Privacy Policy

We collect your personal data in the following ways:

• When you create a user account with us.

• Via our website or app, including via cookies and similar technologies.

• Through e-mail correspondence.

• When you provide us with data through meetings, social media, events, or otherwise in the course of our business relationship with you.

We process the following categories of personal data:

• Basic information, such as name, age, and gender.

• Contact information, such as email address and telephone number.

• Information you upload to our website and app, which may include answers to pre- and post-training questions on physical and mental readiness, general wellbeing, and similar matters ("Wellbeing Data").

• Information derived from your use of our website and platform.

• Technical data, which may include your URL, IP address, unique device ID, network and computer performance, browser type, language and identifying information, geographic location, device type, and operating system.

• E-mail correspondence.

Below is a description of the purpose and legal basis for the processing of your personal data.

• Purpose: To provide you or the organization you represent with our services. Legal basis: Performance of a contract (if there is a contract between Welloop and you or the organization you represent).

• Purpose: To market our products and services through, for example, newsletters and similar communication. Legal basis: Legitimate interest (Welloop's legitimate interest in promoting its products and services).

• Purpose: To manage our business relationship with you. Legal basis: Performance of a contract (if there is a contract between Welloop and you or the organization you represent) and/or Legitimate interest (Welloop's legitimate interest in maintaining and managing its business relationships).

• Purpose: To receive payments from customers in connection with purchases of Welloop's products and services. Legal basis: Performance of a contract (necessary for the performance of the agreement between Welloop and you or the organization you represent).

• Purpose: To comply with legal obligations. Legal basis: Comply with a legal obligation (e.g., applicable accounting and tax legislation).

• Purpose: To establish, defend or exercise legal claims, such as to demand performance or enforcement from public authorities or courts. Legal basis: Legitimate interest (Welloop's legitimate interest in establishing, defending or exercising legal claims).

• Purpose: To ensure the technical functionality of our website; and to analyze your usage so that we can develop and improve the website. Legal basis: Legitimate interest (ensuring technical functionality of the website and app) and/or Consent (processing that is not necessary to provide the website and app will only take place if you have given your consent to this).

Please note that the core functionality of the Welloop platform is provided as a service to your sports club. This means that Welloop acts as a data processor and your club as the data controller, and in these cases, your club's own privacy policy applies.

If you would like more information about how your club processes personal data about you in our platform, please refer to your club’s privacy policy or contact your club.

However, if you have given your consent to Welloop to process your personal data, with Welloop acting as an independent data controller, we will perform processing of certain personal data in your capacity as a user of our platform.

Below is a description of the purpose and the legal basis for the processing of your personal data in your capacity as a user of our platform.

• Purpose: To anonymize and aggregate data generated through your use of the Welloop platform, including Wellbeing Data. Legal basis: Consent (only if you have given your consent through the platform interface).

• Purpose: To use and share aggregated data with third parties for research purposes. Legal basis: Consent (only if you have given your consent through the platform interface).

• Purpose: To use aggregated data to market our, and our partners’ and customers’, products and services. Legal basis: Consent (only if you have given your consent through the platform interface).

• Purpose: To comply with legal obligations. Legal basis: Comply with a legal obligation (e.g., applicable research and archiving legislation).

• Purpose: To establish, defend or assert legal claims, such as to demand performance or enforcement from public authorities or courts. Legal basis: Legitimate interest (Welloop's legitimate interest in establishing, defending or asserting legal claims).

• Purpose: To ensure the technical functionality of our website and app; and to analyze your usage so that we can develop and improve the website and app. Legal basis: Legitimate interest and/or Consent (processing that is not necessary to provide the website and app will only take place if you have given your consent to this).

Your personal data is stored only for as long as there is a need to keep such data in order to fulfil the purposes for which such data was collected in accordance with this Privacy Policy.

Personal data will be deleted when the purpose of the processing has been achieved, or if you withdraw your consent (if applicable) to the processing of Personal Data (for contact information, please see “How to contact us” below).

We may disclose or share your personal data with the following categories of recipients:

• Social media platforms, such as Instagram, TikTok, Facebook, LinkedIn and X (Twitter), for the purpose of promoting our services. If you use these services, please refer to the privacy policy of the respective platform for information on how they process personal data about you as a user.

• Collaboration and research partners.

• Auditors and other professional advisors.

• Service companies and suppliers, for example third-party providers of IT services.

• Other third parties where necessary to comply with a legal obligation or to establish, assert or defend legal claims.

We strive to keep all of your data within the EU/EEA.

[However, some of Welloop's IT providers operate in the United States. When personal data is shared with these providers, Welloop has ensured that the level of protection corresponds to that applicable within the EU/EEA through the suppliers' accession to the EU-U.S. Data Privacy Framework ("DPF"). More information about DPF is available on https://www.dataprivacyframework.gov/s/. For any entities which have not acceded the DPF, the European Commission's standard contractual clauses are applied for the transfer. For more information on these clauses, see: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en]

Any transfer of your personal data outside the EU/EEA will be subject to appropriate safeguards in accordance with applicable data protection legislation.

We use a range of technical and organizational measures to protect your data from unauthorized access, use, loss, alteration or deletion in accordance with applicable data protection legislation.

Such measures include, but are not limited to, [physical controls, encryption, permission restrictions, and internal policies].

As data controller, Welloop is responsible for ensuring that your personal data is processed in accordance with applicable data protection legislation. You have the following rights in relation to your personal data:

• Rectification: Welloop will, at your request or on its own initiative, correct, de-identify, delete or supplement information that is found to be incorrect, incomplete or misleading. You are always entitled to request that we correct or update your personal data.

• Deletion: You have the right to request erasure of your personal data (e.g. if your data has been stored longer than necessary). Welloop will notify each recipient to whom the personal data has been disclosed of any deletion of data that takes place under this section.

• Restriction: You have the right to request restriction of further processing of your personal data (e.g. if you question the accuracy of the personal data). Welloop will notify each recipient to whom the personal data has been disclosed of any restriction of processing of data that takes place under this section.

• Objections: You have the right to object to processing of your data that takes place on the legal basis that we have a legitimate interest. Unless there are compelling legitimate reasons that justify continued processing despite your objection, Welloop will cease the processing.

• Data portability: You have the right to data portability, i.e. the right, under certain conditions, to receive and transfer your personal data in a structured, commonly used and machine-readable format to another data controller.

• Direct marketing: If you do not want Welloop to process your personal data for direct marketing purposes, you have the right to notify Welloop of this in writing at any time. Once Welloop has received your notification, Welloop will cease to process the personal data for this marketing purpose.

• Access: You have the right to receive, free of charge, an extract from Welloop containing information about how we process your personal data. The extract contains, among other things, information about the purposes for which we use your personal data, to which recipients the data has been disclosed and for how long the personal data will be stored or the criteria used to determine this period. You also have the right to receive a copy of your personal data. In the event that the personal data has not been collected directly from you, you also have the right to receive information about where it has been obtained from.

• Consent: If you have given your consent to a particular processing of personal data, you have the right to withdraw your consent at any time. If you choose to withdraw your consent, Welloop will cease the processing covered by the withdrawal and delete your personal data, unless there is another lawful purpose or legal basis that justifies further processing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing carried out prior to such withdrawal. [You can withdraw your consent to the processing of your Wellbeing Data directly in the platform's account settings.]

• Right to lodge a complaint with a supervisory authority: You are welcome to contact us if you have any complaints regarding our processing of your personal data, to allow us to address and, if necessary, rectify our processing practices. You also have the right to submit any complaints regarding Welloop's processing of your personal data to the Swedish Authority for Privacy Protection (IMY), or another competent supervisory authority within the EU/EEA.

A cookie is a text file that is placed on your computer by the web server you visit. We use cookies for various purposes. Some cookies are necessary to provide our services, while other cookies are used for statistical or marketing purposes.

Welloop's website uses both so-called session cookies and persistent cookies. Session cookies are only stored during your visit to the website, while persistent cookies are stored after you leave the website (but for a maximum of 2 years).

For more information about how Welloop uses cookies, please refer to www.welloop.se/legal-cookies.

If you do not wish to receive cookies, you can find information on how to prevent your browser from accepting new cookies in the help section of most browsers. Depending on the browser you use, you may also be able to set your browser to notify you when you receive a new cookie.

You may also disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on's settings or visiting the manufacturer's website.

Welloop reserves the right to make changes to this Privacy Policy at any time.

If material changes to the Privacy Policy are made, Welloop will notify you of such changes by email, provided that Welloop has access to your email address, or by other appropriate means.

If you have any questions regarding this Privacy Policy or our processing of your personal data, or if you wish to exercise any of your rights under applicable data protection legislation, you may contact us at: [email address].