This document describes how Legacies AB, company registration number 559463-8198 having its registered address at Vikingagatan 27 Lgh 1305, 113 42 Stockholm (“Legacies”, “we” or “us”) collects, uses and processes Personal Data (“Privacy Policy”). This Privacy Policy is applicable when you use the Legacies platform (the “Service”), provided through our mobile application (the “App”). Information about the Service is provided on our webpage (the “Webpage”).
All definitions in this Privacy Policy shall be interpreted in accordance with applicable data protection laws which refers to the General Data Protection Regulation (Regulation no. 2016/679) and the Directive on Privacy and Electronic Communications (Directive 2002/58/EC), as well as the national implementations and related national legislation.
DATA PROCESSED
We will process the following personal data when you create an account on the Service and throughout your usage of the Service.
name;
email address;
date of birth;
telephone number;
pictures of the data subject;
information about your use of the Service;
content that you post, upload and/or contribute to the Service;
purchase information;
personal data included in your will and other documents uploaded to the Service;
We are unable to provide you with the Service unless you provide us with the personal data above e.g. the processing of the personal data above is necessary to enter into the terms of use with us and is necessary to maintain the contractual relationship between you and us. This, however, does not apply to personal data included in your will and other documents uploaded to the Service, which is an optional feature, as well as purchase information which will only be processed if you choose to pay for premium features.
We may also process your personal data if your personal data is contained in content uploaded to the Service as described above, for example if you are included in a user’s will. Personal data of other people than users with registered accounts is also processed when users appoint their guardians. Only people appointed by the user as guardians will be able to access and view the content of the user's account. Guardians must create their own accounts in order to access this content. Information on how to create an account will be sent to guardians along with a link to this Privacy Policy.
PURPOSES OF PROCESSING
We will process the personal data set out above for the following purposes:
to administer your account, to enable and provide the Service, and to provide, personalize and improve your experience with the Service, and to otherwise provide the Service according to the terms of use;
to send you alerts or messages by email or otherwise, including to provide you with marketing of our Service;
to inform you about updates of the Service or the terms of use;
to improve and develop the Service or new services and products and to analyse your use of the Service;
to ensure the technical functioning of the Service and to prevent use of the Service in breach of the terms of use;
to enforce the terms of use, including to protect our rights, property and safety and also the rights, property and safety of third parties if necessary;
to enable payment for premium features within the Service; and
to to fulfil requirements by law.
Prior to any processing of personal data for a purpose other than the purposes mentioned above, we will provide you with information on that purpose and any other relevant information.
LEGAL GROUND
The processing of your personal data for the purposes of supplying you with the Service and carrying out our obligations under the terms of use, is conducted on the basis of fulfilment of contract. Furthermore, the processing of your personal data for the purpose of enabling payment for premium features within the Service is conducted on the basis of fulfilment of contract.
The processing of your personal data for the purposes of improving and developing the Service or new services and products and to analyse your use of the Service, is conducted on the basis of the legitimate interest of Legacies. Our legitimate interest for the processing is improving the Service which includes, among other things, the functioning of the Service and maintaining sufficient IT-security.
We are processing your personal data to fulfil our legal requirement to fulfil legal requirements relating to consumer rights, payment, accounting and tax legislation.
DISCLOSURE OF PERSONAL DATA
We may share and disclose your personal data to cloud computing service providers to store information enabling the usage of the Service. We may also share and disclose your name to payment platform providers to enable payment of premium features within the Service.
Our current cloud computing service provider is located outside the EU/EEA and we are therefore applying a relevant safeguard in the form of the EU-U.S. Data Privacy Framework for the data transfers to this recipient. You can acquire further information regarding the transfer by contacting us at info@getlegacies.com.
When using the Service you may be directed to other websites where the personal data collected is not in our control. The privacy policy of the other website will govern the personal data obtained from you on that website.
RESPONDING TO LEGAL REQUESTS AND PREVENTING HARM
We may access, preserve and share your personal data in response to a legal request (like a search warrant, court order or a subpoena or the like), or when necessary to detect, prevent and address fraud and other illegal activity, to protect ourselves, you and other users, including as part of investigations.
RETENTION
We store your personal data for as long as it is necessary to fulfil our contractual obligations to you and to comply with applicable law. We will not store your personal data if you request its erasure, unless storage is required by applicable law. Please see Section 10 below for more information on your rights.
CHILDREN
The Service is not directed to persons under the age of thirteen (13). If you are a parent or guardian of a person under the age of 13 and you become aware of that the child has provided personal data to us without your consent, please contact info@getlegacies.com to exercise your access, rectification, erasure, limiting of processing and objection rights.
YOUR RIGHTS
You have the right to request access and further information concerning the processing of your personal data, or request that we correct, rectify, complete, erase or restrict the processing of your personal data. You have the right to obtain a copy of the personal data that we process relating to you free of charge once (1) every calendar year. For any additional copies requested by you, we may charge a reasonable fee based on administrative costs.
If the processing is based on the legal ground fulfilment of contract, you have the right to data portability. Data portability means that you can receive the personal data that you have provided to us, in a structured, commonly used and machine-readable format, and have the right to transfer such data to another data controllers.
CONTACT INFORMATION
To exercise your rights, or if you have any questions regarding our processing of your personal data, please contact us at the following address: info@getlegacies.com or Legacies AB, Vikingagatan 27 Lgh 1305, 113 42 Stockholm. In your letter/email please state your full name and what your request concerns (including what personal data is concerned and what right you would like to exercise). Note that you should sign the request to receive information of the processing of your personal data yourself.
If you have any complaints regarding our processing of your personal data, you may file a complaint to the competent data protection authority. You can find out more about the local data protection authorities under the following link http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
CHANGE OF CONTROL
If there is a change of control in our business, we may transfer your information to the new owners for them to continue to provide the Service. The new owners shall continue to comply with the commitments we have made in this Privacy Policy.
NOTICE OF CHANGES TO THE PRIVACY POLICY
If we make changes to this Privacy Policy, we will notify you by email. If your consent is required due to the changes, we will provide you additional prominent notice as appropriate under the circumstances and, ask for your consent in accordance with applicable law.
