachingplatform if such processes detect a Member or activity that we think poses asafety or other risk to the The Roll website and e-coaching platform, otherMembers, or third parties.We processthis information given our legitimate interest in protecting the The Rollwebsite and e-coaching platform, to measure the adequate performance of ourcontract with you, and to comply with applicable laws.Provide,personalize, measure, and improve our advertising and marketingSend youpromotional messages, marketing, advertising, and other information that may beof interest to you based on your preferences (including information about TheRoll or partner campaigns and services) and social media advertising throughsocial media platforms such as Facebook or Google).Personalize,measure, and improve our advertising.Administerreferral programs, rewards, surveys, sweepstakes, contests, or otherpromotional activities or events sponsored or managed by The Roll or its third-partypartners.Conductprofiling on your characteristics and preferences (based on the information youprovide to us, your interactions with the The Roll website and e-coachingplatform, information obtained from third parties, and your search) to send youpromotional messages, marketing, advertising and other information that wethink may be of interest to you.We willprocess your personal information for the purposes listed in this section givenour legitimate interest in undertaking marketing activities to offer youproducts or services that may be of your interest. You can opt-out of receivingmarketing communications from us by following the unsubscribe instructionsincluded in our marketing communications or changing your notification settingswithin your The Roll Account.
Sharing & disclosure
With your consent Where you have provided consent, we share your information, including personalinformation, as described at the time of consent, such as when you authorize athird party application or website to access your The Roll Account or when youparticipate in promotional activities conducted by The Roll partners or thirdparties.Compliancewith law, responding to legal requests, preventing harm and protection of ourrights.The Rollmay disclose your information, including personal information, to courts, lawenforcement or governmental authorities, or authorized third parties, if and tothe extent we are required or permitted to do so by law or if such disclosureis reasonably necessary: (i) comply with our legal obligations, (ii) to complywith legal process and to respond to claims asserted against The Roll, (iii) torespond to verified requests relating to a criminal investigation or alleged orsuspected illegal activity or any other activity that may expose us, you, orany other of our users to legal liability, (iv) to enforce and administer ourTerms of Service or other agreements with Members, or (v) to protect therights, property or personal safety of The Roll, its employees, its Members, ormembers of the public.Whereappropriate, we may notify Members about legal requests unless: (i) providingnotice is prohibited by the legal process itself, by court order we receive, orby applicable law, or (ii) we believe that providing notice would be futile,ineffective, create a risk of injury or bodily harm to an individual or group,or create or increase a risk of fraud upon The Roll’s property, its Members andthe The Roll website and e-coaching platform. In instances where we comply withlegal requests without notice for these reasons, we will attempt to notify thatMember about the request after the fact where appropriate and where wedetermine in good faith that we are no longer prevented from doing so. ServiceprovidersThe Roll uses a variety of thirdparty service providers to help us provide services related to the The Rollwebsite and e-coaching platform[JW1] . Service providers may be locatedinside or outside of the European Economic Area (EEA).Forexample, service providers may help us: (i) perform product development,maintenance and debugging, (ii) conduct background or police checks, fraudprevention, and risk assessment, (iii) allow the provision of the The RollServices through third party platforms and software tools (e.g. through theintegration with our APIs), or (iv) provide customer service, advertising, orpayments services. These providers have limited access to your information toperform these tasks on our behalf and are contractually bound to protect and touse it only for the purposes for which it was disclosed and consistent withthis Privacy Policy.The Rollwill need to share your information, including personal information, in orderto ensure the adequate performance of our contract with you. Socialmedia platformsWherepermissible according to applicable law we may use certain limited personalinformation about you, such as your email address, to hash it and to share itwith social media platforms, such as Facebook or Google, to generate leads,drive traffic to our websites or otherwise promote our products and services orthe The Roll website. These processing activities are based on our legitimateinterest in undertaking marketing activities to offer you products or servicesthat may be of your interest.The socialmedia platforms with which we may share your personal data are not controlledor supervised by The Roll. Therefore, any questions regarding how your socialmedia platform service provider processes your personal data should be directedto such provider.Please notethat you may, at any time ask The Roll to cease processing your data for thesedirect marketing purposes by sending an e-mail to inca.whyte@theroll.com. BusinesstransfersIf The Rollundertakes or is involved in any merger, acquisition, reorganization, sale ofassets, bankruptcy, or insolvency event, then we may sell, transfer or sharesome or all of our assets, including your information in connection with suchtransaction or in contemplation of such transaction (e.g., due diligence). Inthis event, we will notify you before your personal information is transferredand becomes subject to a different privacy policy. AggregateddataWe may alsoshare aggregated information (information about our users that we combinetogether so that it no longer identifies or references an individual user) andother anonymized information for regulatory compliance, industry and marketanalysis, demographic profiling, marketing and advertising, and other businesspurposes.
Other important informationLinkingthird party accountsYou maylink your The Roll Account with your account at a third party social networkingservice. Your contacts on these third party services are referred to as“Friends.” When you create this link:Theinformation you provide to us from the linking of your accounts may be stored,processed and transmitted for fraud prevention and risk assessment purposes;Thepublication and display of information that you provide to The Roll throughthis linkage is subject to your settings and authorizations on the The Rollwebsite and the third party site.We onlycollect your information from linked third party accounts to the extentnecessary to ensure the adequate performance of our contract with you, or toensure that we comply with applicable laws, or with your consent. GoogleMaps/EarthParts ofthe The Roll website use Google Maps/Earth services, including the Google MapsAPI(s). Use of Google Maps/Earth is subject to Google Maps/Earth AdditionalTerms of Use and the Google Privacy Policy. Third partypartners & integrationsThe TheRoll website may contain links to third party websites or services, such asthird party integrations, co-branded services, or third party-branded services(Third Party Partners). The Roll doesn’t own or control these Third PartyPartners and when you interact with them, you may be providing informationdirectly to the Third Party Partner, The Roll, or both. These Third PartyPartners will have their own rules about the collection, use, and disclosure ofinformation. We encourage you to review the privacy policies of the otherwebsites you visit.
Your rightsYou mayexercise any of the rights described in this section before your applicable TheRoll Data Controller by sending an email to inca.whyte@theroll.com.Please note that we may ask you to verify your identity before taking furtheraction on your request. Managingyour informationYou mayaccess and update some of your information through your Account settings. Ifyou have chosen to connect your The Roll Account to a third-party application,like Facebook or Google, you can change your settings and remove permission forthe app by changing your Account settings. You are responsible for keeping yourpersonal information up-to-date. Rectificationof inaccurate or incomplete informationYou havethe right to ask us to correct inaccurate or incomplete personal informationconcerning you (and which you cannot update yourself within your The RollAccount). Data accessand portabilityIn somejurisdictions, applicable law may entitle you to request copies of yourpersonal information held by us. You may also be entitled to request copies ofpersonal information that you have provided to us in a structured, commonlyused, and machine-readable format and/or request us to transmit this informationto another service provider (where technically feasible). Dataretention and erasureWegenerally retain your personal information for as long as is necessary for theperformance of the contract between you and us and to comply with our legalobligations. If you no longer want us to use your information to provide the TheRoll website to you, you can request that we erase your personal informationand close your The Roll Account. Please note that if you request the erasure ofyour personal information:We mayretain some of your personal information as necessary for our legitimatebusiness interests, such as fraud detection and prevention and enhancingsafety. For example, if we suspend an The Roll Account for fraud or safetyreasons, we may retain certain information from that The Roll Account toprevent that Member from opening a new The Roll Account in the future.We mayretain and use your personal information to the extent necessary to comply withour legal obligations. For example, The Roll may keep some of your informationfor tax, legal reporting and auditing obligations.Because wemaintain the The Roll website and e-coaching platform to protect fromaccidental or malicious loss and destruction, residual copies of your personalinformation may not be removed from our backup systems for a limited period oftime. Withdrawingconsent and restriction of processingWhere youhave provided your consent to the processing of your personal information by TheRoll you may withdraw your consent at any time by changing your Accountsettings or by sending a communication to The Roll specifying which consent youare withdrawing. Please note that the withdrawal of your consent does notaffect the lawfulness of any processing activities based on such consent beforeits withdrawal. Additionally, in some jurisdictions, applicable law may giveyou the right to limit the ways in which we use your personal information, inparticular, where (i) you contest the accuracy of your personal information;(ii) the processing is unlawful and you oppose the erasure of your personalinformation; (iii) we no longer need your personal information for the purposesof the processing, but you require the information for the establishment,exercise or defence of legal claims; or (iv) you have objected to theprocessing pursuant to Section 7.6 and pending the verification whether thelegitimate grounds of The Roll override your own. Objectionto processingIn somejurisdictions, applicable law may entitle you to require The Roll not toprocess your personal information for certain specific purposes (includingprofiling) where such processing is based on legitimate interest. If you objectto such processing The Roll will no longer process your personal informationfor these purposes unless we can demonstrate compelling legitimate grounds forsuch processing or such processing is required for the establishment, exerciseor defence of legal claims.Where yourpersonal information is processed for direct marketing purposes, you may, atany time ask The Roll to cease processing your data for these direct marketingpurposes by sending an e-mail to inca.whyte@theroll.com. LodgingcomplaintsYou havethe right to lodge complaints about the data processing activities carried outby The Roll before the competent data protection authorities. SecurityWe arecontinuously implementing and updating administrative, technical, and physicalsecurity measures to help protect your information against unauthorized access,loss, destruction, or alteration. Some of the safeguards we use to protect yourinformation are firewalls and data encryption, and information access controls.If you know or have reason to believe that your The Roll Account credentialshave been lost, stolen, misappropriated, or otherwise compromised or in case ofany actual or suspected unauthorized use of your The Roll Account, pleasecontact us following the instructions in the Contact Us section below. Changes tothis privacy policyThe Rollreserves the right to modify this Privacy Policy at any time in accordance withthis provision. If we make changes to this Privacy Policy, we will post therevised Privacy Policy on the The Roll website and update the “Last Updated”date at the bottom of this Privacy Policy. We will also provide you with noticeof the modification by email at least thirty (30) days before the date theybecome effective. If you disagree with the revised Privacy Policy, you maycancel your Account. If you do not cancel your Account before the date therevised Privacy Policy becomes effective, your continued access to or use ofthe The Roll website will be subject to the revised Privacy Policy. Contact usIf you haveany questions or complaints about this Privacy Policy or The Roll’s informationhandling practices, you may email us or contact us at:The Roll ABEriksbergsgatan10114 30,STOCKHOLM, SWEDENCompany number:556845-3764Telephone: +46(0)70025 54 20Email: inca.whyte@theroll.com LastUpdated: April 25th, 2019 [JW1]Futureproofing or unnecessary?
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