Privacy Policy - Prenly
According to Swedish data protection legislation and the GDPR (General Data Protection Regulation), you, as the data controller, are required to provide a valid privacy policy.
If you also have an Android or iOS app, you are required to provide a valid privacy policy in accordance with Google's and Apple's guidelines.
If you do not have your privacy policy, you can refer to Generate a Privacy Policy.
It's important to keep in mind that your privacy policy must clearly outline how you, as the data controller, collect, use, and potentially share user data.
You are not allowed to process user data that is not specified in your privacy policy.
User Data
Personal and sensitive user data includes any information that can be directly or indirectly linked to a specific (natural) person.
- Personal identity number
- Contact information, such as email address and phone number
- Payment information or other financial details
- Authentication details (i.e. login credentials)
- Authorization details (i.e. subscription information)
- Health-related information, including sexual orientation
In other words, any information that can identify a specific user from among all available users when using the service/product.
Google's requirements
Your privacy policy must...
- ...describe what data the app can access or collect about the user.
- ...explain how the data [1] is used and/or shared.
- ...not be combined with other disclosures that are unrelated to the collection of personal and/or sensitive user data.
- ...the term "Privacy Policy" must appear somewhere in the text. Google will translate the information into English, and if their translation tool cannot find the phrase "Privacy Policy," the policy will be rejected.
- ...be directly accessible via a URL (web address) without a paywall, and the page must not be editable. A linked PDF is not allowed.
- ...cannot be partial. The full policy must be accessible via the URL and cannot link to external resources such as "read more".
Sources
Frequently Asked Questions
- Do I need a privacy policy?
- Yes, if you have an e-paper, you are required to have a privacy policy.
- Can I place my privacy policy behind a login?
- No. The privacy policy must be publicly accessible in full via a website. It may not be provided as a downloadable document, such as a PDF or MS Word file.
- Can I include my privacy policy in my e-magazine?
- Yes, that's possible. You can include it as an article in an open digital publication via Prenly Workspace, and the article can serve as a webpage for your privacy policy.