Privacy Policy

This Privacy Policy describes how we collect, use, process, and disclose your information, including personal information, in conjunction with your access to and use of the The Roll website and e-coaching platform

When this policy mentions "The Roll", we, us, or our, it refers to the The Roll AB company that is responsible for your information under this Privacy Policy (the Data Controller).

 

Data Controller

The entity responsible for the processing of your personal information is:

The Roll AB

Eriksbersgatan 10

114 30, STOCKHOLM, SWEDEN

Company number: 556845-3764

Telephone: +46(0)700 25 54 20

Email: inca.whyte@theroll.com

 

Information we collect

There are three general categories of information we collect.

Information you gave to us

Information that is necessary for the use of the The Roll website and e-coaching platform

We ask for and collect the following personal information about you when you use the The Roll website and/or e-coaching platform. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.

Account information

When you sign up for an The Roll Account, we require certain information such as your first name, last name, email address, and date of birth.

Communications with The Roll

When you communicate with The Roll, we collect information about your communication and any information you choose to provide.

Information you choose to give us

You may choose to provide us with additional personal information in order to obtain a better user experience when using The Roll website and e-coaching platform. This additional information will be processed based on your consent.

 

Additional Profile Information

You may choose to provide additional information as part of your The Roll profile (such as gender, preferred language(s), city. Some of this information as indicated in your Account settings is part of your profile page, and will not be publicly visible to anyone other then a coach and peers if you may have one and/or the others.

Address Book Contact Information

You may choose to import your address book contacts or enter your contacts’ information manually to access certain features of the The Roll client portal, like inviting them to use The Roll client portal.

Other Information

You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your The Roll Account, respond to surveys, post to community forums, participate in promotions, or use other features of the The Roll website and client portal.

 

Information we automatically collect from your use of the The Roll website and client portal.

When you use the The Roll website or clients portal, we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for the adequate performance, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the The Roll website and client portal.

Geo-location information

When you use certain features of the The Roll website and client portal, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. The Roll may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.

Usage information

We collect information about your interactions with the The Roll website and client portal such as the pages or content you view and other actions on the The Roll website and client potal.

Log data and device information

We automatically collect log data and device information when you access and use the The Roll website and client portal, even if you have not created an The Roll Account or logged in. That information includes, among other things: details about how you’ve used the The Roll website (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the The Roll website.

Cookies and similar technologies

We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers. We may also allow our business partners to use these tracking technologies on the The Roll website, or engage others to track your behavior on our behalf. While you may disable the usage of cookies through your browser settings, the The Roll website currently does not respond to a Do Not Track signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted. For more information on our use of these technologies, see our Cookie Policy.

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link.

You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.

Information we collect from third parties

The Roll may collect information, including personal information, that others provide about you when they use the The Roll website and client portal, or obtain information from other sources and combine that with information we collect through the The Roll website and client portal. We do not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

Third Party Services

If you link, connect, or login to your The Roll Account with a third party service (e.g. Google, Facebook), the third party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.

Other Sources

To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the The Roll website and client portal through partnerships, or about your experiences and interactions from our partner ad networks.

 

How we use information we collect

We use, store, and process information, including personal information, about you to provide, understand, improve, and develop the The Roll website and client portal, create and maintain a trusted and safer environment and comply with our legal obligations.

Provide, improve, and develop the The Roll website and client portal.

Enable you to access and use the The Roll website and client portal.

Operate, protect, improve, and optimize the The Roll website and client portal and experience, such as by performing analytics and conducting research.

Provide customer service.

Send you service or support messages, updates, security alerts, and account notifications.

If you provide us with your contacts’ information, we may process this information: (i) to facilitate your referral invitations, (ii) send your requests for references, (iii) for fraud detection and prevention, and (iv) for any purpose you authorize at the time of collection.

To operate, protect, improve, and optimize the The Roll website and client portal experience, and personalize and customize your experience (such as making Listing suggestions or ranking search results), we conduct profiling based on your interactions with the The Roll website and client portal, your search, your profile information and preferences, and other content you submit to the The Roll website.

We process this information given our legitimate interest in improving the The Roll website and client portal and our Members’ experience with it, and where it is necessary for the adequate performance of the contract with you.

Create and maintain a trusted and safer environment

Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.

Conduct security investigations and risk assessments.

Comply with our legal obligations.

Resolve any disputes and enforce our agreements with third parties.

Enforce our Terms & Conditions and other policies.

In connection with the activities above, we may conduct profiling based on your interactions with the The Roll website and client portal, your profile information and other content you submit to the The Roll website and client portal, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the The Roll website and client portal if such processes detect a Member or activity that we think poses a safety or other risk to the The Roll website and client portal, other Members, or third parties.

We process this information given our legitimate interest in protecting the The Roll website and client portal, to measure the adequate performance of our contract with you, and to comply with applicable laws.

Provide, personalize, measure, and improve our advertising and marketing

Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about The Roll or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google).

Personalize, measure, and improve our advertising.

Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by The Roll or its third party partners.

Conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the The Roll website and client portal, information obtained from third parties, and your search) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you.

We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your The Roll Account.

 

Sharing & disclosure

With your consent

Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your The Roll Account or when you participate in promotional activities conducted by The Roll partners or third parties.

Compliance with law, responding to legal requests, preventing harm and protection of our rights.

The Roll may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against The Roll, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Service or other agreements with Members, or (v) to protect the rights, property or personal safety of The Roll, its employees, its Members, or members of the public.

Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon The Roll’s property, its Members and the The Roll website and client portal. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that Member about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

 

Service providers

The Roll uses a variety of third party service providers to help us provide services related to the The Roll website and client portal. Service providers may be located inside or outside of the European Economic Area (EEA).

For example, service providers may help us: (i) perform product development, maintenance and debugging, (ii) conduct background or police checks, fraud prevention, and risk assessment, (iii) allow the provision of the The Roll Services through third party platforms and software tools (e.g. through the integration with our APIs), or (iv) provide customer service, advertising, or payments services. These providers have limited access to your information to perform these tasks on our behalf and are contractually bound to protect and to use it only for the purposes for which it was disclosed and consistent with this Privacy Policy.

The Roll will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.

 

Social media platforms

Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the The Roll website. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest.

The social media platforms with which we may share your personal data are not controlled or supervised by The Roll. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider.

Please note that you may, at any time ask The Roll to cease processing your data for these direct marketing purposes by sending an e-mail to inca.whyte@theroll.com.

 

Business transfers

If The Roll undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

 

Aggregated data

We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

 

Other important information

Linking third party accounts

You may link your The Roll Account with your account at a third party social networking service. Your contacts on these third party services are referred to as “Friends.” When you create this link:

The information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes;

The publication and display of information that you provide to The Roll through this linkage is subject to your settings and authorizations on the The Roll website and the third party site.

We only collect your information from linked third party accounts to the extent necessary to ensure the adequate performance of our contract with you, or to ensure that we comply with applicable laws, or with your consent.

 

Google Maps/Earth

Parts of the The Roll website use Google Maps/Earth services, including the Google Maps API(s). Use of Google Maps/Earth is subject to Google Maps/Earth Additional Terms of Use and the Google Privacy Policy.

 

Third party partners & integrations

The The Roll website may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (Third Party Partners). The Roll doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, The Roll, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.

 

Your rights

You may exercise any of the rights described in this section before your applicable The Roll Data Controller by sending an email to inca.whyte@theroll.com. Please note that we may ask you to verify your identity before taking further action on your request.

 

Managing your information

You may access and update some of your information through your Account settings. If you have chosen to connect your The Roll Account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up-to-date.

 

Rectification of inaccurate or incomplete information

You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your The Roll Account).

 

Data access and portability

In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

 

Data retention and erasure

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the The Roll website to you, you can request that we erase your personal information and close your The Roll Account. Please note that if you request the erasure of your personal information:

We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an The Roll Account for fraud or safety reasons, we may retain certain information from that The Roll Account to prevent that Member from opening a new The Roll Account in the future.

We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, The Roll may keep some of your information for tax, legal reporting and auditing obligations.

Because we maintain the The Roll website to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

 

Withdrawing consent and restriction of processing

Where you have provided your consent to the processing of your personal information by The Roll you may withdraw your consent at any time by changing your Account settings or by sending a communication to The Roll specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular, where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 7.6 and pending the verification whether the legitimate grounds of The Roll override your own.

 

Objection to processing

In some jurisdictions, applicable law may entitle you to require The Roll not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing The Roll will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.

Where your personal information is processed for direct marketing purposes, you may, at any time ask The Roll to cease processing your data for these direct marketing purposes by sending an e-mail to inca.whyte@theroll.com.

 

Lodging complaints

You have the right to lodge complaints about the data processing activities carried out by The Roll before the competent data protection authorities.

 

Security

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your The Roll Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your The Roll Account, please contact us following the instructions in the Contact Us section below.

 

Changes to this privacy policy

The Roll reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the The Roll website and update the “Last Updated” date at the bottom of this Privacy Policy. We will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the The Roll website will be subject to the revised Privacy Policy.

 

Contact us

If you have any questions or complaints about this Privacy Policy or The Roll’s information handling practices, you may email us or contact us at:

The Roll AB

Eriksbergsgatan 10

114 30, STOCKHOLM, SWEDEN

Company number: 556845-3764

Telephone: +46(0)700 25 54 20

Email: inca.whyte@theroll.com

 

Last Updated: April 25th, 2019