Privacy Policy for the Service Alex

Applicable from Aug 26, 2020

1. Introduction

1.1 Definitions

These concepts, with capital letters, are used consistently in the policy and are defined as follows:

• User: a natural person using the Alex service.
  
• Alex Therapeutics AB: supplier of the Service.
• The service: the cloud service and the mobile application Alex.
• Personal Data: any information relating to an identified or identifiable natural person, a User, in which an identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, a location task or an online identifier or one or several factors specific to the physical person's physical, physiological, genetic, mental, economic, cultural or social identity.
  
• Processing: a measure or combination of actions regarding personal data or sets of personal data, whether automated or not, such as collection, registration, organization, structuring, storage, processing or modification, generation, reading, use, transmission by transmission, dissemination or other means, adjustment or assembly, limitation, deletion or destruction.
  
  

1.2 Purpose and General

Alex Therapeutics AB's ("We") personal data processing follows the data protection("GDPR"), and this policy explains how We collect, use, protect and share the personal data We process about our users.

We take all appropriate technical and organizational security measures required to protect your personal information from improper access, change or destruction. If you can’t find the answer to any question, please contact us at: support@alextherapeutics.com

This privacy policy regulates:

• Data processing and integrity for the User
  

The service is an application on mobile phones that should serve as a tool for the User to quit smoking.

If you as a User do not agree to this policy, you will not be able to access the service. Please contact Alex Therapeutics AB to discuss alternative terms, via support@alextherapeutics.com.

1.3 Changes to the policy

Alex Therapeutics AB continuously updates this policy to reflect:

• (1) Changes in legislation or practice, or
  
• (2) Improvements or additions to the Service
  

We from Alex Therapeutics AB will notify you through the Service when the policy is updated. With this, we will request a renewed consent to continue processing your personal data in accordance with the updated policy.

2. Data processing and integrity

2.1 Personal data

Alex Therapeutics AB processes the personal data that you, as a User, enter into the Service. The categories of personal data processed are:

• Contact information, such as e-mail address
  
• User data, such as smoking habits and demographic data
  
• Customer support information, such as conversations with support for the Service
  

The above mentioned data is processed for the following purposes:

• Deliver the Service - For Alex to support you as you become and stay smoke free the Service uses your personal data, e.g. your smoking habits.
  
• Create market insights - In order to help as many people as possible, Alex creates statistics and market insights based on your contact information. You will not be contacted for marketing purposes, but Alex will be able to find others who are similar to you.
  
• Contact Users via email - You will occasionally get tips and support sent to your email, as a complement of the service. You can choose to unsubscribe at any time.
  

All of the above processing of data rely on the user's explicit consent.

For the above purposes, Alex Therapeutics AB may hire personal data assistants to produce statistical data and market insights. If this involves a transfer to a third country or an international organization, Alex Therapeutics AB will always ensure that there is a commission decision on the adequate level of protection or alternatively that the assistant through agreements or otherwise can guarantee appropriate protective measures.

You always have the right to:

• Access your personal data. You can request a copy of the information you would like to have and verify the information we have about you. A copy is free to request. In order to ensure that it is the right person who requests information, such a request must come from the email address that you have previously used to communicate with us.
  
• Get corrected from incorrect or incomplete personal information. Request for correction is sent to us via email address below.
  
• Have your data deleted in some cases, such as if your personal information is no longer necessary for the purposes for which they were collected.
  
• Restrict processing of your personal data in some cases - e.g. if you have objected to the processing of your personal data, which is done after balancing interest - in the meantime, control of whether our reasons weigh heavier than your interests, rights and freedoms.
  
• Get out and transfer personal data to another person responsible for personal data in some cases (data portability).
  
• You have the right to object to the processing of your personal data based on a balance of interests. Continued processing of your personal data requires, in such a case, that We may display mandatory justifications that outweigh your interests, rights and freedoms or whether it is for the purposes of the determination, exercise or defense of legal claims.
  
• You have the right to file a complaint regarding the processing to The Swedish Data Protection Authority or another data protection authority within the EU.
  
• At any time withdraw your consent to the processing of your personal information.
  
• If you request access to your information, you can send an email to support@alextherapeutics.com.
  

2.2 Collection of information

Alex Therapeutics AB collects anonymized information in the Service via automated data collection tools. Alex Therapeutics AB collects and uses such information in order to secure, maintain and improve the Service and to create reports based on statistics of anonymized user data. The information can also form the basis for market and customer analyzes, market surveys, research, business follow-up and business and method development, which takes place in the light of Alex Therapeutics AB's interest in monitoring and analyzing the use of the Service.

2.3 Storage of user data

If the User chooses to stop using the Service, the User's data is stored for sixty (60) days, after which Alex Therapeutics AB is entitled to delete the User's remaining material from Alex Therapeutics AB's servers. At the request of the User, all data shall be deleted immediately after the termination of the agreement.

The user's data will not be deleted if, due to current legislation or other authority decisions, there would be obstacles to Alex Therapeutics AB doing so.

2.4 Data security

For access to the Service, login with user name and activation code or password is required. It is the user's responsibility to ensure that login information to the Service is kept safe.

The login process is completely encrypted, which means that no information is sent in non-encrypted form.

3. Change log

3.1 Version

• v. 1 released 2018-05-01, comes into force 2018-05-01.
  
• v. 2 released 2018-10-10, comes into force 2018-10-10.
  
• v. 3 released 2018-10-23, comes into force 2018-10-23.
  
• v. 4 released 2019-06-07, comes into force 2019-06-07.
  
• v. 5 released 2019-12-09, comes into force 2019-12-09.
  
• v. 6 released 2020-08-26, comes into force 2020-08-26.