1. IN GENERAL
1.1. MiniFinder process your personal data when you use our apps, our hardware devices or our website. The processing of your personal data takes place in compliance with the General Data Protection Regulation (“GDPR“).
2.1. Controller. The controller for the data processing within the meaning of the GDPR is MiniFinder. Should you have any questions regarding the processing of your personal data, please do not hesitate to contact us. You can contact us via email email@example.com or telephone:+46(0)470-786 833.
3. WHICH DATA WE PROCESS
3.1. In General
MiniFinder processes such personal data, that you as a user of the Products make available to us, for example by using our Products, and that others provide to us.
3.2. Data You Provide to Us
Mandatory Information: You have to provide us with certain information in order to register to use most of our products:
* Email address;
* First and last name
* Telephone number
In order to purchase a physical or digital product in the MiniFinder web shop, to order a MiniFinder Start device and/or to activate a MiniFinder GPS tracker, you have to provide additionally data, such as the following: address, post code, city, country.
Payment information: We use payment providers (e.g.PayPal, Klarna, Swish, Trustly) to process payments. Although we do not store any payment credentials information ourselves, we store a payment ID number that is given out by the respective provider and can be allocated to a person by that payment provider.
Optional Information: Certain information is optional during registration and can also be added later on by you.
3.3. Data from Others
The following personal data we retrieve from external services (without being explicitly provided by the user):
* IP address
* Language (based on the settings of the browser/mobile phone of the user)
* Country (based on the ip address)
4. USAGE OF EXTERNAL SERVICES AND DATA TRANSFER FOR THIRD PARTIES
4.1. Service Use
Opt-Out. You can prevent the collection of data through the cookie concerning your use of the Products (incl. your IP-address) as well as its processing of this data by Google, by downloading and installing the following browser plug-in: https://tools.google.com/dlpage/gaoptout?hl=en.
Anonymize IP. The Products use Google Analytics in conjunction with the option "_anonymizeIP()". This means, IP-addresses are processed in a shortened form in order to prevent transmission of any personal data. Any connection with a specific person is therefore precluded and personal data immediately deleted.
Purpose. MiniFinder uses Google Analytics to analyse and be able to constantly improve the use of MiniFinder Products. Through the statistics, MiniFinder is able to improve its services and make them more interesting for users and to optimize new features and products. In those special cases in which personal data is transmitted to the USA, Google is certified via EU-US privacy shield. The basis for the processing is Art 6 sec 1 subsec f GDPR.
For the (partially) automated handling of MiniFinder online shop orders, MiniFinder transmits for the shipping required data to the carrier of choice. MiniFinder primarily works with DHL, Fedex and the PostNord. MiniFinder will transmit required information (such as name, shipping address, email address and phone number) solely for the purpose of the fulfillment of the order.
Payment Service Provider
All payments to MiniFinder are handled by external payment providers (Such as Paypal, Klarna, Swish, Trustly etc.). In order to capture payments through external payment providers, MiniFinder transmits the following - for the payment relevant - data to the payment service provider:
* E-mail address
* First Name, Last Name
* Address, Zip Code, City, State, Country (for Fraud Detection)
* Payment Data (e.g. Credit Card Number)
MiniFinder never stores any Payment Data (e.g. Credit Card Number), but leaves this up to the carefully select payment providers who store your payment details securely.
Customer Service Software
MiniFinder offers its users of the website, the online-shop and in the MiniFinder GPS WebApp the option to Live-Chat with the customer service team. To accomplish this, the software Tawk.to is being used. All data being transmitted through the live chat, will be stored and processed by Tawk.to. Therefore personally identifiable data entered by a user will be transmitted to Tawk.to. Aside from data entered by the user, Tawk.to will automatically store the following data:
* Language (detected based on browser language)
* All personally identifying data are being processed by Tawk.to and are only used to solve customer support cases and support the customer in the Live-Chat environment.
In order to send emails (aside from newsletters) MiniFinder uses the following external software and services:
For the usage of the above service, the customers Email address, the language, First name and Last name are being transmitted to the service provider. All personally identifying data are being processed by MailChimp Service and are only used to for sending automated and automatically triggered emails.
Beside the services mentioned above MiniFinder may uses additional services to ensure high quality of all the MiniFinder products (e.g. caching services to reduce the response time of requests). It might be the case that personally identifying data is transmitted to those services. MiniFinder pares the transfer of this data down to the minimum which is required for using the services. The external services process the data on behalf of MiniFinder and do not use the data for their own benefit.
4.2. Marketing Services
MiniFinder websites and apps use retargeting technologies. This allows us to display advertising on partner websites to customers who previously were interested in MiniFinder and/or visited the MiniFinder website.
We are convinced that personalized and interest-based advertising is more interesting and relevant to our customers, compared to advertising without and relevance for the customer. Retargeting technologies analyze the information captured through interactions with MiniFinder (website, online-shop, apps) as well as through cookies, and displays advertising based on the users surf behavior online. More information about cookies can be found in section 5.
MiniFinder uses remarketing services from Google Inc. (AdWords), Microsoft (Bing) and Facebook. MiniFinder remains the right to add additional remarketing providers.
MiniFinder also works with Affiliate Marketing Services, who display advertising on partner websites. These providers can store data about your usage of the MiniFinder website and/or MiniFinder apps.
5. COOKIES AND PLUGINS
5.1. What are Cookies
If you do not want cookies, you can change your browser settings to delete or prevent certain cookies from being stored on your computer or mobile device without your explicit consent. The ‘help’ section in your browser should provide information on how to manage your cookie settings. Find out how this works for your browser here:
Internet Explorer: https://support.microsoft.com/help/17442/windows-internet-explorer-delete- manage-cookies
Mozilla Firefox: http://support.mozilla.com/en-US/kb/Cookies
Google Chrome: http://www.google.com/support/chrome/bin/answer.py?hl=en&answer=95647
6. WHY WE PROCESS DATA (PURPOSES)
6.1. Operating the Products.
We process your Data to be able to provide you with a seamless user experience when using our products.
Selling/Shipping Products. To sell and ship our physical products.
Providing Services. To operate the Products and provide the services, including to:
* Authenticate your access to an account;
* Show statistics about your device
* Log and display your position information
To investigate, respond to your requests, and resolve complaints and service issues, e.g. to contact you about a question you submitted to our customer service team.
6.2. Business Needs
We process your Data to manage our business needs, but only as long as your rights and interests do not outweigh ours. This includes advertisements and general marketing.
Performance. We process Data to monitor, analyse and improve the use of our Products and services. As well as protect the security or integrity of the Products as well as their performance and functionality. For example, we analyse User behaviour and perform research about the way you use our Services.
Research and Development. We process data, including public feedback, to conduct research and development for the further development of our Products in order to provide you and others with a better, more intuitive and personalized experience, and drive membership growth and engagement in our Products.
We process Data to market to you by delivering (tailored) marketing materials about MiniFinder products and online services or the products and services of MiniFinder.
We target and measure the performance of ads to registered users and visitors.
With your consent we will send you newsletters with relevant information.
You might see marketing messages (ads) on different platforms (e.g. Google, Facebook, …). In addition, other users who have similar traits to you on those platforms could see marketing messages on those platforms as well (i.e. Facebook Lookalike audience).
6.3. Compliance and Enforcement.
We process your data to comply with our obligations and to comply with all applicable laws and regulations.
7. NEWSLETTER /PUSH-NOTIFICATIONS
Registration / Cancellation
MiniFinder only sends newsletters in the following cases:
The user decides to register for the MiniFinder newsletter through MiniFinder website or webshop. In this case, the registration is being done with Double-Opt-In. This requires an email to be sent to the user after registration to confirm the registration, in order to avoid registration of Email addresses that are not valid or confirmed.
A link to unsubscribe from MiniFinder newsletters will be at the end of every newsletter.
Usage of Email Information System “MailChimp”
Email newsletters from MiniFinder are being sent by MailChimp, an email distribution platform by Rocket Science Group (Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA)
The email addresses of all MiniFinder newsletter subscribers as well as additional data as described in this document will be stored on servers owned by MailChimp. MailChimp uses the provided information solely for the distribution and analysis on behave of MiniFinder. Additionally, MailChimp can use the information to improve it services, e.g. optimizing their technical infrastructure and setup, visualization of newsletters or for economical reasons to detect the region of where newsletter subscribers come from.
MailChimp explicitly does NOT use the data provided, to contact any subscribers and will in no circumstance hand over the data and/or email addresses to a third party.
Statistical data analysis
Newsletters contain a so called “Tracking Pixel” which allows for statistical analysis. This “Tracking Pixel” allows to track technical information (such as Browser Version, IP-address and the point in time the document was opened. This information is being used to improve the system and service of MailChimp based on technical data or user groups, by looking how often / how long, where (location guess based on IP-address) and when an email is being read.
Part of the statistical analysis is the detection of whether an email has been read, opened and whether a link was clicked in the email. Technically this information can be correlated to a unique user, but it is neither MiniFinder’s or MailChimp’s intention to track the behavior of individual users. The analysis simply helps MiniFinder understand the reading patterns of its users and to understand whether certain topics in certain emails are more or less interesting to our users.
MiniFinder will also send you (based on you allowing this through the apps) push notifications through its mobile apps. Notifications will be related to MiniFinder products (GeoFence Alerts, Battery alerts).
You can disable push notifications for individual apps in your phone settings or uninstall the app to discontinue receiving push notifications.
8. SHARING OF PERSONAL DATA
We transmit Data to third parties only, if this is necessary for the Purposes, due to a request from a national authority, due to a court ruling, required by law, necessary to investigate and defend ourselves against any third-party claims or allegations, exercise or protect the rights and safety of MiniFinder, our members, personnel, or others, or if you have consented beforehand. We attempt to notify you about legal demands for your personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
8.2. Service Providers and other Third Party Services
We transfer your information to others, who help us to provide and improve our Products (e.g. maintenance, analysis, audit, payments, fraud detection, marketing and development). Service providers will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes. The list of our Service Providers / Third Party Service can be found in section 4.
9. HOW LONG WE STORE DATA
9.1. Storage period
We store your Data as long as you are a registered user of the Products. Beyond that, we only store Data, if it is legally necessary (because of warranty, limitation or retention periods) or otherwise required.
9.2. Account Deletion
If you decide to delete your account, all personal data we have about you will be deleted with the following exceptions:
Any details made public by you (e.g., shared routes)
Any Data required for MiniFinder’s performance of contractual obligations or compliance with statutory retention obligations, shall not be deleted but minimized to the necessary extent.
A deletion request does not affect data, if the storage is legally necessary, for example for accounting purposes.
10. WHICH RIGHTS YOU HAVE
10.1. Exercise of Rights
To exercise the rights defined in Sections 10.2 to 10.8, please send a request via e-mail to our email address or via mail to our postal address.
10.2. Revocation of Consent
You can revoke the consent for future data processing at any time. However, this does not affect the lawfulness of Data processing based on the consent before the revocation.
10.3. Right of Access
You have the right to obtain (i) confirmation as to whether or not your Data is being processed by us and, if so, (ii) more specific information on the Data.
10.4. Right to Rectification
You have the right to obtain from us the rectification of inaccurate Data concerning you. In case the Data processed by us is not correct, we will rectify these without undue delay and inform you of this rectification.
10.5. Right to Erasure
Should you decide, you do not want us to process your data any further, please contact us via mail. We’ll delete your account and erase your data. Should mandatory provisions of law prevent such erasure, we will inform you.
10.6. Right to Data Portability
You have the right to (i) receive your Data in a structured, commonly used and machine-readable format.
10.7. Right to Object
You have the right to object at any time to the processing of Data for which our legitimate interests are the legal basis, including profiling based on those provisions.
10.8. Right to Lodge a Complaint
You have the right to lodge a complaint with a supervisory authority (in Sweden: Datainspektionen), if you think that the processing of Data infringes applicable law, especially the GDPR.
11. FURTHER IMPORTANT INFORMATION
11.1. Legal Bases
Data protection laws regulate, that we are only allowed to collect and process your Data, if we have lawful bases for processing. The lawfulness of processing stems from your consent in such cases where you have given consent; the necessity for the fulfillment of your user contract, e.g. where Data is needed for a satisfactory use of the Product; or
legitimate interests pursued by MiniFinder or a third party.
Our legitimate interests include protecting you, MiniFinder, or others from security threats or fraud, complying with all applicable laws, managing and improving our business (e.g. customer service, reporting) including possible corporate transactions (e.g. M&A), enabling users to share their and connect via pet experiences, and express all pet related opinions.
11.2. Safety Measures
To avoid unauthorized access to Data and generally secure the Data, we apply the safety measures which comply with the latest technological developments.
11.3. Usage of Minors
Users under the age of 18 are not allowed to transmit any personally identifying information to MiniFinder, without the consent of their legal guardian.
12.2. Material Changes
12.3. Last Updated