INTEGRITY POLICY

Your integrity is important to us at Upotential (”we”, “us”, “our”). Therefore, we wish to be transparent in the processing of your personal data. The purpose of this integrity policy is to inform you about why and how we gather and use your personal data, as well as your rights. You are always welcome to contact us on legal@upotential.se should you have any questions.

CONTROLLER

Upotential, org.nr 559161-8672 is the responsible controller for any processing of personal data in connection to the services we provide.

CATEGORIES OF PERSONAL DATA

We gather information that you provide when registering for our services. In order to continuously improve, we also gather information about your traffic on our website.

The following categories of personal data may be processed:

· Personal- and contact information (e.g. name, address, e-mail address, phone number, whether you are a private or corporate client).

· Information about the usage of our services (e.g. information about your traffic on our website, technical data such as IP-address)

· Payment and billing information (e.g. name, civic number, organisation number, order history, billing address)

PURPOSE AND LEGAL BASIS FOR PROCESSING PERSONAL DATA

We only process your personal data when we have to. Below you will find the purpose and legal basis for our processing of your personal data.

Purpose Legal basis

Register you for our Training. Consent.

Contact us for our Pop up gym. Consent.

Process your application for our Club. Consent.

Provide our services and communicate

with you for purposes connected to our

services. The processing is necessary in order to fulfill an agreement we have with you.

TRANSFER OF PERSONAL DATA

We may have to share your personal data with public authorities (e.g. the police, tax authority or other authorities) if necessary according to Swedish law or in regard to a suspected crime.

STORING OF PERSONAL DATA

We only keep your personal data as long as we have to in order to fulfill our agreement(s) with your or as long as it is necessary for legitimate purposes. Your personal data will be stored for a maximum of twelve (12) months from when you end your agreements with us, after which we will erase your personal data. Personal data processed in order for you to receive our newsletter will be stored for as long as you subscribe to this.

COOKIES

Cookies are small text files that are downloaded to your unit when you visit a website, and which make it possible for us to recognize your unit. We use cookies in order to improve your customer experience on our website.

We use the following types of cookies for the following purposes:

You may at any time choose not to receive cookies by changing your browser settings. Please note that some cookies are necessary in order for us to fully provide our services.

You can visit www.allaboutcookies.org for more information about cookies.

YOUR RIGHTS

You have the following rights in regard to our processing of your personal data, in accordance with current data protection legislation:

Communicate with you through our newsletter and for other marketing purposes. Upotential’s legitimate interest of providing you with relevant information about our services.

Keep track of how our website is used. Upotential’s legitimate interest of being able to develop our services and website, as well as your interest of the improvement of these.

Manage payment and billing. The processing is necessary in order to fulfill an agreement we have with you.

Cookie Purpose

Google analytics Necessary in order to track performance and statistics on website.

· You have the right to, on request, obtain access to your personal data that we process.

· You have the right to, without undue delay, have any inaccurate personal data concerning you rectified and, taking into account the purposes of the processing, have incomplete personal data completed.

· You have the right to, without undue delay, have your personal data erased, and we are obliged to erase such data if it for example is no longer necessary in relation to the purposes for which they were collected, if you withdraw your consent and there is no other legal basis for processing the data, or if our processing is illegal.

· You have the right to, under certain conditions, request that our processing of your personal data is limited, e.g. if we do not longer need the personal data for the purposes listed in this integrity policy but you need them in order to establish, exercise of defend legal claims.

· You have the right to, at any time, withdraw your consent if our processing of your personal data is based on this. Such a withdrawal will not affect the legality of any previous processing.

· You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, given that the processing is carried out by automated means and is based on your consent or the fulfillment of an agreement. Furthermore, you have a right to transfer this data to another controller or, if technically feasible, request that we transfer it to another controller.

· You have the right to, on ground relating to your specific situation, object to the processing of data carried out on bases of a legitimate interest. In such case, we may only process your personal data if we can demonstrate compelling legitimate grounds for the processing which overrides your interest or if the processing is necessary in order to establish, exercise of defend a legal claim.

If you wish to exercise your rights, please contact us on the address provided below.

You also have a right to express your complaint to the relevant supervisory authority (in Sweden, this is Datainspektionen) if you are dissatisfied with how we process your personal data.

CHANGES TO THE INTEGRITY POLICY

We reserve the right to, at any time, make changes to this integrity policy. If you have registered to any of our services, and the changes are not obviously to your benefit, we will inform you of the changes by e-mail in a timely manner.

CONTACT INFORMATION

If you wish to exercise your rights or if you have any questions regarding the processing of your personal data or this integrity policy, please contact us on:

E-mail: legal@upotential.se