Lanetalk PRIVACY STATEMENT

This privacy statement was last updated on 20 November 2020.

1                   introduction

Lanetalk AB (”Lanetalk”, ”we” or ”us”) cares about your personal privacy and strives to protect your personal data in the best way possible. As such, it is important to us that you understand how we process your personal data.

This privacy statement is intended to provide you with information about how Lanetalk handles personal data and to assure you that the processing of your personal data takes place in accordance with the General Data Protection Regulation (GDPR) and other applicable privacy legislation. The privacy statement also describes your rights with respect to us and how you can exercise your rights.

Whilst this privacy statement is based on the requirements set out in the GDPR and supplementing national laws in the EU/EEA, Lanetalk provides the same degree of protection to all of its users worldwide. Please note that particular rights may be available to you if you reside in certain locations, such as California and Nevada. For more information on your specific rights if you reside in any of these locations, please see relevant sections below.

This privacy statement applies to the processing of personal data on Lanetalk's website and in Lanetalk's application (the ”Application”), which is available to download from the App Store and Google Play, as well as to Lanetalk's processing of suppliers' and business partners' data. This privacy statement also applies to the processing of personal data in connection with specific bowling competitions arranged by Lanetalk under separate terms and conditions.

This privacy statement also contains information about Lanetalk's role as data processor when you book bowling lanes through a bowling alley connected to Lanetalk's booking system.

2                   who is the data controller?

Lanetalk AB is the data controller for the processing of the personal data covered by this policy, unless otherwise stated.

Below you will find Lanetalk's contact details.

Lanetalk AB, corporate ID no. 556840-1656.

Virkesvägen 12, 120 30 Stockholm, Sweden

If you have any questions about Lanetalk's processing of your personal data, please contact us at support@lanetalk.com

3                   PERSONAL DATA, purpose, legal basis and retention period

3.1               Lanetalk's website

On Lanetalk's website (the ”Website”) you can follow results from connected bowling venues all over the world. The information is retrieved from connected bowling venues in real time. The names shown on the Website are the names given by the players in the bowling venue where they are playing and will be displayed in a hashed format unless you have agreed that your full player name may be publicly displayed on the Website. As a general rule, these names do not constitute personal data, as the names displayed on the Website cannot specifically identify a particular person.

If a player has entered data that makes it possible to identify a natural person, e.g. by means of a unique name or a name in combination with a bowling club, the data constitutes personal data. In such cases, Lanetalk processes this personal data for the purpose of showing results, both historically and in real time, from different bowling alleys to visitors to the Website. The legal basis for the processing is based on  a balance of interests, where our legitimate interest is that this is necessary in order to be able to provide the results to our visitors.

The personal data is processed for the above purpose for a period of one month from the date of the game.

3.2               Lanetalk's Application

3.2.1           Personal data you provide to us

In Lanetalk's Application, you can track your score in real time, save your results and thus monitor your own development, as well as follow other users and access their results. Lanetalk’s Application also gives you the opportunity to follow results from connected bowling venues all over the world.

When you register an account, we collect your name, age, gender, city, licence number (with your bowling club) and email address. Your name, age, gender, city and licence number are processed so that you can get the most benefit from the service, such as being able to compare yourself with other players of the same gender, in the same city, etc. Your email address is necessary for you to be able to retain and administer your account, and for us to be able to contact you if necessary (e.g. reset your password). Your licence number is used to enable us to verify that you are who you are, such as for competition results.

If you choose to log your results or synchronise your account with your game in real time, we will also process data related to this (e.g. your results, the line you play in, who you play with, etc.). Your performance data, your name and other data may be viewed by other users of the Application.

The above processing is carried out in order for us to offer the service to you, administer your account and, ultimately, perform our obligations under the agreement entered into with you when you registered and when you use the Application.

This data is saved for as long as you have a registered account. If you have not logged in to your account for a consecutive period of 24 months, your agreement will automatically expire and your account will be deregistered. You will be informed before your account is deregistered.

Your data may be saved in anonymised form after your account is closed. Lanetalk may also retain your personal data for a longer period, if it is necessary to fulfil a legal obligation that requires processing in accordance with applicable law, or for Lanetalk to be able to establish, assert or defend legal claims.

3.2.2           Participation in competitions arranged by Lanetalk

In Lanetalk's Application, you may also be given the opportunity to participate in specific competitions arranged by Lanetalk and/or our partners under separate terms and conditions. If you choose to participate in any of the special competitions arranged by Lanetalk, we will collect your name, email address, results, geographical location (based on participating bowling venue), account details (optional and subject to achieving a certain result in the competition) and results. Your name and email address are necessary for you to be able to retain and administer your participation in the competition. Your account number is used to enable us to pay out any winnings that are paid out if you, as a player, have reached a certain position in the competition. Your results data and name may be viewed by other users of the Application.

The above processing is carried out in order for us to provide the agreed service and for the performance of the agreement we have with you, i.e. in order to enable your participation in any of the specific Lanetalk's competitions that you have signed up for.

3.2.3           Technical information

When using the Application, we process certain technical information from the device onto which you download the Application. This includes geographic data (provided that you have enabled your location information), IP address, usage data (e.g. how you use the application, how long you spend on the site, how often you return, interactions with links and objects, any errors that have occurred, etc.), and information about the type of device you are using.

The processing of the above data is based on a balancing of interests, where our legitimate interests are to be able to: obtain information about how the Application is used and works from a user perspective, provide, develop and improve the Application, create statistics for internal and external use, determine the effectiveness of our communication; increase security, and prevent fraud and misuse of the Application.

This data is generally deleted or anonymised within 30 days, but may be retained for longer if there are reasons for this (e.g. if we suspect misuse or are trying to resolve a problem). Lanetalk may retain your personal data for a longer period, if it is necessary to fulfil a legal obligation that requires processing in accordance with applicable law, or for Lanetalk to be able to establish, assert or defend legal claims.

3.3               Suppliers and business partners

Lanetalk processes your name, title and contact details (e-mail address and telephone number) for the purpose of enabling Lanetalk to perform its contractual obligations, and otherwise, in order to exercise its rights and obligations under the agreements or in the relationship with the company you represent. If this information is not provided, the agreement cannot be fulfilled or the relationship cannot be effectively maintained. The legal ground for the processing is fulfillment of our contractual obligations and, where applicable, Lanetalk's legitimate interest is to be able to exercise its rights and obligations in accordance with agreements entered into, and otherwise, administer the relationship with the company you represent.

Your name and contact details will be retained for the duration of our contractual relationship or should we otherwise need the information for a situation related to our contractual relationship or relationship with the company you represent. In the event that your employment with the company you represent ceases or you otherwise cease to be the contact person, we will delete your data following notification. 

Your data (e.g. your name) may appear in agreements, correspondence or other documentation relating to Lanetalk's relationship with the company you represent and which Lanetalk needs to retain for commercial, business or legal reasons. The data is stored based on fulfilment of contractual obligations and a balancing of interests, where Lanetalk's legitimate interest is to store information and documentation that is of commercial, business or legal importance for Lanetalk's operations. Where Lanetalk needs to retain this documentation for the purposes stated above, the personal data will not be erased during this period.  

Lanetalk may also retain your personal data for a longer period, if it is necessary to fulfil a legal obligation that requires processing in accordance with applicable law, or for Lanetalk to be able to establish, assert or defend legal claims.

3.4               Newsletters and marketing via email

If you have registered an account in the Application, Lanetalk may use your email address to enable us to send you relevant information about the Application and for marketing purposes. The legal ground for processing is based on Lanetalk’s legitimate interest, where our legitimate interest is to market our services to our users.

If you have booked a time in a bowling alley that uses Lanetalk's booking service (see more about Lanetalk's processing of personal data in this context below), you will have been offered the opportunity to sign up to receive newsletters and marketing from Lanetalk. If such an offer has been accepted, processing takes place in order for Lanetalk to be able to administer the subscription and send out such information. The legal basis is your consent to receive such marketing.

You can unsubscribe from receiving such newsletters and marketing at any time by using the unsubscribe link found in all email correspondence from Lanetalk.

4                   Lanetalk as the data processor

Lanetalk also provides booking services to bowling alleys connected to Lanetalk's booking service. In this context, the bowling alley is the data controller for the personal data you provide when making your booking.

The personal data you provide, i.e. your name, email address and mobile phone number, as well as card and payment details, will be processed by the bowling alley and you will be asked to contact the relevant bowling alley if you have any questions about the processing of your personal data.

Lanetalk is the data processor for the bowling alley in connection with the booking. This means that Lanetalk will only process your data on behalf of the bowling alley and not for its own purposes.

The bowling alley, or Lanetalk on behalf of the bowling alley, will use your email address to send newsletters and marketing communication for services and products similar to those you have booked when you used the booking service. You can unsubscribe from receiving such newsletters and marketing at any time by using the unsubscribe link found in all email correspondence from Lanetalk.

5                   who may we share your data with?

Lanetalk may transfer your personal data to suppliers who provide services to Lanetalk, such as digital storage or similar. These suppliers are only entitled to process your personal data on behalf of Lanetalk when they perform a service for Lanetalk. Lanetalk takes all appropriate legal, technical and organisational measures to ensure that your personal data is handled securely and with an adequate level of protection when transferring to or sharing with such selected third parties.

If you have chosen to participate in any the bowling competitions arranged by Lanetalk, your name and result may be published online and shared with Lanetalk’s partners (e.g. sponsors) in order to the competition to take place.

Lanetalk may also disclose your personal data to authorities if we are required to do so by law. In the event that all or part of Lanetalk's business is disposed of, Lanetalk may transfer your personal data to a potential purchaser of the business.

6                   Where do we process your data?

Your personal data will mainly be processed within the EU/EEA, but may also be transferred to countries outside the EU/EEA to suppliers who perform services on behalf of Lanetalk in accordance with clause 5 above. If Lanetalk decides to use suppliers who process data outside the EU/EEA, Lanetalk has taken appropriate precautions to protect your personal data by ensuring that the recipient of the personal data has signed an agreement containing provisions that ensure that your data is processed in accordance with the General Data Protection Regulation. In the situation your name and result information needs to be shared with a Lanetalk’s partners as part of a Lanetalk competition described in 3.2.2 above, we may ask for your consent to the transfer of such data to regions outside of the EU/EEA in that specific instance.

7                   your rights

You have certain statutory rights that you can enforce against Lanetalk. Below is a summary of the rights avaliable to you.

(a)    Right to access/register extract You have the right to find out whether Lanetalk processes personal data about you. In such an event, you have the right to information about the personal data that is processed, the purposes of the processing, the external recipients who receive your personal data and how long we store your personal data for.

(b)    Right to data portability You have the right to request a copy of the personal data you have provided to Lanetalk in a structured, commonly used and machine-readable format. You also have the right to request Lanetalk to transfer this personal data to another data controller. The right to data portability applies to personal data processed by automated means and that is based on your consent or on an agreement to which you are a party.

(c)    Rectification of incorrect information You have the right to request that Lanetalk rectifies incorrect or incomplete information about yourself.

(d)    Erasure of certain data You have the right to request Lanetalk to erase your personal data under certain circumstances, e.g. if the personal data is no longer necessary for the purpose for which we collected the personal data.

(e)    Right to object to Lanetalk's processing of personal data Under certain circumstances, you have the right to object to Lanetalk's processing of your personal data. 

(f)     Right to restrict processing of your personal data You have the right to request restriction of Lanetalk's processing of your personal data in certain cases. For example, if you have contested the correctness of your personal data, you can request restriction of the processing for a period that allows Lanetalk to check whether the personal data is correct.

(g)    Complaints If you have a complaint regarding Lanetalk's processing of your personal data, you have the right to lodge such a complaint with the Swedish Data Protection Authority.

If you wish to submit a request for a register extract, rectification, erasure, objection or restriction, or if you have any other questions about your rights concerning Lanetalk's processing of your personal data, please contact Lanetalk at support@lanetalk.com

8                   Specific rights for California residents

Lanetalk users that reside in California, as set out in the California Code of Regulations, have certain specific rights under the California Consumer Privacy Act of 2018 (the "CCPA") in relation to their personal information. A description of the specific rights available to California residents is set out below. As used herein, the definition of personal data and personal information shall have the same meaning, unless specially stated otherwise.

 

 

8.1     Rights under the CCPA and how to exercise them.

(a)    Right to understand what personal information Lanetalk collects and shares. The CCPA gives Lanetalk users the right to request that Lanetalk discloses the specific pieces of personal information that have collected about the user. Lanetalk will provide such information after your specific request has been received and validated.

(b)    Personal information is not sold by Lanetalk. However, we may share some personal information for our legitimate business purpose and/or disclose aggregated data (not constituting personal information) with our third party partners. When you make a request to access your personal information, Lanetalk will provide a list of the categories of personal information that we may have disclosed about you, as well as the categories of third parties to whom your personal information may have been disclosed by Lanetalk.

(c)    How to make a disclosure request. You may request the disclosures described above by sending a request to support@lanetalk.com. You have the right to make two (2) free requests during any 12-month period. Lanetalk will make the disclosure within 45 days of receiving your request, unless we request an extension. In the event that we reasonably need a 45-day extension, we will notify you of the extension within the initial 45-day period.

(d)    Right of deletion. You have the right to request that we delete your personal information, subject to certain exceptions. After we receive and validate your request, we will delete your personal information, as well as direct our service providers to delete your personal information, unless an exception applies

(e)    Right to non-discrimination. You have the right not to receive discriminatory treatment for the exercise of your privacy rights under the CCPA.

 

8.2     Disclosures About Your Personal Information

(a)    Categories of information we collect and disclose for a business purpose. We collect the following categories of personal information from you in connection with the services, as defined in the CCPA. In addition, during the past twelve months, we have disclosed these categories of personal information for a business purpose:

·     Identifiers, such as your name, IP-address, email, and other similar identifiers.

·     Personal information categories listed in the California Customer Records provisions, including physical characteristics, such as weight, and

·     Payment information, such as your credit card number.

·     Characteristics of protected classifications under California or federal law, such as your gender and age.

·     Commercial information, such as the record of purchase of Lanetalk membership.

·     Internet or other electronic network activity information, such as session logs.

·     Geolocation data, such as the physical location of your recorded activity based on the bowling venue that you play at.

·     Electronic, visual, or similar information, such as photos.

 

According to California law, personal information does not include:

·     Publicly available information from government records.

·     Deidentified or aggregated consumer information.

 

8.3     Questions regarding CCPA?

If you have questions about your rights or our disclosures under the CCPA, you may reach us at support@lanetalk.com.

9                   SPECIFIC RIGHTS FOR Nevada RESIDENTS

We do not sell your covered information, as defined by Section 1.6 of Chapter 603A of the Nevada Revised Statutes. If you reside in Nevada, you have the right to submit a request to support@lanetalk.com regarding the sale of covered information.

10                changes to the privacy statement

Lanetalk reserves the right to make changes to this privacy statement. If such changes are made, this will be notified on the website or in some other way that Lanetalk deems appropriate.