How BabyNaps processes your personal data
BabyNaps AB’s (“BabyNaps”) processing of personal data is in accordance with the General Data Protection Regulation (GDPR) and other legislation, legal practices and general advice which applies at any given time regarding personal data (“Applicable Legislation”). This means that BabyNaps protects your personal data by taking the necessary technical and organizational security measures in each individual case, and that you are entitled to contact us at any time to find out what personal data we have stored about you.
You can read more about your rights in this policy and visit www.IMY.se for additional information about the processing of personal data. You are always welcome to contact us if you have any questions about how we process your personal data.
1. Who is responsible for personal data about you and your child or your babysitter?
BabyNaps AB, corporate ID no. 559294-7401, is the personal data controller for our processing of personal data about you, anyone you have invited to the app and your child, and is responsible for ensuring that such processing occurs in a lawful manner, in compliance with the Applicable Legislation. Please do not hesitate to contact us if you have any questions about how we process personal data.
Our contact details are as follows:
531 99 Lidköping
2. Our processing of personal data in connection with visits to our website or social media and in contact with us
2.1 How does BabyNaps obtain your personal data?
We may process personal data that you provide to us when, for example, you contact us via social media, email, telephone or mail, register for our newsletter, our events or our email courses or when you otherwise use our website.
2.2 What types of personal data and information are processed?
Examples of personal data that we may process include contact details such as name, address, email address and telephone number, IP address, the content of messages and/or attachments that you send us or other necessary information containing your personal data that is needed for each purpose.
2.3 Why does BabyNaps process data about you?
We may process your personal data for the following reasons, among others:
- to answer questions that you send us,
- to send newsletters with tips and advice, as well as discounts from our partners,
- to send information about different events,
- to process and administer your registration to events and email courses,
- so that our partners can send targeted advertisements to you,
- to keep statistics on the use of our services and visits to digital channels, so we can develop these to improve your experience,
- to provide support in using the App if you have contacted us for this reason,
- to detect and prevent fraud, misuse, attempted breaches, cyber attacks and other improper use,
- to manage legal requirements in laws and regulations, and
- to otherwise comply with our commitments.
2.4 When does BabyNaps have the right to process your personal data?
We only process your personal data when we have legal grounds to do so. We process your personal data (1) on the basis of a balance of interests, where, for example, we have a legitimate interest in being able to offer you a good service, (2) when the processing is necessary so that you are able to enter into an agreement with us, (3) in order to comply with our legal obligations as a result of requirements in laws or regulations, for example, or (4) if you have given consent to the processing. You can read more about consent in the “What are your rights?” section below.
3. Our processing of personal data when you use the app
3.1 How does BabyNaps access to personal data?
We collect personal data that you provide to us or that is obtained when you use the App.
3.2 What types of personal data and information are processed?
Accessing the App only requires the App to be downloaded and then log-in via Apple ID or using a Google account (“User ID”). You don’t need to create a specific account in the App. Examples of personal data that may be processed include your User ID, email address and subscription type.
When you use the App, you can choose to enter your child’s date of birth (YYYY-MM-DD) and your child’s name or nickname. You also have the option to enter information about your child’s sleep routines and to upload a picture of your child. This information will also constitute personal data that we will process.
If you wish to share your account on the App with a babysitter, for example, you can easily do this. To do this, enter the name of the person you wish to share the account with and their role, such as a babysitter. This information will also constitute personal data that we will process.
When you use the App, BabyNaps collects statistics about how you use the App in your capacity as a user, known as user data. Your user data is anonymized, which means that neither BabyNaps, nor any other party, can trace back such user data to you as an individual. Since your user data are anonymized, they are not considered to be personal data and they therefore are not covered by the General Data Protection Act (GDPR). The following anonymized user data are collected: the user’s gender and age bracket, the operating system that is used, and the country where the user is located. User data are stored in Google Firebase.
3.3 Why does BabyNaps process data about you, your child and your babysitter?
We may process your personal data (and where applicable a babysitter’s personal data) for the following purposes, among others:
- in order to offer a well-functioning service and app that meet your wishes and expectations,
- in order to develop the App to improve your experience,
- to manage legal requirements in laws and regulations, such as the Swedish Accounting Act, and
- to otherwise comply with our commitments.
We may process your child’s personal data such as date of birth, name/nickname and picture for the following purposes:
- in order to offer you, in your capacity as user, a sleep schedule for your child based on statistics, and
- so that you can have a personally designed experience based on your wishes to be able to see your child’s name and/or picture.
We may process your child’s personal data, such as your child’s sleep routines, which you enter in the App yourself for the following purposes:
- in order to offer you a more customized and personal sleep schedule for your child.
3.4 When does BabyNaps have the right to process personal data about you, your babysitter and your child?
We only process your personal data when we have legal grounds to do so. We mainly process your personal data because this is necessary for us to fulfill your agreement with us. Otherwise, we may process personal data in order to comply with legal obligations resulting from requirements in laws or regulations, for example, or because we have a legitimate interest.
Any babysitter’s personal data in the form of name and role is processed on the basis of a balance of interests where we have a legitimate interest in processing the personal data.
Your child’s personal data will normally only be processed by us if you have given consent to this in your capacity as the parent or guardian. You provide your consent to the processing of personal data separately in the App. You are entitled to withdraw your consent at any time. If you wish to read more about consent, you can do this in the section entitled “What are your rights?” below.
We may also need to process the personal data of any babysitters and/or your child’s personal data as a result of legal or regulatory requirements.
4. Who has access to personal data about you and your child or your babysitter?
We want you to feel confident about allowing us to process personal data about you, your babysitter and your child. The individuals at BabyNaps who need to access the personal data in order to fulfil the purposes for which the personal data are intended have access to and the authorization to process the personal data collected on you.
You have the option to choose whether you wish to share your child’s sleep schedule with your friends and family. In such cases, you may also choose to give the person access to your account. If you share your account with somebody, that person will receive a code by SMS or another messaging service of your choice. The person will then have access to all information in the App and can contribute information about the child’s sleep. You can remove the invited person’s access to your account at any time.
We do not disclose personal data to other companies or the authorities unless we are required to do so by law, ordinance, regulations or governmental decision, or to protect our rights or the rights of any third party.
In the event of a company merger, consolidation, restructuring or sale of substantially all shares and/or assets or other form of reorganization, personal data may be divulged to the subsequent owners, part-owners and their consultants in connection with the reorganization.
5. Transfer to a third country
As a rule, BabyNaps does not transfer personal data to countries outside the EU/EEA (third countries). In the processing of newsletters, a limited transfer of personal data may occur to an engaged company in the USA. We ensure that such transfer is subject to particularly strict requirements, entering into an agreement with standard contractual clauses which fulfil the requirements for appropriate protection measures stipulated in the GDPR.
7. How long does BabyNaps store personal data about you and your child or your babysitter?
We only store personal data for as long as is necessary in order for us to fulfill the purpose of the processing of personal data in each case. Typical occasions when data is removed include the following.
- If you ask to close your account connected to the App, your personal data will be anonymized or deleted after two months.
- If you contact us to ask a general question, your personal data will normally be deleted two months after the case is closed.
- If you have entered a babysitter’s personal data when sharing your account in the App, the babysitter can disconnect from the account and delete their personal data at any time.
- If you withdraw consent, we will delete the personal data that are processed on the basis of this consent.
The timescale for our processing of personal data may differ from the information above. This applies if certain processing is required by our statutory obligations, such as the requirements set out in the Accounting Act which stipulates that necessary personal data currently needs to be kept for seven years after the end of each calendar year, or if there is another legitimate interest.
8. What are your rights?
It is important to us that you are aware of your rights and that you can contact us at any time for more information about the rights below. You can find the contact information under the heading “Who is responsible for personal data about you and your child or your babysitter?” above. The information you requested will be sent to your address as it appears in the population register.
The information below also applies to those who have gained access to an account as a result of a parent or babysitter sharing their account.
Right to request access to personal data
We always wish to be transparent about how we process personal data. If you wish to have confirmation that personal data about you or your child is being processed, or to learn what personal data about you or your child is being processed, you have the right to request access to such data. At the same time, you will also receive information about the purposes for processing, what personal data the processing applies to, the recipients or categories of recipients to whom the personal data has been sent or will be sent and, if possible, the anticipated period during which your personal data will be stored or the criteria used to determine the period. Information about further rights is provided at the same time and you will receive a copy of the personal data that is being processed. Your request must be made in writing and signed personally. We need this information to ensure that we release the data to the right person.
Right to have personal data corrected
You have the right to request that incorrect personal data about you or your child are corrected without undue delay. You also have the right to provide additional personal data that are missing and that are relevant with regard to the purpose of processing the personal data. You can also change your child’s personal data in the App yourself.
Right to have personal data deleted
You have the right to have your or your child’s personal data deleted. We will delete personal data at your request without undue delay, to the extent that this is possible in accordance with applicable law. This right applies, for example, when personal data are no longer necessary for the purpose for which they have been collected or otherwise processed, if you withdraw your consent or object to the processing, if the personal data have been processed in an unlawful way or if the personal data must be deleted so as to comply with a legal obligation, provided there is no reason pursuant to applicable law that makes the processing necessary. Processing may, for example, be necessary in order to exercise the right to freedom of information and expression, to comply with a legal obligation or to determine, present or defend a legal claim.
Right to have processing restricted
You also have the right to restrict our processing of your personal data or your child’s personal data. You can, for example, do this if you contest the correctness of the personal data, if the processing is unlawful, if the personal data are no longer needed for the purpose of processing but you need them in order to be able to determine, present or defend a legal claim or when awaiting any check on whether our legitimate interest carries more weight than your legitimate interest.
Right to object to processing
You also have the right to object at any time to our processing of your personal data or your child’s personal data when this relates, for example, to direct marketing or for reasons relating to your specific situation when the processing is based on a legitimate interest.
Right to data portability
Under certain conditions, you have the right to have your personal data or your child’s personal data transferred, in a structured, generally used and machine-readable format, to another Personal Data Controller when this is technically possible – what is known as the right to data portability. This applies when the processing of personal data is based on consent or on an agreement and the processing is done automatically.
Right to withdraw consent
You also have the right to withdraw your consent for certain personal data processing at any time. If you withdraw your consent, we will delete the personal data that is processed on the basis of this consent. Withdrawal of consent does not affect the legality of processing that was performed before the withdrawal occurred.
Right to lodge a complaint
If you consider that we have processed your personal data or your child’s personal data in an incorrect way, you have the right to lodge a complaint with the Swedish Authority for Privacy Protection.
9. How are personal data protected?
It is important that the personal data we process are protected. We therefore work continuously to take all appropriate technical and organizational measures necessary in each individual case to protect personal data about you and your child from unauthorized access, modification, loss, disclosure or destruction and to otherwise ensure that all processing complies with applicable legislation. Our work is structured in such a way that only those who require access to personal data in order to fulfil the purposes for processing are given the authority to access the personal data.