PRIVACY POLICY

I. Introduction

Swedish Chamber of Commerce India (‘SCCI’ or ‘we’ or ‘us’) considers the privacy of individuals to be of the utmost importance and accordingly, we treat any information received responsibly and in compliance with the applicable Data Protection Laws (defined herein below).

II. Who Are We

SCCI is an independent, non-profit networking organization with the mission to enable, promote and encourage Swedish companies to drive long-term, sustainable business in India. We provide our members with unique opportunities for continuous learning and development, platforms for leverage for the community as well as individual member companies. To achieve the above objectives, one of the initiatives taken by SCCI is to organize the Swedish Corporate Championship (the ‘Championship’) for its member companies (the ‘Member Companies’). To ease the process of registering for and participating in the Championship, this year we have launched the ‘Swedish Corporate Championship Application’ (the ‘Application’), which can be used by the employees of the Member Companies and/or their Family Member(s) (as defined below) (‘You’ or ‘User’).

III. Definitions

a. ‘Data Protection Laws’ shall mean and include the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and the General Data Protection Regulations 2016/679 (applicable only to EU-resident users who are natural persons).

b. ‘Family Member(s)’ shall mean immediate family members (i.e. spouse, adult children and/or dependant parents) of the employees of the Member Companies, who are above the age of eighteen (18) years and residing in India.

c. ‘Purpose’ shall mean the purposes connected with the activities and operations relating to the Championship and the purposes listed in clause IV below.

d. ‘Personal Information’ shall mean any information relating to an identified or identifiable natural person.

IV. Purpose/ User’s Consent

By using or visiting the Application/Website, the User consents to the terms of this Privacy Policy and processing of the Personal Information by SCCI for the Purposes given under the terms and conditions and this Privacy Policy. Further, the User also consents to abide by the Data Protection Laws.

The Service Provider may use the information you provided to contact you from time to time to provide you with important information, required notices and marketing promotions.

For a better experience, while using the Application, the Service Provider may require you to provide us with certain personally identifiable information, including but not limited to email, phone, image, Date of Birth, city, company, employee code. The information that the Service Provider request will be retained by them and used as described in this privacy policy.

We collect Personal Information of Users who are directly or indirectly identifiable, having regard to any characteristic, trait, attribute or any other feature of the identity of such natural person, or any combination of such features, or any combination of such features with any other information as well as sensitive personal data including, but not limited to, passwords, financial data, data identifying the gender of the person, etc.

The app has a provision to let users upload pictures which will be displayed on their profile. The SCC App respects user privacy and acknowledges that uploading a display picture is not mandatory. If the user chooses to upload a display picture, please note that we may collect and store this image solely for the purpose of personalizing your user experience within the app. Rest assured that your display picture will be treated with confidentiality and will not be utilized for any other purposes without your explicit consent. Your privacy and data security are of utmost importance to us.

The User explicitly consents to the use of their Personal Information by SCCI for the purpose of services provided by us in conducting, organizing, facilitating and hosting the Championship on the Application/website www.swedishchampionship.com (the ‘Website’), SCC App as well as the following purposes:

a. to allow the User to create an account and update the profile including display picture;

b. to create a profile through an account for uploading pictures and keeping a track of their matches/tournaments (schedule, statistics),

c. to allow SCCI to function based on information that the User has provided as well as the information imported from other websites or applications, or information provided to us by third parties such as the User’s contacts or advertisers;

d. to provide the User additional information and promotions such as promotional news, advertisements, etc;

e. to contact the User about Application/ Website updates, informational and service-related communications, including important security updates;

f. to enable the User to provide feedback, to contact us and for us to respond to the User;

g. to conduct surveys, questionnaires, promotions and contests, and to provide the results thereof such as success stories and names of contest winners;

h. to provide information about the User and their potential interests based on their activity and searches conducted on the Application/ Website;

i. to help other registered users find the profile and connect with the User;

j. to detect, investigate and prevent activities that may violate our policies or be illegal;

k. to generate internal reports about the use of our Application/ Website; and

l. to share information with third-party tools including, but not limited to, Google Analytics; Firebase Analytics, and Google Map Services to provide certain data to third parties (including the developer of the Application/ Website) as and when required; and

m. to provide any other services which are essential, related and incidental to the Purposes.

If the terms and conditions of this Privacy Policy are not accepted by a User, we would request such User not use or access the Application/Website.

V. Information We Collect

Throughout the course of the relationship with the User, SCCI would need to collect the User’s Personal Information. The Personal Information collected by us will primarily fall under the following categories:

a. Information collected directly from the User;

b. Information collected automatically by the Application/Website, and

c. Information collected from third parties.

a. Information collected directly from the User: The User may provide us with the requisite Personal Information when they are using the Application/Website including, but not limited to, real name, gender, age, phone number, email address, city, country etc. to register for the Championship.

b. Information collected automatically: The Application/Website will automatically collect certain information as soon as the User visits/uses/registers on the Application/Website. The type of information so collected may vary, but generally includes the device information (including IP address, URL, device ID, device model, network type, OS version, etc.), data usage while using the Application/Website, browsing behaviour while using the Application/Website, etc.

c. Information collected from third parties: When you access the Application/Website using a third-party platform, such as Google, Apple, Twitter, Facebook etc., certain information (including Personal Information) may be collected from your profile/account on the third-party platforms (as permitted by the terms of the third party platform and your privacy settings thereon.

VI. Accuracy of the Personal Information provided by the User

The User confirms that the Personal Information provided by them is accurate, true, complete, and not out of date. It is clarified that SCCI shall not be responsible for the authenticity and accuracy of the Personal Information provided by the User on the Application/Website.

VII. Cookie and Related Technologies

The Application/Website uses cookies and other technologies to recognize the User’s browser or device, learn more about their interests, and provide them with essential features and services and for additional purposes. Approved third parties may also set cookies and related technologies when the User uses our Application/Website.

VIII. Disclosure and transfer of the information to third parties

a. SCCI may disclose and transfer the Personal Information to third parties for one or more of the Purposes listed in Clause IV above. In this regard, the User acknowledges, agrees and consents that SCCI is permitted to disclose and transfer their Personal Information to such third parties for one or more of the abovementioned Purposes.

b. Without limiting the generality of the foregoing or of the immediately preceding paragraph setting out the Purposes, such third parties include service providers that SCCI engages to perform services relating to the Championship, including hosting and other internet services, data storage and analytics, marketing research and campaign management, event organizing, investigation regarding potentially illegal activities and suspected fraud, information technology and data processing services, and any other third party/ service provider, as deemed necessary by SCCI.

c. All such third-parties/ service providers are required to take appropriate security measures to protect the Personal Information in line with this Privacy Policy and the applicable laws.

d. SCCI may also share your Personal Information where such disclosure is essential to comply with a legal obligation or a lawful data access request.

IX. Security and data storage

At SCCI, all the security procedures are in place to protect the confidentiality, integrity and availability of the User’s Personal Information. We maintain strict physical, electronic, and administrative safeguards to protect the User’s Personal Information from unauthorized or inappropriate access.

We follow generally accepted standards to collect, store and protect Personal Information.

We will take all reasonable efforts to ensure the confidentiality of the Personal Information and will make reasonable efforts to ensure that the Personal Information received from the User is not misused.

While the Application/Website will take the above reasonable measures to guard against the misuse of the Personal Information submitted to it by the User, SCCI cannot guarantee that someone will not breach our security measures including, without limitation, the security measures implemented on the Application/Website. Therefore, posting of the Personal Information by the User on the Application/Website shall constitute acceptance of the said risk by the User.

X. Your Data Protection Rights Under General Data Protection Regulation (GDPR)

a. If You are from the European Economic Area (EEA), our legal basis for collecting and using your Personal Information depends on the information we collect and the specific context in which we collect it. We may process your Personal Information because:

• we need to perform a contract with the User;

• You have given us permission to do so;

• the processing is in our legitimate interest, and it is not overridden by any of your rights; and

• to comply with the law.

b. If You are a resident of the EEA, You have certain data protection rights, including the following:

• right to access, update or to delete the Personal Information;

• right of rectification;

• right to object;

• right of restriction;

• right to data portability; and

• right to withdraw consent.

XI. Data Retention Policy

The Service Provider will retain User provided data for as long as you use the Application and for a reasonable time thereafter.

If you'd like them to delete User Provided Data that you have provided via the Application, please contact them at swedishchampionship@gmail.com and they will respond in a reasonable time.

XII. Links and Third Party Services

If you click on a link to a third party website including, without limitation, an advertisement, you will leave our Application/Website and go to the website of the said third party. Because SCCI cannot control the activities of third parties, we do not take responsibility for any use of your Personal Information by the said third parties.

XIII. Amendments

We may amend, at our discretion, any portion of this Privacy Policy at any time by posting or displaying the amended Privacy Policy on the Application/Website. We will provide notice on our Website or by other appropriate means to the User if these changes are material, and where required by the applicable laws. The User will be deemed to have accepted such amendments by continuing to use the service, so please review it frequently. The User can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.

XIV. Limited use disclosure

Swedish Corporate Championship use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements. SCC App requires you to log in with your Gmail account which is linked to your Google Fit App, in order to fetch your step counts, to compare and declare a winner.

XV. Contact Us

If you have any questions about this Privacy Policy or your dealings with this Application/Website, please contact the Grievance Officer, whose contact information is provided herein below:

Name: Mr. Karan Dua

Contact details: (M) + 91 9899186282; (E) swedishchampionship@gmail.com

Address: Swedish Chamber of Commerce India, Nyaya Marg, Chanakyapuri New Delhi - 110021