Effective Date: April 16, 2018
Updated January 4, 2023
1. Websites Covered
2. Information We Collect
We collect the following data about users: (1) information that you voluntarily submit to us (“User-Supplied Information”); (2) technical data automatically collected from all visitors to the Gearwise AB Website (described below under “Passive Data Collection”); (3) information we collect through our Services; and (4) information we collect from third party sources.
User-Supplied Information. We may collect user-supplied information when you choose to provide us with your Personal information via the Gearwise AB Websites, including when you send us an email asking a question, register to attend an event, submit a form to receive marketing materials or email newsletters, or request any research or whitepapers.
3. Use of Collected Information
We use personal information to establish and enhance our relationship with you. We may use personal information to operate, provide, improve, and maintain the Gearwise AB Websites; to prevent abusive and fraudulent use of the Gearwise AB Websites; to personalize and display content on the Gearwise AB Websites; where permitted by applicable law, to send you information, including via email, about our products and Services in which we believe you may be interested; to respond to your inquiries and for other customer service purposes; and for other administrative and internal business purposes.
We may use your e-mail address, including any email address provided at www.gearwise.se or through the Gearwise AB Websites as set forth in the “Communications and Unsolicited Marketing Communications” section.
On the Gearwise AB Websites, we may use passively collected data to: (a) remember your information so that you will not have to re-enter it during your visit or the next time you visit the Gearwise AB Websites; and (b) monitor aggregate website usage metrics such as total number of visitors and pages viewed.
4. Disclosure of Collected Information
We do not sell or rent email addresses and other personal information that we collect directly through the Gearwise AB Websites. Please be aware, however, that any information that you voluntarily choose to display on any publicly available portion of the Gearwise AB Websites, or on any Service, becomes publicly available and may be collected and used by us or others without restriction. We share your information, including personal information, as follows:
Gearwise AB Service Providers
We may disclose personal information if we have a good-faith belief that doing so is required by a subpoena or other judicial or administrative order or otherwise required by law. Additionally, we may disclose personal information where we, in good faith, deem it appropriate or necessary to prevent violation of the Gearwise AB Terms of Service, or our other agreements; take precautions against liability; protect the rights, property, or safety of Gearwise AB, any individual, or the general public; maintain and protect the security and integrity of our Services or infrastructure; protect ourselves and our Services from fraudulent, abusive, or unlawful uses; investigate and defend ourselves against third-party claims or allegations; or assist government enforcement agencies.
Aggregate Information and Non-Identifying Information
We may share aggregated information with Clients, prospective Clients, partners or the press in order to demonstrate usage of the Service, identify industry and advertising trends, and to generate publicity for the Gearwise AB Services.
5. Your Choices
On the Gearwise AB Websites
You may, as a visitor to our website, choose not to provide us with personal information. You may also, at any time, access your personal information to update, correct, or delete certain personal information about you by contacting us at firstname.lastname@example.org or at the address set forth below in the “Contact Us” section. You also have the right to obtain from Gearwise AB the erasure of personal data about you in accordance with applicable data privacy laws. You may exercise your rights with the following requests:
Exercise Your Rights
In addition you may decide not to opt–in, either when you first provide Gearwise AB with any personal information, to receive marketing information from Gearwise AB about products and Services (including our products and Services and those of third parties). See also Section 6, “Communications and Unsolicited Marketing Communications”, for additional information regarding changing your preferences or opting out of receiving marketing information.
Please be aware that even if you update or remove personal information that you have provided to us, your personal information may be retained in our backup files and archives for a reasonable period of time for legal purposes.
6. Communications and Unsolicited Marketing Communications
If you opted in to receive communications from us, including through email@example.com, we may send you administrative messages and updates regarding your account, updates regarding the Gearwise AB Websites, and, where permitted by applicable law, information regarding our offer, products and Services, including, without, limitation, through social media updates, by email and postal mail. If you no longer want to receive commercial email messages, you may indicate your preferences regarding commercial email messages by taking the steps described in such messages. Also, you may indicate your preferences regarding commercial email messages and postal mail messages by contacting us using the information in the “Contact Us” section below.
7. Client Data
We collect, use, and retain certain information at the direction and on behalf of our Clients from individuals (“End Users”) who use the Client website (Client Data). Gearwise AB has no relationship with such End Users whose Client Data we process on behalf of our Clients. We also do not decide how the Clients use such Client Data. Gearwise AB does not access and use the Client Data, except at directed by our Clients or required by law.
Information Collected Directly Through Use of the Services about End Users: We collect two types of data about End Users: (1) information that is passed through the Service as a result of use of the Website and (2) technical data automatically collected from all visitors to pages of your website that load the Services. The information that we collect on your behalf depends on the particular Services to which you subscribe and your preferences. Social network and/or identity providers are hosted by a third party and on our Client’s service. The Client’s and the End User’s interaction with these features are governed by the privacy statement of the company providing it.
End User Information: We maintain no rights to use any End User Personal Information transmitted to us on your behalf through the Gearwise AB Website or received from the social networks, except to make the Services available to you and/or End User.
We use the information that we collect automatically about the use of our Website to facilitate delivery of the Service and, in some cases, for internal reports. Additionally, some of the information collected is used in the Client Reports. The Client Reports may contain both passively-collected information and End User Personal Information.
If you are a customer of one of our Client’s, and you want to edit or delete any information captured about you on that Client’s website, you should contact the Client directly.
8. International Users
The Gearwise AB Websites are hosted in Sweden, and we may use service providers in the United States and elsewhere to process personal information on our behalf. If you use the Gearwise AB Websites outside the U.S., please note that your personal data may be transferred outside of your home jurisdiction to the United States and to other jurisdictions where our affiliates and service providers are located. Some of these jurisdictions, including the United States, do not have equivalent data protection laws as the European Union and other jurisdictions. By using our Websites, you are agreeing that your personal data may be transferred to the United States and other jurisdictions, as explained in this Section.
9. EU, Switzerland and the Data Privacy Shield Framework
Gearwise AB complies with the E.U.- U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information obtained from European Union member countries and Switzerland. Gearwise AB is a sub-processor for Clients websites that utilize our Services and certifies its processing of personal information from E.U. member countries and Switzerland is in accordance with the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement and Liability (the “Principles”).
Information We Process. We collect, in accordance with the Privacy Shield principles, the categories of information described in sections 2 and 7 above. We process personal information about website users for the purposes described in section 3 above. Please note: additional information about Gearwise AB’s participation in the Privacy Shield program, with regard to data collected in a capacity as a processor to our Clients, is available by contacting firstname.lastname@example.org.
E.U. and Swiss End Users whose personal information we process on behalf of a Gearwise AB Client (as a data processor) should first contact the Gearwise AB Client, who is the controller of your personal information, to access their personal information; Gearwise AB will work with its Clients to provide End Users the necessary access about what personal information is processed.
Transfers to Third Parties. As described in the “Disclosure of Collected Information” section above, we may transfer personal information from the E.U. and Switzerland to third parties. We contractually require third parties to whom we transfer personal information to provide the same level of protections as the Principles. Gearwise AB remains responsible for the personal information we receive and transfer under Privacy Shield as it relates to our Services.
In accordance with our legal obligations, we may also transfer, subject to a lawful request, personal information to public authorities for law enforcement or national security purposes.
Contacting Us, Complaints and Dispute Resolution. E.U. and Swiss individuals who have questions or complaints about how we process their personal information may contact us at email@example.com. We will work to resolve your issue and respond no later than 45 days of receipt.
The security of your information is important to us, including, but not limited to, the personal information collected via the Gearwise AB Websites and Services. We use reasonable security measures to protect against the loss, misuse, and alteration of Personal information under our control, both during the transmission and once we receive it. This includes, but is not limited to, the use of firewalls and encryption. Although we make good faith efforts to maintain the security of such personal information, no method of transmission over the Internet or method of electronic storage, is 100% secure and we cannot guarantee that it will remain free from unauthorized access, use, disclosure, or alteration. Further, while we work hard to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent “hackers” or other unauthorized persons from illegally accessing or obtaining this information.
If we learn of a security breach involving your personal information, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Gearwise AB Websites or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Gearwise AB Websites. If a security systems breach occurs, we may post a notice on our homepage (www.Gearwise.se) or elsewhere on the Gearwise AB Websites and may send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach, involving your personal information, in writing. This notice paragraph applies to users of the Gearwise AB Websites and our Clients who utilize our Services on their third party websites only. Should there be a breach that affects End Users of Clients, the Client will be responsible for disseminating notice of such a breach to those End Users.
The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. Gearwise AB’s Websites are not directed toward individuals under the age of thirteen (13), and we request that such individuals do not provide personally identifying information through our websites. Additionally, we do not knowingly collect or maintain personal information from anyone under the age of 13, unless or except as permitted by law. If we learn that personal information has been collected from a user under 13 years of age on or through the Gearwise AB Websites, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has registered on the Gearwise AB Websites or you believe has otherwise provided personal information to Gearwise AB, please contact Gearwise AB at firstname.lastname@example.org to have that child’s account terminated and information deleted.
In addition, we use Google Analytics to analyze our users’ use of the Gearwise AB Websites. Google Analytics is currently on www.Gearwise.se and www.gearwise.se. Google Analytics provides us with aggregated data in order to help us make informed business decisions. Ultimately, Google, as a third party, controls information collected through Google Analytics and you should check and be comfortable with its privacy practices prior to using the Gearwise AB Websites. You may review information about Google’s privacy practices with respect to Google Analytics at http://www.google.com/analytics/learn/privacy.html.
13. Third-Party Ad Networks
You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information regarding this practice by NAI members and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: www.networkadvertising.org/optout_nonppii.asp (NAI) and www.aboutads.info/choices (DAA).
Opting out of one or more NAI member or DAA member networks (many of which will be the same) only means that those members no longer will deliver targeted content or ads to you. It does not mean you will no longer receive any targeted content or ads on our Site or other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI’s and DAA’s websites accessible by the above links.
15. Contact Us
Domnarvsgatan 2F, Spanga