Privacy Policy
Last updated: 1 November 2022
1. INTRODUCTION
Your privacy is of the utmost importance to Reason Studios AB (“Reason”, “we”, “us”, “our”) and we are continuously taking measures to ensure that the personal data that we process about you is processed in a transparent and secure manner. This privacy policy (“Privacy Policy”) describes how and why we collect and process personal data about you when you are using our services.
Throughout this Privacy Policy the term “processing” is used to cover all activities involving your personal data, including e.g. collecting, handling, storing, sharing, accessing, using, transferring and disposing of your personal data.
“Applicable Data Protection Laws” means all legislation and regulations, including regulations issued by relevant supervisory authorities, protecting the fundamental rights and freedoms of individuals and, in particular, their right to privacy with respect to the processing of personal data that from time to time apply to this Privacy Policy, including the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the “GDPR”) as well as laws and regulations complementing the GDPR.
“Personal data” is defined as any information relating to an identified or identifiable natural person.
Please note that some of our services may entail specific processing activities that are not included in this Privacy Policy. In such case, you will receive information about such specific processing activities before any processing of your personal data starts.
2. WHO IS THE DATA CONTROLLER FOR THE PERSONAL DATA?
Reason Studios AB (556546-2206), Hornsbruksgatan 23, SE-117 34 Stockholm, is the data controller for the processing of your personal data as described in this Privacy Policy.
3. FROM WHERE DO WE COLLECT YOUR PERSONAL DATA?
We collect your personal data from:
4. PURPOSES OF THE PROCESSING OF YOUR PERSONAL DATA
Management of our services
We will process your personal data in order to manage the provision of our services to you, including to provide you with your subscription or product, providing you with after sales care such as handling returns etc., checking that payment is not made fraudulently and communicating with you within the scope of the customer relationship (e.g. sending information about purchases, managing technical service issues, responding to enquiries, support and other related communication).
| Categories of personal data | Legal basis |
|---|---|
|
Contract. The processing is necessary in order for Reason to perform under a contract with you. Legitimate interest. If the contract is entered into with any other person or entity than you (e.g. your employer), the processing is necessary in order for Reason to meet its legitimate interest of providing you with the services in accordance with the contract with such other person or entity. |
| Retention period: Your personal data is stored for as long as you are a customer of Reason and for a period of one (1) year thereafter. | |
Development and improvement of our products and services
We will process your personal data in order to develop and improve our products and services. The processing activities carried out for this purpose includes (i) using purchase history and search history to operate and improve website content and digital services, (ii) enhancement of our products and services on the basis of information how our products and services are used, (iii) sending surveys and requesting other information from you about your opinions on our products and services in order to make customer driven improvements, (iv) using your contact details to contact you through email in order to inform you about updates in, guidance for and changes to our products and services and (v) improving the products and services through knowledge gained from your use of our products and services. You can unsubscribe from emails about updates and changes in our products and services at any time by using the unsubscribe link in every such email
| Categories of personal data | Legal basis |
|---|---|
|
Legitimate interest. The processing is necessary in order for Reason to meet its legitimate interest in being able to continuously develop and improve our products and services to bring you the best possible experience with using our products and services. |
| Retention period: Your personal data is stored for as long as you are a customer of Reason and for a period of one (1) year thereafter. Your personal data will also be anonymized for this purpose and such anonymized data may be processed indefinitely. Anonymized data may also be shared with third parties. | |
Evaluate and follow-up on the business, including compiling statistics
We will process your personal data to evaluate and follow-up on our business activities and to produce reports and statistics. Such follow-ups and statistics may inter alia relate to which and how many products and/or services that have been sold during a certain period. These activities are performed to e.g. be able to develop and improve our business model as necessary. Reports and statistics are normally produced on an aggregated level, i.e. no information in such documents could be related to you as an individual. Such aggregated documents may be shared with our business partners.
| Categories of personal data | Legal basis |
|---|---|
|
Legitimate interest. The processing is necessary to fulfil our legitimate interest in evaluating and following-up on our business activities. |
| Retention period: The personal data is deleted as soon as the relevant report and/or statistic is generated. Reports and statistics on an aggregated level (i.e. non-personal data) will be retained until further notice. | |
Evaluate and improve the experience on our website
We will process your personal data, e.g. collected via cookies and similar techniques as well as from our partners, to analyse and better understand how you are using our website and to improve your experience on our website. This means that we e.g. may store information about your browsing history and settings on the website (such as language and display settings) for now mentioned purposes.
| Categories of personal data | Legal basis |
|---|---|
|
Legitimate interest. The processing is necessary to fulfil our legitimate interest in improving your experience on our website and to provide you with tailored content. |
| Retention period: The personal data is deleted as soon as the relevant report and/or statistic is generated. Reports and statistics on an aggregated level (i.e. non-personal data) will be retained until further notice. | |
Provide you with relevant marketing
We process your personal data to provide you with personalised marketing content that we believe may be of interest to you. We do this e.g. by using cookies and similar techniques which help us and our partners to send you relevant marketing via email and other communications channels, and display relevant advertising on different websites based on e.g. your visits and clicks (interest-based advertising) and by the use of your purchase history. You can unsubscribe from our marketing emails at any time by using the unsubscribe link in every email.
| Categories of personal data | Legal basis |
|---|---|
|
Legitimate interest. The processing is necessary to fulfil our and our partners' legitimate interest of providing you with interest-based advertising. Consent. We may process your personal data for marketing purposes based on your consent. You can withdraw your consent at any time by using the unsubscribe link in every email. |
| Retention period: Your personal data is retained (i) for as long as you are a customer of Reason and for a period of 12 months thereafter or (ii) during a period of 12 months from when you provided your last consent. Reports and statistics on an aggregated level (i.e. non-personal data) will be retained until further notice. | |
Forums, blogs and Reason's online information sharing sources
Each time you create or reply to a post or thread on a Reason website forum, blog, RSS or other information sharing sources, we may, in addition to providing such online services, record/save the forum, blog, RSS or information sharing source name and the time and date of your post or thread with your account details. We do this for the purpose of better understanding our users and create relevant content.
| Categories of personal data | Legal basis |
|---|---|
|
Legitimate interest. The processing is necessary in order for Reason to meet its legitimate interest in being able to better understand our users and thereby provide relevant content to our users. |
| Retention period: Your personal data is stored for as long as you are a customer of Reason and for a period of one (1) year thereafter. | |
Establish, exercise and defend legal claims
For the purposes of establishing, exercising and defending legal claims, e.g. in connection with a dispute or legal process, we may process your personal data.
We may also process your personal data for the purpose of preventing and detecting fraudulent behaviour on our website, such as fraudulent payments or fraudulent use of our services (including use of fraud accounts or abuse of trial periods and similar offers).
| Categories of personal data | Legal basis | Exemption for special categories of data |
|---|---|---|
| All data collected that are necessary to fulfil the purpose, e.g. identity data, payment data and service usage data. | Legitimate interest. The processing is necessary in order to fulfil our legitimate interest to establish, exercise or defend the legal claims, e.g. in connection with a dispute or legal process. The processing is also necessary to carry out fraud assessments for the purpose of identifying and preventing fraud and criminal offences. | Special categories of personal data, including criminal data, are only processed to fulfil our legitimate interest in establishing, exercising or defending legal claims. |
| Retention period: Personal data will be retained for up to 10 years in order to establish, exercise and defend legal claims. | ||
Fulfil legal obligations
We will process your personal data for the purposes of fulfilling legal obligations within the area of e.g. book-keeping, accounting and requirements under Applicable Data Protection Laws.
| Categories of personal data | Legal basis |
|---|---|
| All data collected that are necessary to fulfil the purpose. | Legal obligation. The processing is necessary to fulfil Reason's legal obligations. |
| Retention period: Personal data will be retained as long as necessary to fulfil each legal obligation. | |
Manage and protect IT systems and services
In order to manage and protect our services and related IT systems, e.g. upon logging, troubleshooting, backup, change and problem management in systems and in connection with potential IT incidents, we process, to the extent necessary, your personal data.
| Categories of personal data | Legal basis |
|---|---|
| All data collected that are necessary to fulfil the purpose. | Legitimate interest. The processing is necessary to fulfil our legitimate interest in managing and protecting our website, services and related IT systems. |
| Retention period: Personal data will be retained as long as necessary in relation to each purpose stated above. | |
5. DISCLOSURE AND TRANSFER OF PERSONAL DATA
Transfer of personal data to third parties acting as controllers
In general, Reason will not transfer, sell, rent or otherwise disclose your personal data with any third parties. However, in our endeavor to provide you with quality products and services, we may need to make certain exemptions to this general principle (in particular when information about you cannot be transferred in anonymous and/or in pseudonymized form). The following is a summary of the third parties with which we may share your personal data.
| Recipients | Purposes | Legal basis |
|---|---|---|
| Reason group companies | For internal business purposes | Legitimate interest. To fulfil our legitimate interest in managing and defending legal claims, e.g. in relation to a dispute. |
| Third-party suppliers acting as data controllers, such as credit card payment suppliers, delivery companies, fraud checking services etc. | In order to provide you with our products and services. | Contract. To perform under a contract with you. |
| Business partners | Sending newsletters from our business partners. | Legitimate interest. To fulfil our legitimate interest in providing you with relevant information. |
| Public authorities (including courts), arbitration tribunals, external advisers and counterparties | To exercise, establish or defend legal claims. |
Legal obligation. To fulfil our legal obligations. Legitimate interest. Legitimate interest. To fulfil our legitimate interest in exercising, establishing or defending legal claims. |
| Business partners, investors and professional advisors | Take necessary actions in connection with corporate governance events, such as selling all or part of the business or in connection with a merger, acquisition, insolvency event or investment. | Legitimate interest. To fulfil our legitimate interest in being able to sell all or part of the business or in connection with a merger. |
| Other users | Allow you to communicate with other users, either by providing links to content uploaded by you or when you post comments in communities and on forum areas. | Consent. The processing is based on your consent. |
Data processors acting on behalf of Reason
In order to fulfil the purposes of the processing of your personal data, we transfer personal data to external parties such as service providers that we have engaged as well as other partners. These parties provide services within the areas of inter alia IT (such as data storage, support and management services) and finance (e.g. book-keeping systems). For research and statistical purposes, we prepare anonymous, aggregate or generic data for a number of purposes outlined above. As we consider that you cannot reasonably be identified from this information, we may share it with external parties such as our partners, advertisers, industry bodies, media and/or the general public. However, we do apply a restrictive approach in order to ensure a high level of security and safety.
These external parties will act as data processors of Reason and may only process your personal data in accordance with our instructions and not for their own purposes. Reason is the data controller for the processing of personal data that these external parties carry out on our behalf.
Please note that third-party providers, such as external developers, generally process shared information to develop and optimize their products and services. When using third-party developer product in Reason's products and services, we recommend that you always read such third-party developer's privacy policy and terms of use before using their products or services in Reason's products and services.
Appropriate safeguards for transfers of personal data outside of the EU/EEA
Reason use suppliers and third-party providers to process personal data in a matter which includes transfer of personal data to countries outside of the EU/EEA area (third-countries). These transfers are a necessary element for the Reason services performance.
With these suppliers and partners Reason have entered data processing agreements including provisions safeguarding such third-country transfers with appropriate safety measures.
Transfers of personal data outside of the EU/EEA area will be processed in accordance with EU data protection law including the GDPR. Such transfers are either relied upon a European Commission adequacy decision on data protection transfer for the third-country in question or legal safeguards through European Commission Standard Contractual Clauses (SSC's) for transfer of personal data outside of the EU/EEA area combined with supplementary technological and organisational protection measures including encryption and anonymization/pseudonymization.
Should you have any questions regarding Reasons transfers of personal data to a country outside the EU/EEA, please contact us using the contact information stated at the end of this Privacy Policy.
6. COOKIES
Reason may use technologies such as cookies in order to collect information about the pages you view, the links you click and other actions you take on Reason's website and services. Cookies are small text files that are stored on your hard drive through your web browser.
Reason may use cookies in order to store your preferences and other information on your computer in order to save time by eliminating the need to repeatedly enter the same information, for example by remembering personal information when you use Reason's websites, and to display your personalized content and targeted advertising on your later visits to its websites. However, the cookies used on Reason's websites do not normally contain information that identifies you personally.
Cookies on Reason's websites
Reason uses session cookies as well as persistent cookies on its websites. A session cookie is a temporary cookie which is erased when a session is ended, i.e. usually when you close your browser, while a persistent cookie is stored in one of your browsers subfolders until deleted manually or the set duration period of the persistent cookie expires.
Reason uses cookies such as "ph_hasloggedin" in order to determine whether to show "sign up" or "log in" when prompting a user to log in, "ph_st_variants" in order to determine which version of a page to show to a user, and "ph_sessionid" in order to remember information about a logged in user.
Third-party cookies on Reason's websites
Reason also uses third-party cookies. Third-party cookies may be necessary in order for third parties to provide its services to Reason. Reason uses third-party cookies such as "_ga" in order to access Google Analytics data.
More information about our use of cookies can be found in Reason's Cookie Policy.
7. CHILDREN'S PRIVACY
Subject to Reason's Terms of Service, you must be 16 years of age or older to subscribe and to use our products and services, however individuals under the age of 16 may utilize our products and services only with the involvement, supervision, and approval of a parent or legal guardian.
Any parent or guardian with queries and questions concerning personal data processing that may relate to their child can contact us by using the contact details set out below.
8. YOUR RIGHTS
Under Applicable Data Protection Laws, you have certain rights in relation to the processing of your personal data. We process your personal data to the extent necessary in order to fulfil your rights. Please submit requests for exercising your rights by contacting us on the contact details set out below.
You have, under certain circumstances, the right to exercise the following rights:
- Access
You may request confirmation whether personal data is processed and, if that is the case, access your personal data and additional information such as the purposes of the processing. You are also entitled to receive a copy of the personal data undergoing processing. If the request is made by electronic means the information will be provided in a commonly used electronic format if you do not request otherwise. - Object to certain processing
You have the right to object to the processing 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 processing 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. - Rectification
You have at any time the right to have inaccurate personal data rectified, as well as, taking into account the purposes of processing, the right to have incomplete personal data completed which relates to you. - Erasure
You may have your personal data erased under certain circumstances, such as when your personal data is no longer needed for the purposes for which it was collected. However, we cannot delete your personal data if we e.g. are obligated under law to keep the data. - Restriction of processing
You may ask us to restrict the processing of your personal data to only comprise storage of your personal data under certain circumstances, such as when the processing is unlawful, but you do not want your personal data erased. If the processing of your personal data has been restricted, we may only, besides storing the data, process your personal data with your consent, in order to establish, exercise or defend legal claims or to defend rights of others. - Withdrawal of consent
You have the right to at any time withdraw your consent to processing of personal data to the extent the processing is based on your consent. - Data portability
You may ask to receive a machine-readable copy of the personal data processed on the basis of your consent or on the basis that the processing is necessary in order to perform an agreement with you, and which personal data have been provided to Reason by you (data portability) and ask for the information to be transferred to another data controller (where possible). - Complaints to the supervisory authority
You acknowledge that you always have the right to lodge complaints pertaining to the processing of your personal data to the Swedish Authority for Privacy Protection (Sw. Integritetsskyddsmyndigheten).
9. CONTACT INFORMATION
If you have any questions or concerns regarding the processing of your personal data, please contact Reason on the contact details set forth below.
The data controller is:
Reason Studios AB
Hornsbruksgatan 23
SE-117 34 Stockholm
E-mail address: [email protected]
Privacy Policy last updated: 1st of November 2022
DESCRIPTION OF CATEGORIES OF PERSONAL DATA
Please see the table below for detailed information regarding which personal data (included in the categories of personal data set forth in this Privacy Policy) that we process.
| Categories of personal data | Examples of personal data |
|---|---|
| Contact details | Telephone number, e-mail address |
| Geographic data | Location data from your unit e.g. collected via cookies |
| Identity data | Name |
| Purchase history | Information about subscription and purchases |
| Login data | Username, password |
| Organisational information | Title, position, company |
| User generated data | Visitor and click statistics, technical data regarding unit used and its settings (e.g. language setting, IP address, browser settings, time zone, operating system, display resolution and platform), information on how you have interacted with us, log in method, from where and how long you have visited our sites, response time, how you are reaching and leaving the service etc. |
| Your communication | Personal data included in your communication, e.g. in e-mails |