GUGO's privacy policy

1. Introduction

Gugo AB is mindful of the user's privacy and seeks to ensure that the personal data of users is processed correctly and in accordance with applicable data protection legislation. Acceptance of this privacy policy (the "Privacy Policy") is an act of consent and means that users agree to Gugo AB's processing of personal data.

2. The Privacy Policy’s area of application

2.1 Scope

This Privacy Policy applies to our users and collaboration partners.

Gugo AB’s Privacy Policy governs how Gugo AB collects and processes personal data for our activities that include handling personal data to market our collaboration partners to their target groups/potential users (the "Service").

The policy also governs the handling of personal data for individuals by those parties with which Gugo AB has a commercial relationship, such as collaboration partners.

3. Processing of personal data

How Gugo AB handles personal data is described below.

3.1 For Gugo AB’s users

3.1.1 The purposes of processing personal data

Personal data is only processed for the purposes and objectives described in this Privacy Policy. If users choose not to provide Gugo AB with certain personal data, this can have an impact on the Service. Gugo AB only processes personal data to the extent that such processing is necessary for the Service or for other purposes described below. This also applies to sensitive personal data.

Gugo AB processes users’ personal data to be able:

(a) to provide the Service to our users and offer the option to become acquainted with the service.

(b) to contact users through such means as newsletters, marketing and advertising material and provide other information that may be of interest to the user. The user can choose not to receive some or all notifications from Gugo AB by following the "unsubscribe" link or the instructions in the email notification that has been sent.

3.1.2 Personal data

By approving this Privacy Policy, users consent to Gugo AB processing personal data in accordance with this Privacy Policy.

Below you will find information regarding the type of personal data processed by Gugo AB and how Gugo AB can receive/collect this information.

3.1.2.1 Users

The personal data processed by Gugo AB about users stems from the information provided to Gugo AB by our users via the internet or by contacting our staff for our provision of the Service.

The personal data about users that may be processed by Gugo AB comprises data such as their name, personal identification number, telephone number and email address.

Gugo AB can also ask users to provide additional information. In such cases, special approval shall be obtained from users. Personal data provided/processed after special approval shall also be covered by this Privacy Policy.

3.1.2.2 Collaboration partners

Gugo AB can process the personal data of contact persons and other employees. Such personal data consists, inter alia, of the information specified in section 3.1.2.1 and other information necessary for

the provision and monitoring of the Service, in order to ensure good delivery of services and to enable future business relations.

3.2 Storage of personal data

How long personal data is stored depends on the nature of the personal data and the purpose of its processing. Gugo AB dos not store personal data for longer than necessary with respect to the purposes for which the personal data was collected.

As a general rule, Gugo AB shall store personal data that concerns:

(a) information in accordance with section 3.1.2.1 concerning users for the current year and then for a period of ten (10) years;

(b) user and collaboration agreements and information about commercial events, for the term of the agreement and then for ten (10) years.

4. Cookies and analyst services

4.1 Cookies

Gugo AB uses cookies on its website. A cookie is a small text file that the website sends to and stores on the user’s computer or other device used to access the website. Gugo AB uses cookies to optimise the users’ experience on the website. Information received via cookies can also be used for marketing and communication purposes.

Gugo AB, and our collaboration partners, use cookies to inform, optimise and display advertising

based on the user’s previous visits to our service.

By surfing on our websites, users accept our use of cookies. However, users can clean cookies from web reader settings after visiting our website or, if the user so desires, disable them altogether.

However, please note that cookies enable certain functions on our websites and thus Gugo AB cannot guarantee that all functions on our websites will work as intended if cookies are not enabled.

4.2 Analyst services

Analyst services that are provided by third parties are used on Gugo AB’s websites. Amongst other things, these analyst services collect the user's IP address and information about use and the traffic on our website in order to help Gugo AB develop and better customise our services.

4.3 Links to third parties

Gugo AB’s service includes links to other websites that are not operated by Gugo AB. If users click on a third-party link, users will be directed to the third party's website. Gugo AB has no control over and accepts no liability for the content, confidentiality and privacy policy or the operation of third- party websites or services.

5. Responsibility for personal data

Gugo AB has carried out appropriate technical and organisational measures to protect personal data from loss, misuse, unauthorised access, disclosure, alteration and destruction.

Gugo AB’s employees are bound by confidentiality and are responsible for complying with Gugo AB’s regulations for information and IT security and this Privacy Policy.

6. Sharing of personal data with third parties

Gugo AB will not sell, disclose or share personal data with third parties, except as stated in this Privacy Policy. Within the framework of the Service, personal data can be disclosed to a user or collaboration partner if this is necessary for the implementation and provision of the Service.

Gugo AB can also disclose personal data to another third party, such as Gugo AB's collaboration partners, for purposes such as administration, technical support and operation of the IT system. Parties that Gugo AB may disclose personal data to can be outside the European Economic Area, EEA, which means that personal data may be transferred to non-EEA countries. If Gugo AB discloses personal data to a partner outside the EEA, Gugo AB shall take steps to ensure that the personal data remains protected and shall also take the steps required for the legal transfer of personal data to non-EEA countries.

In addition, Gugo AB may disclose personal data if Gugo AB is required to do so under applicable law, by a court order or if disclosure is otherwise necessary to participate in a legal investigation. In the event that Gugo AB is subject to a reorganisation, merger or sale, Gugo AB may transfer personal data to the relevant third party, provided that the third party undertakes to process the personal data in accordance with this Privacy Policy.

7. Gugo AB as personal data processor

Gugo AB is the personal data controller for certain personal data, but situations may occur in which Gugo AB is not the personal data controller but the personal data processor for third parties.

When Gugo AB processes personal data as a personal data processor, it does so on behalf of third parties, and Gugo AB is then bound by the instructions given to Gugo AB by the person data controller. In these situations, Gugo AB cannot guarantee that such processing will be in accordance with this Privacy Policy, but Gugo AB will always ensure that processing is in accordance with applicable law and, as far as possible, in accordance with this Privacy Policy.

8. The user's rights

After making a written application to Gugo AB, the user has the right to receive, free of charge, information about what information is processed by Gugo AB, and about the scope and purpose of such processing.

The user is also entitled to request that Gugo AB blocks, deletes or rectifies personal data. The user is always entitled to revoke consent granted and to notify that users oppose continued processing of personal data.

9. Changes to this Privacy Policy

Gugo AB reserves the right to revise this Privacy Policy from time to time. The date of the last update is shown at the end of the Privacy Policy. If Gugo AB makes any changes to this Privacy Policy, Gugo AB shall publish these on its website.

If you have any questions regarding Gugo AB’s processing of personal data, please contact Joakim Hellström, MD of Gugo AB, at [email protected]

10. Disputes

Disputes Privacy Policy shall be settled by Swedish public court in which Swedish law shall be applied. For any interpretation of this Privacy Policy, its original language shall apply.