This privacy notice contains information about how we will collect, use and process personal data, with whom we may share such data and your rights in relation to your personal data. By personal data we mean any information that refers to an identified or identifiable natural person. In order to use our Services you must accept the content of this Privacy Notice. If you do not agree with this the content in general or any part of it, you should not use our Services.
We are responsible
This privacy notice concerns users of the Milkywire app, distributed on the App Store and on Google Play, users of www.milkywire.com, and subscribers of Milkywire's newsletter (collectively referred to as the “Services”), provided by Milkywire AB, company registration number 559156-8018, having its registered address at Karlbergsvägen 7, 113 27 Stockholm (“Milkywire”), named in the notice as we or us.
Milkywire shall be considered the controller of any processing of personal data as specified in this privacy notice.
Milkywire ensures that your personal data is handled with adequate security measures in order to protect your personal data against unlawful or unauthorized access.
Milkywire only gathers information that is needed to provide the Services to you and to make improvements for your benefit as a user.
Data that we collect
Data is both provided directly by you while interacting with the Services and collected indirectly (or passively) as you navigate the Services.
Personal information you provide us directly:
Account details such as email, full name, profile picture
Communications you send to us, including but not limited to, support requests, comments, or notifying us of any problems with the Services
Technical information indirectly collect about you:
Behavioral information indirectly collect about you:
Information regarding your use of the Services, such as the pages you visit and how you interact with those pages, engagement scores (“likes”, comments, messages) and other user generated content, as well as any interaction data with our online ads as made available to us by our third party advertising partners
Information about how you interact with Milkywire online ads, including the website where you clicked on the ad, if you created a user account, and the first time you logged on to the platform
Please note that we are unable to provide the Services unless you provide the above stated data.
Donation and payment data that we collect
When you make a donation on the Services, we collect data that is either provided by you through your actions, and by our third party payment processing partners.
Information you provide us directly:
Behavioral information related to donations and payments, such as donation dates, amounts, and donation history
Information you give us indirectly:
Details related to any financial requests or transactions you make while using the Services, as collected by our third party payment processing partners (currently, Stripe Inc.), and information submitted by you is collected and used by them in accordance with their privacy policies
For avoidance of doubt, payment card information such as card numbers, expiration dates or CVV verification numbers are collected and stored with our third party payment processing partners, and never with us.
How we use your information and legal bases
We will process the information set out above for the following purposes and legal bases.
Purpose: To deliver the Service to you. Legal basis: Fulfillment of contract
Purpose: To improve the Services. Legal basis: Legitimate interest
Purpose: For internal operations, including troubleshooting, data analysis, and testing
Legal basis: Legitimate interest
Purpose: To manage support and questions from customers. Legal basis: Legitimate interest, or fulfillment of contract depending on the question
How we share your information
We do not sell any of your personal data to third parties. We share your data with the following categories of third party service providers.
To enable payment as a part of our Services. Milkywire uses third party partners to process payments (currently Stripe, Inc.), and information submitted by you is collected and used by them in accordance with their privacy policies
Professional service providers who help us run our business, such as our host provider, marketing agencies and online marketing tools
To Facebook for login details, and ad tracking analytics for our online ads
To Google for 1) login details, 2) Firebase to allow on-platform login account creation, and tracking of email addresses among registered accounts to ensure that duplicate accounts are not created for one and the same email address, and 3) Google Analytics for our own internal analysis to help improve the platform further
To Hojtar for website performance and usage analysis
We may also share your personal data with law enforcement agencies, public authorities or government bodies as required by law
Some of your information will be visible to other users on the platform, such as your name, comments you write, and if you are an active donor. For avoidance of doubt, Milkywire will never share information with other users about your payment details, password, phone number, date of birth or other documentation for identity verification purposes, your IP address, or any communications you send to us.
All data is stored encrypted in data centers in Ireland, by our host provider. Access to data and technology relating to user information is adequately protected and access limited to authorized personnel.
We store your personal data for as long as necessary to perform the Services to you, unless there is a legal obligation to store the data for longer.
Under applicable data protection legislation you have the right to:
Request access and further information concerning the processing of your personal data
Request that we correct, update or delete the processing of your personal data
You have the right to obtain a copy of the personal data that we process relating to you free of charge.
You can update certain personal information about yourself through the Services.
To exercise the aforementioned rights please contact us (firstname.lastname@example.org). In order to ensure that you receive a quick response, please state your full name and user name and the email address used for registration.
Responding to legal requests and preventing harm
We may access, preserve and share your information in response to a legal request (like a search warrant, court order or a subpoena or the like), or when necessary to detect, prevent and address fraud and other illegal activity, to protect ourselves, you and other users, including as part of investigations, if we have a good faith belief that the applicable law requires us to do so.
If you have any complaints about our processing of your personal data, we encourage you to contact us directly (email@example.com) so that we may address your concerns immediately. You also have the right file a complaint with the Swedish Data Protection Authority.
Milkywire AB Karlbergsvägen 7, 113 27 Stockholm support
Last updated: 25 November 2019