**According to artikel28.3 i General Data Protection Regulation EU 2016/679:
the definition of "Personal Data": Any information relating to an identified or identifiable natural person, whereby an identifiable natural person is a person who can be directly or indirectly identified specifically with reference to an identifier such as a name, an identification number, a location information or online identifiers or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the natural person.
Accordingly, use of Application and Application services does not create by definition, “Personal Data Controller / Personuppgiftsansvarig”, “Personal Data Processor / Personuppgiftsbiträde” nor “Personal Data Assistant / Personuppgiftsunderbiträde”.
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Rowing Nation AB
Owner contact email: [email protected]
Data processed using the following services for the following purposes:
- Google Analytics for Firebase
Data collected: Application opens; Application updates; device information; geography/region; launches; number of sessions; operating systems; Usage Data (such as which function in the app are used)
- Location-based interactions
- Non-continuous geolocation
Data: on all "banas" (permanent walking courses) geographic position used in the interactive map in the app.
- Continuous geolocation (when app is open and in foreground or background)
Data: on "banas" which have "geofencing" in the name, there are no QR codes. Questions open due to user proximity to question icon in the interactive map in the app.
Use: geofencing banas are necessary when the bana is located in an area where it is not allowed or impracticle to install physical QR codes, or it is imperative to ensure users are actually walking the bana for exercise.
- Managing contacts and sending messages
- Firebase Notifications
Data: uses both your anonymous user name and your anonymous User ID to communicate in the app directly to your mobile device.
The purpose of Xrundan
Xrundan collaborates with various municipalities, associations and other organizations that buy Xrundan's "Quiz Walk / Tipspromenad" service and facilities. This is why a municipality's or association's logo is often visible when choosing which round you want to go.
Xrundan's purpose is to give people a fun activity that gets them out and exercising, while engaging their brain via quizzes.
Another purpose is as a platform for conveying events or other information from the municipality, association or organization via special extra quizzes. Examples of special quizzes can be "Garbage Picker Week in the municipality", "Global goals 2030" or "Get to know your municipality" quiz.
Types of Data collected
Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Among the types of Data that this Application collects, by itself or through third parties, there are: Camera permission; Microphone permission;; Approximate location permission when using the interactive map in the app; Usage Data (for example, when you use the app, and what functions in the app you use); User name; password; Type of mobile phone used.
Data such as Gender and Birth year are not mandatory, and the app works well without this data.
Users who are uncertain about which Anonymous Data is mandatory are welcome to contact us via the email address above.
Personal Data collected in earlier versions of the Application
Personal Data, such as Name, Email or phone number, if provided by User in earlier versions of the Application, will be deleted from the Application. Only your anonymous Username and UserID will remain in the system.
Use of data
Your username is used for in-app communication via in-app notifications.
We and / or our partner use "In-app" notifications to notify you of new quizzes, competitions, important information, etc. and also winning mailings.
Gender and year of birth are thus used in anonymous statistical reports that help the municipality assess who is participating.
Home municipality and which round you went to is used to be able to communicate to people who go in a certain municipality or on a certain round. This is done via in-app notifications. Examples of such communication can be information about the condition of the round, or information about a quiz that is available on a certain round.
The location service is used so you can see where the next question is in the app's interactive map and as confirmation that you have actually gone round.
Results and your tasks
Your username and which round you went to will appear in this week's results list as well as in the winner list available on Xrundan.com if you win.
Information for a club / organization that organizes Xrundan events
Your anonymous username may be on a list available to the municipality, association or organization responsible for the round ("host organizations") you attended. The main purpose is to be able to send out profits, necessary information, and for the collection of anonymous statistics.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorised destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Anonymous Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Anonymous Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Anonymous Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Anonymous Data shall be processed and stored for as long as required by the purpose they have been collected for. Data retention time is maximum of 2 years since User’s last use of Application.
- Anonymous Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Anonymous Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Anonymous Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Anonymous Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Managing contacts and sending messages and Location-based interactions.
For specific information about the Anonymous Data used for each purpose, the User may refer to the section “Detailed information on the processing of Anonymous Data”.
Detailed information on the processing of Anonymous Data
Anonymous Data is collected for the following purposes and using the following services:
- Location-based interactions
- Managing contacts and sending messages
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Anonymous Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Anonymous Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Anonymous Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Anonymous Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Anonymous Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Additional information about Data collection and processing
The User's Anonymous Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal Anonymous data upon request of public authorities.
Additional information about User's Anonymous Data
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Anonymous Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Available upon request.
Latest update: April 16, 2022