Privacy Policy

1. GENERAL

1.1
This privacy policy (the "Privacy Policy") always applies, unless otherwise agreed in writing, between the service Humbo and the user (“You” or the "User") of its digital products such as the website humbo.io, as well as all content, products and services available from Humbo (collectively, the “Services”).

1.2
Humbo (“We” or “Humbo”) process personal data in accordance with legislation applicable at each time. This means, among other things, that we protect your personal data with the necessary measures and that you always have the right to contact us to find out what personal data we have stored about you. We process the personal data provided to us and/or collected by us. It can be, for example; name and email address. Your personal data may be processed by us in order to contact you, to fulfill our obligations to you as a User, to provide well-functioning, efficient and simple services, to enable good support and services, to comply with applicable legislation, to send relevant information and marketing offers on our services or to use as a basis for invoicing and accounting. You can read more about your rights in the policy below.

1.3
By using the Services, the User agrees to Humbo's processing of the User's personal data in accordance with this Privacy Policy, where the processing is needed for Humbo to provide the Services to the User. If the User does not provide the required information or explicit consent when needed, the User may not be able to access the Services or part of the Services.

1.4
If You have any questions about our processing of personal data, you are always welcome to contact us at [email protected]

2. PERSONAL DATA

2.1
Personal data refers to any information that can be attributed to an identified or identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data.

2.2
Humbo does not process any User sensitive personal data. Sensitive personal data refers to data which reveals a User's ethnic origin, political opinions, religious beliefs or membership of the trade union, as well as personal data relating to health or sex life.

2.3
Humbo is the personal data controller responsible for the processing of your personal data and is responsible for the legal processing of such data.

2.4
Humbo undertakes all appropriate technical and organizational security measures, that are required in accordance with applicable regulatory frameworks governing the processing of personal data, to ensure a high level of security appropriate to the risks and to protect the personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to processed personal data.

2.5
The purpose of processing the personal data is to enable Humbo to offer the Services in full, provide information about the Services and market the Services. Humbo collects and processes the User's personal data only to the extent it is necessary to provide the Services to the User.

2.6
The collection and processing of the User's personal data is conducted solely with the User's consent or on the premise of an existing agreement or legal obligation, e.g. when Humbo must save the data according to accounting rules. Exceptions are made for cases where a prior consent is not possible for practical reasons, the processing of the data is permitted by law, and Humbo has a legitimate interest in processing the personal data, e.g. for providing the Services, marketing, follow-up of the Services, or for defending Humbo against legal claims, according to a so called balance of interests.

2.7
Humbo processes the personal data to administer the User's user account and to be able to offer the Services to the User. The legal basis for the processing is Humbo's contractual relationship with the User in accordance with Humbo's Terms of Service.

2.8
When a User contacts Humbo, Humbo saves the personal data that Humbo needs to be able to provide support as part of the Services, administer support and complaint cases and be able to contact the User. In addition to Personal data, Humbo may process personal data relating to case/ticket numbers. The legal basis for the treatment is Humbo's contractual relationship with the User in accordance with Humbo's Terms of Service.

2.9
Humbo processes the User's Personal data for direct contact with the User via email, in order to conduct user research or to deliver updated user terms, newsletters etc. The legal basis for the processing is a so-called balance of interests.

2.10
Humbo may process the Personal data to fulfill its legal obligations based on legal requirements, judgments or decisions by authorities etc. In such cases, the legal basis for the processing is Humbo's legal obligation.

3. STORING OF PERSONAL DATA

3.1
We only store your personal data as long as it is necessary for us to fulfill the purpose of the processing in each case. We will otherwise delete personal data in the manner that follows from applicable legislation, where an examination is made on a case-by-case basis when different types of personal data should be culled.

3.2
If you choose to deactivate your user account, your personal data will be deleted or de-identified no later than 30 days from the deactivation of the account. This is provided that the personal data is not required to be saved in the future in order for Humbo to fulfill its legal obligations or to be able to exercise its legal claims.

4. USER RIGHTS

4.1 The right to request information:
You have a right to, once a year, request and obtain, free of charge, information regarding what personal data about You (if any) that is being processed by Humbo, a so-called register extract. If You repeatedly send requests for an extract from the register, Humbo may charge a fee or, in some cases, in accordance with statutory law, refuse to comply with the request.

4.2 The right to rectification:
In order to fulfill its obligations to always have accurate and relevant personal data, Humbo systematically works with its registers and updates personal data where necessary. If You notice that the personal data Humbo processes is incorrect or if Humbo lacks important personal data, You have the right to have your personal data corrected.

4.3 The right to erasure:
You have the right to request that Humbo erases your personal data when they are no longer needed for the purposes for which they have been collected and for which they are being processed or when the consent or interest upon which the processing is based ceases to exist.

Humbo has the right to refrain from erasing your personal data if Humbo needs to retain these in order to fulfill a legal obligation or to be able to make legal claims against You or in defense against legal claims from You.

4.4 The right to restriction of processing:
You have the right to request the restriction of Humbo's processing of your personal data when You oppose that the personal data is deleted and instead request a limitation of its processing, for example when You need the personal data to be able to determine, enforce or defend legal claims. Restriction of processing implies that the personal data will be marked, so that it in the future may only be processed for certain limited purposes.

4.5 The right to withdraw consent and object to processing:
You have the right to object to Humbo's processing of your personal data which Humbo conducts with the support of so-called balancing of interests according to law. If You wish to exercise this right, You need to specify in writing which processing You object to. In the event of such an objection, Humbo may only continue to process your personal data if Humbo can show that there are compelling, entitling reasons for why the personal data must be processed, and provided such reasons weigh heavier than your interests.

If your personal data is processed for direct marketing, You always have the right to object to the processing at any time.

4.6 The right to data portability:
If You have provided your personal data to Humbo, You may, in some cases, be entitled to extract your personal data. In order for You to be able to use the right to so-called data portability, your request must relate to personal data that you have yourself provided to Humbo and which Humbo processes with your consent or to fulfill an agreement with You. The right to data portability does not apply when Humbo's processing of your personal data is based on a balance of interests or a legal obligation for Humbo. The right to data portability does not apply when data portability is technically difficult to implement.

4.7 The right to complain:
In the event that You have complaints or objections in connection with Humbo's Processing of your personal data, Humbo kindly asks You to initially contact Humbo, so that Humbo can help You in the best way possible. However, You always have the right to submit your complaints directly to the Swedish Data Protection Authority (Datainspektionen).

5. SUB PROCESSORS AND THIRD PARTIES

5.1
Without the User's explicit permission, Humbo will not share the User's personal data with any third party in any other way than what follows from this Privacy Policy, unless Humbo is obliged to do so following the applicable regulations or unless the personal data is shared in connection with an ongoing legal-, administrative- or recovery procedure in which the User and Humbo are both parties. Humbo never discloses, sells or exchanges the User's personal data for marketing purposes to third parties.

5.2
Humbo uses sub processors for services in connection with Humbo's Services (so called personal data assistants). These sub processors may handle personal data and may need some access to personal data collected through the Services. Humbo may also need to use the subcontractor's services to store personal data. Humbo will always limit such sub processors' access to personal data to the minimal amount needed for Humbo to still be able to offer the User access to the Services. Humbo also requires all sub processors to (i) protect the User's personal data in accordance with this Privacy Policy and (ii) not use or disclose the User's personal data for any purpose other than to provide the agreed upon services to Humbo, enabling Humbo to offer access of the Services to the User. These sub processors may only process the User's personal data in accordance with Humbo's instructions and may not use the User's personal data for any other purpose.

5.3
This is a list of the sub processors Humbo uses to support the Services that handle personal data:

Twilio Sendgrid (USA) - delivers email and thus temporarily processes Users' email addresses. Headquarters: Denver, Colorado, United States.
EU-U.S. Data Transfers: Protected by Standard Contractual Clauses

Amazon Web Services (Luxembourg) - hosts images at a data center in Frankfurt, Germany. Headquarters: Seattle, Washington, United States
EU-U.S. Data Transfers: Protected by Standard Contractual Clauses

mongoDB (Ireland) - hosts databases at a data center in Dublin, Ireland. Headquarters: New York, New York, United States
EU-U.S. Data Transfers: Protected by Standard Contractual Clauses

6. COOKIES

6.1
Our website uses small text files, so-called cookies, to facilitate your browsing the site. Humbo only uses essential cookies that are necessary to provide an ‘information society service' (i.e. a service delivered over the internet, such as a site or an app) requested by You, the User. This includes, but is not limited to, cookies to keep track of your choice of dark or light mode and to be able to keep you signed in if you have a user account on Humbo, to provide and secure our website, as well as to analyze the usage of our website, in order to offer you a great user experience.

The Services uses persistent cookies and session cookies. Persistent cookies are stored on your computer for a fixed amount of time until you or the server erase them. Session cookies are temporarily stored on your computer and deleted when you close your browser.

By using the Services, you consent to Humbo using cookies in the manner set out in this Privacy Policy. No personal or sensitive information is stored in the above cookies.

In case you do not want to accept cookies, your browser can be set to automatically deny the storage of cookies or be informed every time a website requests to store a cookie. The browser can also delete previously stored cookies. Please note that cookies are a prerequisite for the Services to function properly.

7. UPDATES AND CONTACT INFORMATION

7.1
We make continuous changes to this Privacy Policy. A new version becomes applicable when made available here on our website.

Please contact us if you have any questions about our processing of your personal data. Questions and requests for register extracts, information, correction of incorrect data or deletion of data are sent to: [email protected]

Since it is important that We do not disclose your personal data to anyone but You, any request must be made in writing, signed by You, scanned and sent by email to Humbo. To the request, you shall also attach a copy of a valid ID document, i.e. passport or driving license.

7.2
This Privacy Policy is valid from 2020-11-08.