FlatFrog Board Privacy Policy

Version 2018:6

1.   General

1.1     FlatFrog Laboratories AB (”FlatFrog”, “We” or “Us”) supplies an application for digital drawing, writing and collaboration called FlatFrog Board (“FlatFrog Board”). When someone uses FlatFrog Board, FlatFrog may collect and process Personal Data (defined below). This privacy policy (”Privacy Policy”) outlines the details of FlatFrog’s processing of Personal Data. Please read this text carefully and return to FlatFrog should you have any questions. Our contact information and company details are found at the end of this text.

1.2     For Personal Data which FlatFrog process in order to supply the Service, FlatFrog determines the purpose and means for processing, and is thereby legally defined as a data controller (“Data Controller”). For other Personal Data which may be found in the Service, FlatFrog is legally defined as a data processor (“Data Processor”).

1.3     By ticking the “I accept” button when accessing the Service, you agree that FlatFrog process Personal Data in accordance with this Privacy Policy.

1.4     The term “Personal Data” refers to information that is directly or indirectly referable to a natural, living individual. This may include the name or e-mail address of a user, but could also include user created content, or any other data that fulfils the legal definition of Personal Data as set out by applicable law, such as the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”).

1.5     The term “processing” refers to such actions that are performed with, or on, Personal Data. This may include collecting, transferring, storing, analysing, archiving, or erasing Personal Data.1.6     The term “Principal” refers to the person, institution, company, or organization (Such as e.g. your employer or commissioner) with which FlatFrog has an agreement concerning supply of the Service, and on whose behalf you use the Service and create User Content.

2.     Personal Data processed by FlatFrog

2.1     You hereby agree to FlatFrog’s Processing of your Personal Data as outlined in this Privacy Policy. If you do not want FlatFrog to process your Personal Data, please refrain from using FlatFrog Board.

2.2     Personal Data that FlatFrog collects. FlatFrog collects and process your name, your company and your e-mail address from you, or the third-party service of your choice (e.g. your Microsoft work or school account), when you sign up for and use FlatFrog Board.

2.3     FlatFrog will automatically collect certain information attributable to you when you use FlatFrog Board. This information includes:Information about your use of FlatFrog Board,Technical data, including IP address, session ID, network and computer performance, browser type, language and your operating system.

2.4     Cookies. FlatFrog also collects information by using other types of technology, such as cookies and local storage (on e.g. browser or technical device) (“Cookies”).

2.5     We use analytics Cookies to analyse how FlatFrog Board is accessed, used, and performs. We use this information to maintain, operate and improve FlatFrog Board.

2.6     We use functional Cookies to operate certain functions of FlatFrog Board in accordance with your choices, meaning that when you continue to use, or come back to, FlatFrog Board, the site will be provided as you have previously requested, by e.g. remembering your username and customization of FlatFrog Board.

2.7     By accepting this Privacy Policy, you accept our use of Cookies. If you would like to change or limit FlatFrog’s use of Cookies, you can turn this off by altering the cookie-settings of your web-browser.

3.   User Content

3.1     User Content. When you use FlatFrog Board to create content, such as drawings (“User Content”), this User Content may be uniquely attributable to you as its creator, and thereby constitute Personal Data. Depending on how you choose to use the Service, the User Content may also include Personal Data of you, or others (“User Content Personal Data”). For the avoidance of doubt, with reference to any User Content Personal Data, FlatFrog is not the Data Controller. Any and all processing of User Content Personal Data is governed by applicable data processing agreement (“DPA”) between FlatFrog and applicable Principal (as defined in Section 1.6).

3.2     FlatFrog will process your User Content to the extent necessary to supply you with the functionality of FlatFrog Board (e.g. to access this information from other technical devices or computer programs etc.) and in accordance with your access level and subscription plan. To learn more about this, please read our Terms of Service, retrieved at http://products.flatfrog.com/board-tos.

4.   FlatFrog’s purposes of processing Personal Data

4.1     FlatFrog process your Personal Data for the purposes described below. Please note that you have the right to opt-out from certain types of processing, while not all. The reason for why some processing is not optional is that certain types pf processing is necessary to supply the Service, and therefore not possible to opt-out from. Instructions on which type of processing that is optional and not, and how you opt out is found below.
Legal basis for processing
Possible to opt-out from processing
To provide, manage, develop and customize FlatFrog Board and its various functionalities.
Your consent
To set up and administer personal user accounts for FlatFrog Board.
Your consent
To manage the user relationship with you, including communication concerning the application and its features.
Your consent
To meet safety requirements and various statutory requirements following from law, regulation or decision, injunction or otherwise communication by court or public authority (including supervisory authorities).
Necessary for compliance with legal obligation.
To detect, prevent, or pay attention to fraud and other security or technical issues.
Necessary for compliance with legal obligation.
To perform customer and market analysis, market research, statistics, business monitoring and business development.
Your consent.
Yes. Contact us via e-mail to opt-out. Email address is found at the end of this policy.
To provide you with information and direct marketing of similar and additional services or offerings from FlatFrog, or any of its subsidiaries, or partners.
Your consent.
Yes. Contact us via e-mail to opt-out. Email address is found at the end of this policy.
4.2     If you do not want us to send you any direct marking actions, you may opt-out by sending us written notice to privacy@flatfrog.com or by following instructions set out in e-mail newsletter from us.

5.   Data Processing Period

5.1     Unless otherwise stated in this Privacy Policy, your Personal Data is processed until thereto attributable user account is terminated, and for a subsequent period of 3 months. If you exercise any of your legal rights outlined in Chapter 7, this may further reduce the period during which FlatFrog process your Personal Data.

5.2     Please note that session ID is archived for one week, upon which it is deleted.

6.   Transfer of Personal Data

6.1     Subcontractors (“Data Processors”). FlatFrog may choose to include various subcontractors to perform the activities necessary to supply the Service or otherwise to fulfill the purposes of processing your Personal Data, such as IT suppliers, server suppliers, digital analysing tools etc. (“Data Processor”).

6.2     Data Processors may have their place of residence, or otherwise perform their business operations and/or services, within as well as outside the European Economic Area (EEA). Consequently, any Personal Data transferred to a Data Processor may be transferred to, and stored in, a country outside the EEA. As a result, you may have less legal rights in relation to Your Personal Data. However, we strive to, at our best efforts, achieve and uphold an adequate level of security and integrity for Your Personal Data.

6.3     When accepting this Privacy Policy, you understand and agree to transfer of your Personal Data to Data Processors outside the EEA.

7.   Your Rights

7.1     You have several legal rights aimed at safeguarding your personal integrity in relation to the processing of your Personal Data. Below, we have summarized these rights to help you understand them and how you may exercise these rights. However, since the legal field is under continuous development, this list may not be exhaustive. For the avoidance of doubt, any additional rights following from new laws, regulations, or industry practices will apply in addition to our summary.

7.2     Right to rectification. We will in our sole discretion, or upon your request, correct your Personal Data that is found to be incorrect or misleading.

7.3     Right to information. Once per calendar year, you are entitled to, by signed application, obtain a transcript of our processing of your Personal Data, free of charge. Please send any such request to e-mail address set out below. Please mark your e-mail: “Request for information concerning data processing.”

7.4     Right to withdraw consent. You have a right to withdraw your consent to processing of your Personal Data. Should such withdrawal render it impossible for us to supply you with FlatFrog Board, your user account will be terminated. In this case, you will be notified thereof in due time so that you may safeguard your User Content and other information that may be important to you.

7.5     Right to information concerning transfer outside the EEA. You have the right to learn about which safety measures that apply to establish and maintain an adequate level of safety for your Personal Data when this information is transferred outside the EEA. If you would like to learn more about this, please contact us with your request using the e-mail address set out below.

7.6     Right to Data Portability. You have the right to receive from us your Personal Data in a structured, commonly used and machine-readable format. Please send any such request to e-mail address set out below.

7.7     Right to file complaint with the supervisory authority. You have the right to file complaints concerning our processing of your Personal Data with the supervisory authority. In Sweden, this authority is named ’Datainspektionen’, and you may find their contact info via their website: www.datainspektionen.se

7.8     Right to erasure (Also known as ‘the right to be forgotten’). We strive to limit our processing of Your Personal Data. Should you choose to delete your user account, we will delete your Personal Data as soon as possible, and no later than after 3 months. In addition to this, we will erase your Personal Data within 1 month if:
- You withdraw your consent to processing, and there is no other legal basis for processing, or
- You oppose processing and there are no overriding legitimate reasons that outweigh your rights to personal integrity, or
- The Personal Data must be erased for compliance with a legal obligation set out in Union- or Member State law, or
- Personal Data have been unlawfully processed.
- You suspect that processed Personal Data is inaccurate (for the time needed to verify whether that is the case), or
- Processing is unlawful, but you agree to limited processing instead of deleting the data, or
- You need the Personal Data to establish, exercise or defend a legal claim.

7.9     Right to restriction. You have the right to claim that we restrict processing when:

8.    Miscellaneous

8.1     No automated processing. For the avoidance of doubt, FlatFrog does not process your Personal Data to perform automated decision making, which produce a legal effect for you, including profiling.

8.2     Changes to this Privacy Policy. If we make changes to this Privacy Policy, we will notify you by publication on our website. For material changes, we will also provide you with prominent notice as appropriate under the circumstances (e.g. by e-mail to your e-mail address or pop-up when you start the application) and, where required under applicable law, ask for your consent.

8.3     FlatFrog has the right to assign and subcontract its rights and obligations, including a right to subcontract the performance of their duties, following from this Privacy Policy.

8.4     Change of Ownership. If the ownership of FlatFrog’s business or FlatFrog Board changes, FlatFrog reserves the right to transfer and assign your information, including your user account, User Content, and your Personal Data, to the new owners, or partners thereto, regardless whether they are resident and having business operations within or outside of the EU/EEA, so they can continue supply FlatFrog Board. This includes any assignment to a company within FlatFrog’s group of companies, including an owner of, or subsidiary to, FlatFrog, or to a company that is not owned by, or otherwise affiliated with, FlatFrog. Any new legal entity will still have to honour the commitments FlatFrog have made in this Privacy Policy.

8.5     This original version of this Privacy Policy is written in English. Should any translated version of the Privacy Policy conflict with the English version, the English version shall prevail.

9.   Company Details and Contact Information

9.1     Company Details
Company name:
FlatFrog Laboratories AB
Company registration number:
E-mail address:
Visiting Address:
Scheelevägen 15 A, 223 63, Lund, Sweden.
Postal Address:
Scheelevägen 15 A, 223 63, Lund, Sweden.
Data Protection Officer
Not Applicable.
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