Readly Privacy Policy

Effective as of 25 May 2018

1. WE CARE ABOUT YOUR PRIVACY

Thank you for your using the Readly Service! Your trust is important to us. We care about your privacy. This is our Privacy Policy, which explains how and why we use the personal data that you share with us and which we collect. In short, we use the personal data that we collect in order to provide the Service and its features. We never sell your personal data to others without your permission.

Personal data means any information which may be used to identify you.

Throughout the Privacy Policy we refer to the Service. This term is defined in our Terms and Conditions of Use. https://readly.com/eula

Please read on for detailed information regarding when we collect personal data, how and why we use the personal data and your rights.

Readly AB (Readly), a Swedish entity, is the data controller for the use of your personal data as described in this Privacy Policy. Please find the contact details of Readly under section 10 below.

2. WHEN DO WE COLLECT PERSONAL DATA?

We collect personal data when you:

Create a User Account

When you sign up for the Service, we collect the personal data that you provide such as your e-mail address, password and country in order to create your user account.

If you connect to the Service by using Facebook, you authorize us to collect your username and other information that may be available through your Facebook account, including your name, country, e-mail address, date of birth and gender. We only collect the information which you make available to us according to your Facebook privacy settings.

Use the Service

When you use and interact with the Service, we collect information about how the Service is accessed and used. For example we collect information about the type of subscription you have and the interactions that you make with the Service, e.g. which magazines you read and mark as favorites.

We also collect certain technical information, which includes e.g. URL information, your IP address, the type of device that you use to access the Service, your device's operating system and Readly application version.

If you have signed up for the Service via one of our business partners, we collect information whether payment has been made from the business partner.

Make a Payment

When you pay for a subscription, we collect your name, address and credit or debit card information (e.g. card type and expiration date) which are needed in order to process the payment. We use payment service providers to process your payment.

Use the Website

When you use the website, we collect certain technical information, including your IP address.

Communicate With Us

When you communicate with us for example when contacting our customer support or interacting with us on social media platforms, we collect the information you provide. This may include your name, e-mail address and your communication.

Participate in Contests and Surveys

If you choose to participate in contests and surveys, we ask you for certain information in addition to what is stated above. This additional information may be combined with other information we have collected.

3. WHY DO WE USE YOUR PERSONAL DATA?

We use your personal data to:

Provide the Service

This may be obvious, but we use your personal data to provide the Service, e.g. to give you access to the Service, providing customized and personalized content, recommendations and features in the Service, processing your payment and preventing or detecting fraud. You need to provide the information that we request when you sign up for the Service as the information is necessary for the performance of the contract with you. If you do not provide the information requested, you cannot use the Service.

Personal Data Legal Basis
  • Account data
  • Profile data
  • Address data
  • Mobile subscriber data
  • Payment data
  • User generated data
  • Technical data
Performance of a contract. The processing of your personal data is necessary in order to fulfill the terms for the Service.
Storage Period: Your personal data is stored for this purpose as long as your user account is active and for a period of 12 months thereafter in order to satisfy our legitimate interest of promoting the Service.

Communicate with You Regarding the Service

We use your personal data to communicate with you regarding the Service, e.g. notify you of updates to the Service or to respond to questions that you may have regarding the Service.

Personal Data Legal Basis
  • Account data
  • Profile data
  • Address data
  • Communication
Performance of a contract. The processing of your personal data is necessary in order to fulfill the terms for the Service.
Storage Period: Your personal data is stored for this purpose as long as your user account is active.

Communicate with You for Marketing Purposes

We use your personal data to communicate with you for marketing and promotional purposes regarding offers from us and our business partners.

Personal Data Legal Basis
  • Account data
  • Profile data
  • Address data
  • User generated data
  • Technical data
Legitimate interest. The processing of your personal data is necessary in order to satisfy our and our business partners' legitimate interest of communicating with you for marketing and promotional purposes.
Storage Period: Your personal data is stored for this purpose as long as your user account is active and for a period of 12 months thereafter for the same purpose.

Analyze the Use of the Service

We use your personal data to analyze the use of the Service, e.g. to collect and analyze usage statistics of how the Service is used, including for example which magazines are read and favorited. We share this data on an aggregated level - thus in an anonymized way - with the publishers that we collaborate with.

Personal Data Legal Basis
  • Account data
  • Profile data
  • User generated data
  • Technical data
Legitimate interest. The processing of your personal data is necessary in order to satisfy our legitimate interest of analyzing how the Service is used.
Storage Period: Your personal data is stored for this purpose as long your user account is active and for a period of 12 months thereafter in order to satisfy our legitimate interest of promoting the Service. Statistics and reports which do not include any personal data are stored until further notice or until deleted.

Analyze the Use of our Website

We use your personal data to analyze the use of our website, e.g. to collect visitor statistics.

Personal Data Legal Basis
  • Technical data
Legitimate interest. The processing of your personal data is necessary in order to satisfy our legitimate interest of analyzing how our website is used.
Storage Period: Your personal data is stored for a period of 1 month for this purpose. Statistics and reports which do not include any personal data are stored until further notice or until deleted.

Ensure Technical Functionality and the Security of the Service

We use your personal data to ensure the technical functionality and the security of the Service, e.g. security logging, error handling and backup of data.

Personal Data Legal Basis
  • Account data
  • Address data
  • Profile data
  • User generated data
  • Technical data
  • Mobile subscriber data
  • Payment data
  • Communication
Legitimate interest. The processing of your personal data is necessary in order to satisfy our legitimate interest of ensuring the technical functionality and the security of the Service.
Storage Period: Your personal data is stored for this purpose until your user account is deleted. Personal data in technical logs is stored for a period of 13 months from the date of the log event.

Develop and Improve the Service

It is our aim to give you the best digital reading experience possible. We therefore use your personal data to develop and improve the Service, e.g. to develop new features for the Readly application.

Personal Data Legal Basis
  • Account data
  • Profile data
  • User generated data
  • Technical data
  • Mobile subscriber data
Legitimate interest. The processing of your personal data is necessary in order to satisfy our legitimate interest of developing and improving the Service.
Storage Period: Your personal data is stored for this purpose for such period as is necessary in order to anonymize the data, test features or functionality and deploy patches and other bug fixes.

Other Purposes

We also use your personal data to:

Manage and Defend Legal Claims

If necessary we may use your personal data to manage and defend legal claims, e.g. in connection with a dispute or a court proceeding. For this purpose, we may share certain information with other parties, see below under section 4.2.

Personal Data Legal Basis
  • Account data
  • Address data
  • Profile data
  • User generated data
  • Technical data
  • Mobile subscriber data
  • Payment data
  • Communication
Legitimate interest. The processing of personal data is necessary in order to satisfy our legitimate interest of managing and defending legal claims.
Storage Period: Your personal data is stored for this purpose for such period as is necessary in order to manage or defend the legal claim.

Fulfill Legal Obligations

Finally, we use your personal data to fulfil legal obligations that we have, e.g. accounting requirements or obligations under data protection laws. For this purpose, we may share your personal data with other parties, see below under section 4.2.

Personal Data Legal Basis
  • Account data
  • Address data
  • Profile data
  • User generated data
  • Technical data
  • Mobile subscriber data
  • Payment data
  • Communication
Legitimate interest. The processing of personal data is necessary in order to fulfill legal obligations to which we are subject.
Storage Period: Your personal data is stored for such period as is necessary in order to fulfill respective legal obligation. Accounting information is retained for 7 years calculated after the end of the calendar year the relevant financial year ended.

4. SHARING OF PERSONAL DATA

Below we describe when the personal data that we have collected may be shared by you and us.

4.1. Sharing by You

The Service includes various social features which allow you to share content with others. For example you can share which magazines you read with others through the Service.

4.2. Sharing by Us

We share your information with certain recipients as explained below. The recipients are data controllers for their own use of your personal data unless we have stated otherwise.

Service Providers

To provide the Service we use service providers. They provide for example IT services (e.g. hosting) and communication services (which allows us to send notifications and newsletters to you). Where a third party service provider processes personal data on our behalf they act as data processors and we are responsible for the use of your personal data. They may not use your personal data for their own purposes and they are obligated to protect your personal data.

Publishers

The Service allows you to read magazines in a digital format. In order to provide the Service we collaborate with publishers that license this content to us. We share certain information with the publishers in order to allow them to analyze the readership of their magazines. For the same purpose the publishers may match the information that they receive with their own customer database. Please read the publisher's own privacy policy for information on how they use your personal data.

Personal Data Legal Basis for the Transfer
  • Account data (only name and physical address)
Legitimate interest. The transfer is necessary in order to satisfy our legitimate interest of fulfilling our contractual commitments with the publishers and the publishers' legitimate interest of analyzing the readership of their magazines.

Social Network Platforms

To promote the Service on social network platforms (e.g. Facebook), we share certain information with such social network platforms.

Personal Data Legal Basis for the Transfer
  • Profile data
Legitimate interest. The transfer is necessary in order to satisfy our legitimate interest of promoting the Service on social network platforms.

Payment Service Providers

We use payment service providers to process payments.

Personal Data Legal Basis for the Transfer
  • Account data
Performance of a contract. The transfer is necessary in order to handle the payment for your paid subscription.

Business Partners

We collaborate with various business partners through which you can subscribe to the Service. In order to handle your subscription, we share certain information with the business partners.

Personal Data Legal Basis for the Transfer
  • Account data
  • Address data
  • Mobile subscriber data
Performance of a contract. The transfer is necessary in order to handle your subscription.

Other Sharing

In addition to the above, we may if necessary share your information with other recipients for the following purposes:

  • to allow a merger or an acquisition
  • to manage or defend a legal claim
  • to respond to lawful requests from authorities according to mandatory applicable laws.
Purpose Legal Basis for the Transfer
    Allow a merger or an acquisition
Performance of a contract. The transfer is necessary in order to satisfy our legitimate interest of allowing a merger or an acquisition of our business.
    Manage or defend a legal claim
Performance of a contract. The transfer is necessary in order to satisfy our legitimate interest of managing or defending legal claims.
    Respond to lawful requests
Performance of a contract. The transfer is necessary in order to fulfill legal obligations to which we are subject.

5. TRANSFER TO OTHER COUNTRIES

We transfer and use the personal data that we collect in various countries in order to provide the Service. For example, we use service providers which are located in other countries outside your home country. Personal data collected within the European Union (EU) and the European Economic Area (EEA) will be transferred outside and used by our service providers outside the EU and EEA. In order to ensure that your personal data is always protected we ensure that there are adequate safeguards in place, e.g. data transfer agreements or, in case of transfer of personal data to the U.S., that the recipient is certified according to the EU-U.S. Privacy Shield framework. If you have questions regarding to which countries your personal data is transferred and which safeguards we take to protect your personal data, or to request a copy of such safeguards respectively information where they are available, please contact us at support@readly.com.

6. SPECIAL INFORMATION FOR CALIFORNIA (U.S.) CONSUMERS

California residents may request a list of certain third parties to which we have disclosed personal data about you for their own direct marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information in writing by contacting us on the contact details outlined in section 11 below. Please allow up to thirty (30) days for a response.

7. YOUR RIGHTS

Under law you have certain rights in relation to the personal data that we collect about you.

You have the right to:

Access Your Personal Data

You have the right to request access your personal data and request a copy of your personal data that we store. You can view and download certain information that we store about you under "My account".

Update Your Personal Data

You have the right to request that personal data that is incorrect or incomplete is corrected or completed. You can update certain information, e.g. contact information, in "My account".

Withdraw Consent

If we rely on your consent to the use of your personal data you have the right to, at any time, withdraw your consent.

Delete Your Personal Data

You can at any time unsubscribe from the Service and request that your account is deleted, please see our Terms and Conditions of Use. We will in such a case only keep your personal data if we are obligated to keep the data in order to fulfill legal obligations or to manage or defend legal claims.

Unsubscribe from Marketing Communication

You have the right to at any time oppose to our use of your personal data for promotional and marketing purposes. You can opt-out from marketing communication by clicking on an unsubscribe link in the communication or by changing your notification settings in "My account".

Restrict the Use of Your Personal Data

You have under certain circumstances the right to request that the use of your personal data is restricted. Please contact support@readly.com if you wish to exercise your right of restriction. If you have requested restriction of the use of your personal data, please note that we cannot provide the Service to you during the time that the use of your personal data is restricted.

Object to the Use of Your Personal Data

Certain use of your personal data is based on our or others legitimate interest. You have the right to object to the use of your personal data based on a legitimate interest for reasons which concerns your particular situation. In such a situation, we will stop using your personal data where the use is based on a legitimate interest, unless we can show that the interest overrides your privacy interest or that the use of your personal data is necessary in order to manage or defend legal claims.

Transfer Your Personal Data (Data Portability)

You have the right to obtain a copy of certain information that you have provided to us in a structured machine-readable format which allows you to transfer the data to another recipient. You can download your data in "My account".

8. CHILDREN

We do not knowingly collect information from children under the age of 18. If you are under 18 years old you must have your parents' guardians' consent in order to use the Service. If it comes to our knowledge that we have collected Personal Data from a child under the age of 18, without the parents' or guardians' consent, we will take appropriate measures to delete the personal data provided. If you are guardian of a parent and become aware that your child has provided personal data to us, please contact us at support@readly.com.

9. COOKIES AND OTHER SIMILAR TECHNOLOGIES

We use cookies on our website and in the Service. For further information on how we use cookies and other technologies, please see our Cookie Policy. https://readly.com/cookie

10. CHANGES TO THE PRIVACY POLICY

We may occasionally update this Privacy Policy. For example we may decide to collect additional information or use for other purposes than those stated in the Privacy Policy. In such a case, we will notify you in advance in an appropriate way, e.g. by displaying a notice in the Service or by sending you an e-mail.

11. IF YOU HAVE ANY QUESTIONS

If you have any questions regarding this Privacy Policy, the Service or otherwise, please contact us at support@readly.com.

If you are not satisfied with our response, you have the right to lodge a complaint with your data protection authority. In Sweden, Readly is supervised by the Swedish data protection authority (Datainspektionen).

Readly AB
VAT No SE556921112001
Honnörsgatan 20
352 36 Växjö, Sweden

12. CATEGORIES OF INFORMATION

Please see the table below for further information on the categories of information that we use and store about you.

Category Data
Account data Account-ID, e-mail address, country, status, creation date, subscription type.
Address data Name, address, zip, city, county, state, country
Profile data Name, e-mail address, birth year (optional), gender (optional)
Technical data IP address, application version, operating system, unique device ID
Payment data Transaction date, amount, VAT, subscription period, payment method
Mobile subscriber data Phone number
User generated data Magazines read, favorites, bookmarks
Communication Contents of your communication

Thank you for using our Service! We hope you enjoy it!