Welcome to ontrackwithlife and our website at www.ontrackwithlife.com. This Privacy Policy describes our practices for collecting, using, protecting and disclosing the Personal Data we collect from you when you visit our website and use our services.
General Information
What law applies?
In principle, we will only use your Personal Data in accordance with the applicable data protection laws, in particular the Swedish Data Protection Act (dataskyddsförordning) (“DPA”) and the EU`s counterpart the General Data Protection Regulation (“GDPR”).
What is Personal Data?
Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address.
What is processing?
“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
Who is responsible for data processing?
The responsible party within the meaning of the DPA and the GDPR is Lifestory AB of Malmö, Sweden (“Lifestory AB”, “we”, “us”, or “our”).
If you have any questions about this policy or our data protection practices, please feel free to contact us using this link or write to us at the above address.
What are the legal bases of processing?
In accordance with the DPA and GDPR, we have to have at least one of the following legal bases to process your Personal Data:
- Consent – This is where we have asked you to provide explicit permission to process your data for a particular purpose.
- Contract – This is where we process your information to fulfill a contractual arrangement we have made with you or reply to your messages, e-mails, posts, calls, etc.
- Legitimate Interests – This is where we rely on our interests as a reason for processing, generally this is to provide you with the best products and service in the most secure and appropriate way. Of course, before relying on any of those legitimate interests we balance them against your interests and make sure they are compelling enough and will not cause any unwarranted harm.
- Legal Obligation – This is where we have a statutory or other legal obligation to process the information, such as for archiving or the investigation of crime.
Data we collect automatically
Log data
Even if you do not log in or register on our website, but simply browse our website, data is collected and stored and processed by us. Specifically, this requires the IP address of your computer, Date and time of access, Name and URL of the accessed file, Browser used, Number of bytes transferred, Status of the page retrieval, Session ID, Referrer URL.
Hosting of our website
We host our website using the services of Hostinger (Hostinger International Ltd). In this sense Hostinger processes all data and communication data including IP addresses, that are provided to us through our website. This means that all data submitted to our website are transferred to Hostinger. The legal basis for processing is our legitimate interest.
Content Management System (CMS)
We also use the Content Management System of WordPress by Automattic to publish and maintain the created and edited content and texts on our website. This means that all content and texts submitted to us is transferred to WordPress. This represents a legitimate interest.
Cookies
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: a) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and b) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyze your behavior on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).
As set out in the Marketing Act (Sw. marknadsföringslagen (2008:486)) and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies. For further information on the cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.
Cookie consent
Our website uses a so-called cookie consent tool to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is processed by us: a) Your consent(s) or revocation of your consent(s); b) Your IP address; c) Information about your browser; d) Information about your device; d) Time of your visit to the website. The basis for processing is our legitimate interest and your consent.
Data we collect directly
Contacting us
You can easily contact us via our contact form or social-media. In this case, we store and process the following data from you: Name, e-mail address, telephone number as well as other Personal Data that you provide when contacting us. This data is collected and processed exclusively for the purpose of contacting you and processing your request and then deleted, provided there is no legal obligation to retain it. The legal bases for processing are contract and our legitimate interest.
We are present on social media and if you contact or connect with us via social media websites, we and the relevant social media website are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contract.
User account
To use our services, you can register and log in. Here, too, we store data in order to create a User account for you: Name, E-mail address, chosen password. We store this data as long as you are registered with us. If you delete your account, we will delete your data unless there is a legal retention period on our part. In this case, we must store your data for longer. The legal bases for processing are your consent, the provision of our contractual services and our legitimate interest.
When you use our services
We process the Personal Data that arises when you use our services in order to provide our contractual services. In particular, this includes our support, correspondence with you, invoicing, fulfillment of our contractual, accounting and tax obligations. Accordingly, the data is processed on the basis of the fulfillment of our contractual obligations and our legal obligations.
Of course you have choices about the Personal Data you provide and how you make the data available. Please do not make information that you would not want to be available online. The legal basis for the processing of your Personal Data is the establishment and implementation of the contract for the use of the service as well as your consent. You may withdraw your consent to processing your Personal Data at any time and without detriment by contacting us.
Leave A Reply
When you leave comments in our blog, your IP addresses, your Name, and e-mail address are stored on the basis of our legitimate interests. This is done for our security in case someone leaves unlawful content in comments and posts.
Newsletter
If you have consented to receive our newsletter, we will use your email address to send you information about our products, promotions, and news. Our newsletter is provided by Kit, and any information you provided during your consent, such as your name and email address as well as any other additional information you provided, may be shared with Kit, and could be used to create a personalized experience for you. You can revoke your consent to receive the newsletter at any time with effect for the future. You will find the unsubscribe link at the end of each newsletter. The revocation leads to the deletion of the collected user data. The legal basis is your consent as well as our legitimate interest.
Marketing
Insofar as you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.
You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.
Direct Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.
Economic analyses and market research
For business reasons, we analyze the data we have on business transactions, contracts, enquiries,browsing behavior etc., whereby the group of persons concerned may include contractual partners, interested parties, and users of our services.
The analyses are carried out for the purpose of business evaluations and market research. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarized and or anonymized values. Furthermore, we take the privacy of users into consideration and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g., as summarized data).
Principles of processing Personal Data
Storage and Retention
As far as necessary, we process and store your Personal Data for the duration of our business relationship, which also includes, for example, the initiation and execution of a contract.
In addition, we are subject to various storage and documentation obligations, which result from the minimum statutory retention periods. The retention and documentation periods specified there are two to eight years.
Security
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organizational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.
Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.
Special Category Data
Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.
Automated decision-making
Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.
DO NOT SELL
We do not sell your Personal Data.
Sharing and Disclosure
We will not disclose or otherwise distribute your Personal Data to third parties unless this is i) necessary for the performance of our services including our shipping forwarders and, ii) you have consented to the disclosure, iii) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; or proceedings at home or abroad or to fulfill our legitimate interests.
International Transfer
We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.
Your Rights and Privileges
Privacy rights
Under the DPA and the GDPR, you can exercise the following rights:
- Right to information
- Right to rectification
- Right to deletion
- Right to data portability
- Right of objection
- Right to withdraw consent
- Right to complain to a supervisory authority
- Right not to be subject to a decision based solely on automated processing.
If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.
Updating your information
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.
Withdrawing your consent
You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
Access Request
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.
USA Users
The following applies to all users located in the United States. While we understand and appreciate that privacy and consumer data protection laws differ as they are subject to each state’s legislature and that no data protection framework similar to the GDPR exists on a federal level, we are committed to follow and apply the for your state relevant privacy rules and regulations.
As of the day of drafting, the following states had enacted privacy and consumer data protection laws:
- California Consumer Privacy Act (“CCPA”) including its subsequent amendments from the California Privacy Rights and Enforcement Act (“CPRA”);
- Colorado Privacy Act (“CPA”);
- Connecticut Data Privacy Act (“CTDPA”);
- Delaware Personal Data Privacy Act (“DPDPA”);
- Indiana Consumer Data Protection Act (“ICDPA”);
- Iowa Consumer Data Protection Act (“ICDPA”);
- Montana Consumer Data Privacy Act (“MCDPA”);
- Oregon Consumer Privacy Act (“OCPA”);
- Tennessee Information Protection Act (“TIPA”);
- Texas Data Privacy and Security Act (“TDPSA”);
- Utah Consumer Privacy Act (“UCPA”); and
- Virginia Consumer Data Protection Act (“VCDPA”).
Further and under consideration of the similarities of the above provisions, no conflict should arise pursuing a uniform approach in granting all users in the USA the same rights and privileges as set out above. However, should ambiguity occur the most stringent provision is chosen to ensure the most comprehensive approach when it comes to protecting your Personal Information.
Further, the following also apply
- i) “Shine the Light”
“Shine the Light” law (Civil Code Section 1798.83) requires us to respond to requests from California asking about the business’s practices related to disclosing Personal Information to third parties for the third parties’ direct marketing purposes. You may make a request about our collection and disclosure of your Personal Information using the contact details provided.
- ii) COPPA (Children Online Privacy Protection Act)
When it comes to the collection of Personal Information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. We do not specifically market to children under the age of 13 years old.
- iii) CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. To be in accordance with CAN SPAM, we agree to the following: If at any time you would like to unsubscribe from receiving future emails, you can email us, and we will promptly remove you from ALL correspondence.
- iv) Telephone Consumer Protection Act (TCPA)
If we process your Personal Information for the purpose of sending you SMS marketing communications, you may manage your receipt of marketing and non-transactional communications from us by replying or texting ‘STOP’ if you receive our SMS communications. In this respect, the data processing is carried out solely on the basis of our consent in personalized direct advertising per SMS.
- v) Controls For Do-Not-Track Features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, our website does not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this policy.
Finaly, and in regard to the Right to complain to a supervisory authority. You have the right to lodge a complaint about our processing of Personal Information with a supervisory authority responsible for data protection. In California this is the California Privacy Protection Agency, www.cppa.ca.gov. Users based in Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia may lodge a complaint with ther elevant district attorney or attorney general office. However, we would appreciate the opportunity to address your concerns before you contact any supervisory authority.
Validity and questions
This Privacy Policy was last updated on Thursday, 22 February, 2024, and is the current and valid version. However, we want to point out that from time to time due to actual or legal changes a revision to this policy may be necessary. If you have any questions about this policy or our data protection practices, please feel free to contact us using this link or write to us at the above address.