- Who is the Data Controller?
TROOPR AB, with registration number 559284-1117 and postal address Vadarvägen 20, 731 42 Köping (referred to as “we,” “us,” “the company,” or “TROOPR” in this policy), is the data controller for the processing of your personal data when TROOPR provides and markets services and during other contacts with TROOPR, such as visiting our website or contacting us through email, chat, or phone. As the data controller, it is TROOPR’s responsibility to ensure that your data is handled correctly and securely according to applicable legislation.
- What Information Does TROOPR Collect?
TROOPR collects information about you when you create an account with us or communicate through our services. We also collect information generated when you use our services, such as access logs, and information from third parties, such as when you access our services through a social media account.
When you create an account, you provide at least your login credentials and basic information required for the service to function, such as your fitness interests, gender, and birthdate.
When filling out your profile, you can share more information with us, such as details about your personality, lifestyle, interests, and other details, including content like images and videos. To add certain types of content, such as images and videos, you need to grant us access to your camera or photo album.
When subscribing to a paid service or making a purchase directly from us (rather than through a platform like iOS or Android), you provide us or our payment service provider with information such as your payment or credit card number or other financial information.
When participating in surveys or focus groups, you provide your opinion on products and services, answer questions, and make statements.
When choosing to participate in our campaigns, events, or contests, we collect information you use to register or participate.
If you contact our customer service, we collect the information you provide during the interaction. Sometimes, we may monitor or record these interactions for training purposes and to ensure service quality.
If you ask us to communicate or otherwise process information about other individuals (for example, if you ask us to send an email to one of your friends), we collect information you provide about other individuals to facilitate this.
To operate the services, we also naturally collect your chats with other users and content you post.
Information We Receive From Others:
In addition to the information you provide directly, we receive information about you from others, including:
Other Users: Other users may provide information about you when they use our services. For example, we may collect information about you from other users if they contact us regarding you.
Social Media: You may use social media logins (such as your Facebook login) to create and log in to your TROOPR account. This allows you to avoid remembering another username and password and enables you to share certain information from your social media account with us.
Other Partners: We receive information about you from our partners, such as when TROOPR ads are displayed on our partners’ websites and platforms (and they provide information about the campaign’s performance).
Information Collected When You Use Our Services:
When you use our services, we collect information about which features you have used, how you used them, and which devices you used to access our services. More information is provided below:
Usage Information: We collect information about your activity on our services, such as how you use them (e.g., the date and time you logged in, features you used, searches, clicks, and pages shown to you, the web address of the page you came from, and which ads you clicked on) and how you interact with other users (e.g., users you contact and interact with, the time and date of your messages, and the number of messages you send and receive).
Device Information: We collect information from and about the devices you use to access our services, including:
Information about the hardware and software, such as IP address, device ID, device type, settings and choices on the device and in the app, app crashes, advertising IDs (such as Google’s AAID and Apple’s IDFA, both of which are randomly generated numbers you can reset through your device settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technology that can identify your unique device or browser (e.g., IMEI/UDID and MAC address).
Information about device sensors such as accelerometers, gyroscopes, and compasses.
Other Information with Your Consent: If you give us your consent, we may collect your precise geolocation (latitude and longitude) in various ways, depending on the service and device you use, including GPS, Bluetooth, or Wi-Fi connections. If you have expressly consented to the collection of your geolocation, it may occur in the background even if you are not using the service. If you decline the collection of your geolocation, we will not collect it. Similarly, we may collect your photos and videos (e.g., if you want to post a photo or video or want to stream in the services).
- Cookies and Other Similar Data Collection Technologies
TROOPR uses, and may allow others to use, cookies and similar technologies (e.g., tracking pixels) to identify you and/or your devices.
- How Do We Use Your Information?
The main reasons we collect your information are to provide and improve our services. Additionally, we use your information to help you stay secure and to show ads that might be interesting to you. Continue reading for a more detailed explanation of the various reasons we use your information, along with practical examples.
To Administer Your Account and Provide Our Services:
To create and manage your account.
To provide customer support and respond to your inquiries.
To complete your transactions.
To communicate with you about our services, including managing purchases and billing.
To Help You Communicate with Others:
To analyze your profile, service activity, and preferences to recommend meaningful contacts for you and to recommend you to others.
To display users’ profiles to each other.
To ensure you have a consistent experience on different devices:
To Link Different Devices:
To provide you with a consistent experience when using the service. We do this by linking devices and browser data, such as when you log into your account on different devices or by using an incomplete or complete IP address, browser version, and similar data about you and your devices to help identify and link them.
To Provide New TROOPR Services:
To register you and display your profile on new features and in new apps from TROOPR.
To administer your account on such new features and in such new apps.
To show relevant offers and ads to you:
To Administer Giveaways, Contests, Discounts, or Other Offers:
To develop, display, and track content and ads tailored to your interests in our services and on other websites.
To communicate with you via email, phone, social media, or mobile devices about products or services that we believe may interest you.
To Improve Our Services and Develop New Ones:
To administer focus groups and surveys.
To study and analyze user behavior to improve our services and content. For example, we may decide to change the look and feel and even fundamentally change a certain feature based on user behavior.
To Develop New Features and Services:
To prevent, detect, and combat fraud or other illegal or unauthorized activities:
To Manage Ongoing or Alleged Misconduct:
To analyze data to better understand and design countermeasures against such activities.
To store data on fraudulent activity to prevent it from happening again.
To Ensure Compliance with Laws:
To comply with legal requirements.
To assist in law enforcement.
We rely on the following legal grounds when processing the information described above:
Provide Our Service to You:
Most often, we process your information to fulfill the agreement we have with you. For example, when you use our service to create contacts, we use your information to manage your account and profile to ensure that other users can see it and to recommend other users to you.
We may use your information where we have legitimate interests to do so. For example, we analyze user behavior in our services to continuously improve our offerings, suggest offers we believe would interest you, and process information for administrative purposes, to detect fraud, and for other legal reasons.
- How Do You Share My Information?
Sharing of information occurs with other users of the service, service providers, and, in some cases, law enforcement authorities.
You share information with other users when you voluntarily disclose information in the service (including in your public profile). Be cautious about what information you share and only share what you are comfortable becoming publicly available, as neither you nor we can control what others do with your information once shared.
Our Service Providers and Partners:
We use third-party services to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analysis, customer support, marketing, advertising, payment solutions, and security. We may also share information with partners distributing ads and assisting us in advertising our services. For instance, we may share certain information about you with our advertising partners in a condensed form that is not readable by humans. We follow strict selection processes before engaging any service providers or working with any partners. All our service providers and partners must accept strict privacy obligations.
We may transfer your information if we, in whole or in part, are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or another change in ownership or control.
When Required by Law:
We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena, or search warrant, an investigation by authorities/law enforcement, or other legal requirements; (ii) to help prevent or detect a crime (in any case according to applicable law); or (iii) to protect a person’s safety.
To Assert Legal Rights:
We may also share information: (i) if the sharing would mitigate our liability in a lawsuit or a threat of a lawsuit; (ii) as needed to protect our legal rights and the legal rights of our users, business partners, and other interested parties; (iii) to perform our agreement with you; and (iv) to investigate, prevent, or take action against criminal activity, suspected fraud, or other wrongful actions.
With Your Consent or Upon Your Request:
- Data Transfer Across Borders
The information sharing described in section six sometimes means that we transfer information across borders, such as to the USA and other jurisdictions. An example is the transfer of personal data about individuals using the services in the European Economic Area (“EEA”) to countries outside the EEA. We use standard contractual clauses approved by the EU Commission and other appropriate safeguards to allow data transfer from the EEA to other countries. Standard contractual clauses are agreements between companies transferring personal data, binding them to protect the privacy of your data and keep it secure.
- Your Rights
We want you to have control over your information, so we have provided you with the following tools:
Access/Update Tools in the Service:
Tools and account settings to help you access, correct, or delete information you have provided us that is directly linked to your service account. Contact our customer service team here for assistance with any questions about the tools and settings.
Mobile platforms have permission systems for specific types of device data and notifications, such as phone contacts and location services, as well as push notifications. If you change the settings on the device to either consent or deny the collection of that type of information or to display that type of notification, some of the services may not function properly.
You can delete your account by contacting us here.
We want you to be aware of your privacy rights. Here are some key points to remember:
Review Your Information:
Privacy laws grant you the right to review the personal data we have about you (depending on jurisdiction, this may be called the right to portability or a variation of these terms). Contact us here or at email@example.com to see what data you share with us.
Update Your Information:
If you believe the information we have about you is incorrect, or we no longer have the right to use it, and you want to request correction or deletion, or if you want to object to its processing, you can contact us here.
To protect you and all our users, we may ask you to prove that you are who you claim to be before we can respond to any of the requests above. Please note that we may deny requests for various reasons, including if the request is illegal or if it could reveal trade secrets, violate intellectual property, or infringe on another user’s privacy. If you want information about other users, such as a copy of messages you received from them through our service, the other user must contact our privacy officer to provide written consent before the information is released. We may not be able to accommodate certain requests with objections to the processing of personal data, especially if such requests would lead us to no longer provide the service to you. For example, we cannot provide the service if we do not know your date of birth.
You can stop all information collection in an app by uninstalling it in the usual way for your device. If you uninstall the app from your mobile device, the unique identifier for your device will continue to be stored. If you reinstall the app on the same mobile device, we will continue to associate the identifier with your previous transactions and activities.
In some countries, including the EU, you have the right to file a complaint with the relevant data protection authority if you are dissatisfied with how we handle your personal data. You can file a complaint with the data protection authority in the country where you reside, work, or where we operate.
- How Your Information Is Protected?
We work hard to prevent unauthorized access, alteration, disclosure, or deletion of your personal information. Like all technology companies, we cannot promise, and you should not expect, that your personal information will always be secure, even though we take steps to keep the information safe.
We regularly monitor our systems for potential vulnerabilities and attacks, and routinely review our procedures for collecting, storing, and processing information to update our physical, technical, and organizational security measures.
We may terminate your use of all or part of the services without prior notice if we suspect or detect security breaches. Notify us immediately at firstname.lastname@example.org or here if you believe that your account or information is no longer secure.
- How Long We Retain Your Information
We retain your personal information only for as long as we need it for legitimate business purposes (as described in section five) and as required by applicable law. To protect your safety and that of other users, both when using and not using our services, we use a security window of three months after the account is deleted. During that period, account information will be retained even if the account is no longer visible in the services.
In practice, we delete or anonymize the information when the account is deleted (after the security window) or after two years of continuous inactivity, unless:
We need to retain it to comply with applicable law (for example, we retain certain “traffic data” for one year to comply with data storage laws).
There is an open question, request, or dispute that requires us to retain the relevant information until it is resolved.
The information must be retained for our legitimate business purposes, such as preventing fraud and improving user security. For example, information may be retained to prevent a user who has been suspended for unsafe behavior or security incidents from opening a new account.
Please note that even though our systems are designed to perform the data deletion processes mentioned above, we cannot guarantee that all data will be deleted within a specified timeframe due to technical limitations.
- Children’s Privacy
Our services may only be used by individuals who are 16 years old or older. We do not allow users under 16 years on our platform and do not knowingly collect personal information about anyone younger than that. If you suspect that a user is under 16 years old, you can report it through the support function in the app or here.
We are always looking for new ways to improve our services. This policy may, therefore, change over time. We will notify you before any substantial changes occur so that you have time to review the modifications.
- How Can You Contact Us?