Privacy Policy

Ebuno AB, a Swedish company with company organization number 559183-6027 (“Ebuno”,”NorgePanelen ”, “we”, “our” or “us ”), is responsible for the processing of your personal data as described below. This privacy policy concern you who register an account and become an NorgePanelen user.

NorgePanelen, a platform built by Ebuno, is a company based in Sweden with organization number 559183-6027

We care about and value your privacy. Through this privacy policy we therefore wish to provide you with information on how we process your personal data as well as what rights you have in relation to our processing of your personal data.

We process your personal data for the following general purposes:

To create and administer your account at NorgePanelen;
To create and administer your profile at NorgePanelen;
To match your profile with surveys that are relevant for you;
To provide surveys
To administer your withdrawal of points for gift cards or digital payment processors;
To provide customer service and improve our website by analyzing feedback;
To administer your interactions with us on our social media account; and
to comply with our legal obligations and handle possible legal claims.

Below you can read more about how we process your personal data. Should you have any questions regarding our processing of your personal data, or if you wish to exercise any of your rights under data protection legislation, please contact us via our email address hej@norgepanelen.com. Our postal address is Ebuno AB Stora Tomegatan 21, 223 51, Lund.

Below you can find more detailed information about the following topics:

From where do we collect your personal data and are you required to provide personal data to us? 2

Who can gain access to your personal data and why? 2

Where are your personal data processed? 2

What rights do you have in relation to our processing of your personal data? 3

Detailed description on how we process your personal data 4

If you register an account and become an NorgePanelen user 4

If you participate in the surveys and/or games we provide 5

If you interact with us on social media 7

Other processing activities 8

Balancing of interests assessments 9

From where do we collect your personal data and are you required to provide personal data to us?

We collect your personal data directly from you, for example when you register an account and answer our profiling questions.

In some of our profiling questions you can choose to share sensitive personal data (e.g. data about your health) with us. Answering these questions is optional and we will process the data you share with us only if you give your explicit consent .

Generally, you are free to choose if you want to provide your personal data to us. It is however in some instances necessary for you to provide personal data to us, e.g. to register an account. What exact personal data we require from you can be found in the tables below in relation to the legal bases “fulfilment of contract” and “legal obligation”. The data we require from you is never sensitive data.

If you don’t provide us with certain requested personal data, you will not be able to participate in the surveys or games we provide or create and use an account. Furthermore, we will not be able to comply with bookkeeping and accounting law and handle possible legal claims.

Who can gain access to your personal data and why?

Your personal data is primarily processed by Ebuno AB under the name Panel Evolution . However, in certain instances, we share your personal data with third parties in accordance with below.

If you want to know more about who we share your personal data with, please feel free to contact us. Our contact details can be found in the beginning of this privacy policy.

No matter the purpose for our processing of your personal data, we will share your personal data with our IT-suppliers who will process these on our behalf and on our instructions in order to ensure good and secure IT-operations. We only share your personal data with our IT-suppliers if it is necessary in order for them to fulfil their obligations towards us according to the contract that we have with them.

If you participate in surveys

In order to provide you with surveys that is relevant for you, we share your personal data with our partners who provide the surveys. Our partners act as intermediating parties between us and the companies looking for participants in surveys by matching your profile to the needs of the survey companies.
In order to administer your withdrawal of points in PayPal money, we will share information about your payment with PayPal. PayPal will process your data as a controller, meaning they are responsible for their own processing activities.

Where are your personal data processed?

We, as well as our processors, mainly process your personal data within EU/EEA. When we process your personal data outside of the EU/EEA we do so because our partner, which help us match your profile to surveys you find interesting and relevant, will store your personal data outside of the EU/EEA.

When we transfer your personal data outside of the EU/EEA, we do so based on either a decision from the Commission, standard contractual clauses or Privacy Shield.

If you want to know more about who we share your personal data with, please feel free to contact us. Our contact details can be found in the beginning of this privacy policy.

What rights do you have in relation to our processing of your personal data?

According to applicable data protection legislation, depending on the circumstances, you are entitled to a number of different rights which are set out below.

If you have any questions regarding these rights or if you want to use any of your rights, you are welcome to contact us. Our contact details can be found in the beginning of this privacy policy.

Right to information and access

You have the right to obtain a confirmation on whether we process your personal data. If we process your personal data, you also have a right to receive information about how we process the personal data and to receive a copy of your personal data.

Right to rectification

You have a right to have inaccurate personal data corrected and to have incomplete personal data completed .

Right to erasure (“right to be forgotten”) and restriction of processing

You have the right to have your personal data erased in certain instances. This is the case e.g. when the personal data is no longer necessary for the purposes for which it was collected or otherwise processed and where we process your personal data on the basis of our legitimate interest and we find, following your objection (see below under Right to object), that we do not have an overriding interest in continuing to process it.

You also have a right to request that we restrict our processing of your personal data. For example, when you question the accuracy of the personal data, when you have objected to our processing of your personal data based upon our legitimate interest, or where the processing is unlawful, and you oppose to the erasure of your personal data and instead want us to restrict our processing.

Right to data portability

In certain instances, you have a right to be provided with such personal data (concerning you) that you have provided to us, in a structured, commonly used and machine-readable format. You also have a right to in certain instances have such personal data transferred to another controller, where technically feasible.

Right to object

You have the right to object to our processing of your personal data if we use it for marketing purposes.

You also have a right to object to our processing of your personal data when the processing is based on the legal basis “legitimate interest” . The situations when we base our processing on our legitimate interest are stated in the below charts and you can read more about our balancing of interest assessments in the end of this privacy policy. In some instances, we may continue to process your personal data even if you have objected to our processing. This can be the case if we can show compelling legitimate reasons for the processing that outweigh your interests or if it is for the purpose of establishing, exercising or defending against legal claims.

Right to withdraw consent

You have the right to withdraw a given consent at any time. The withdrawal will not affect the lawfulness of processing based on your consent before the withdrawal.

Right to lodge a complaint to a supervisory authority

You have the right to lodge a complaint to a supervisory authority concerning our processing of your personal data.

Such a complaint can be filed with the authority in the EU/EEA member state where you live, work or where the alleged infringement of applicable data protection legislation has occurred. In Sweden, the supervisory authority is The Swedish Data Protection Authority .

Detailed description on how we process your personal data

The below chart describes in detail why we process your personal data, which personal data we process, the lawful basis for the processing and for how long we process your personal data.

If you register an account and become an NorgePanelen user

To administer your account
What processing we perform	What personal data we process	Our lawful basis for the processing
To create and enable you to securely use your account, including to communicate with you regarding your account To give you the benefits of having an account, including e.g. enable you to manage your settings and gain access to your survey history To keep track of the points you receive from various completed surveys To calculate your ranking compared to other NorgePanelen users based on your points	Information you provide to us, e.g.: Name Contact information (email) Postal code and city Gender Date of birth The number of surveys you have completed and points you have collected Other information you choose to provide to us, such as street address and phone number	Performance of contract The processing is necessary for us to fulfil the contract concerning your registration at NorgePanelen. Legitimate interest It is not necessary for you to provide us information about your street address and phone number to fulfil any contract. This information is instead processed on the basis of our legitimate interest to process your personal data in order to administer your account.
To keep track of when you have referred a friend to NorgePanelen and how many points they have collected in order to reward you with extra points	The points you collect Name of the friend you have referred The number of points your friend has claimed	Legitimate interest Our legitimate interest to process your personal data to reward you with the extra points for recruiting one of your friends to NorgePanelen. If you are the referred friend and register an account, we will process your personal data based on the performance of contract , please see above.
Storage period: We will store your personal data until you choose to delete your account at NorgePanelen.

To administer your profile
What processing we perform	What personal data we process	Our lawful basis for the processing
To ask you questions in order to create a profile for you that can be matched to relevant surveys To give you surveys that are matched to your interests and persona Note that it is optional to answer these questions and that you choose what information you want to share with us.	Information you provide to us, e.g.: Information about your household, education and occupation, car, food and beverages, hobbies and interests, electronics, computer and video gaming, media, travel and what research surveys you are willing to participate in Information about your ethnicity, smoking and tobacco habits, healthcare and eventual children	Legitimate interest Our legitimate interest to process your personal data that you choose to give us to be able to create and administer your profile. Explicit consent Sensitive information will be processed based on your explicit consent. You can withdraw such consent at any time. You can also change some of the answers you have given to “I prefer not to declare this”.
Storage period: We will store your personal data until you choose to delete your account or until you change your answers to “I prefer not to declare this”. We will stop storing your sensitive personal data immediately if you withdraw your consent.

If you participate in the surveys and/or games we provide

To enable your profile to be matched with relevant surveys
What processing we perform	What personal data we process	Our lawful basis for the processing
To enable your profile to be matched with surveys you find relevant and interesting we share information with our partners Our partner matches your profile to companies that have surveys both within the EU and outside of EU	Information you provide to us, e.g.: Name Contact information (email) Postal code and city Gender Date of birth The number of surveys you have completed and points you have collected Other information you choose to provide to us, such as street address and phone number Other information from the profiling questions you have chosen to answer Other information that might have technical administration purposes such as IP address or country location	Legitimate interest Our legitimate interest to process your personal data to enable your profile to be match with surveys you find relevant and interesting. Explicit consent Sensitive information will be processed based on your explicit consent. You can withdraw such consent at any time. You can also change some of the answers you have given to “I prefer not to declare this”.
Storage period: We will process your personal data until the matching is done. We will stop storing your sensitive personal data immediately when you withdraw your consent or change your answers to “I prefer not to declare this”.

To provide surveys
What processing we perform	What personal data we process	Our lawful basis for the processing
To provide you with surveys that you can participate in To award you points for each survey you partake in Note that we provide the opportunity for you to participate in surveys, but the actual surveys are managed by third parties. If you choose to state your name or any other information about yourself in a survey, the survey company might be able to tie your answers to you as a person. In such cases, the survey company will become a controller. If you want to know more about how they process your data you can contact the relevant company.	Information you provide to us, e.g.: Name Contact information (email) Postal code and city Gender Date of birth Other information you choose to provide to us, such as street address and phone number The number of surveys you have completed and points you have collected Information you have provided to us through your profile	Legitimate interest Our legitimate interest to process your personal data to provide you with surveys that you can participate in.
Storage period: We will process your personal data until the survey is finalized.

To provide games
What processing we perform	What personal data we process	Our lawful basis for the processing
To provide you with games that you can play To calculate your points after each game you win or lose To calculate your ranking compared to other players	Information you provide to us, e.g.: Name The number of points you have collected The number of points you win or lose when playing the games	Legitimate interest Our legitimate interest to process your personal data to allow you to play games that we provide, get the chance to win extra points and see how you rank in comparison to other users.
Storage period: We will store your personal data until you choose to delete your account.

To administer withdrawal of your points in exchange for gift cards
What processing we perform	What personal data we process	Our lawful basis for the processing
To turn the points you have received into gift cards To send you the gift card	Information you provide to us, e.g.: Name Contact information (email) The number of surveys you have completed and points you have collected Information about what gift card you choose	Performance of contract The processing is necessary for us to fulfil the contract concerning your membership in NorgePanelen which means you receive points that can be withdrawn as gift cards in exchange for participating in surveys.
Storage period: We will process your personal data until the withdrawal is finalized.

To administer withdrawal of your points in exchange for online payment processors
What processing we perform	What personal data we process	Our lawful basis for the processing
To turn the points you have received into digital currency To send you the payment reward Note that in order to turn your points into PayPal money we share your personal data with PayPal. If you want more information on how PayPal processes your data you can contact PayPal.	Information you provide to us, e.g.: Name Contact information (email) The number of surveys you have completed and points you have collected Information about what gift card you choose	Performance of contract The processing is necessary for us to fulfil the contract concerning your membership in NorgePanelen which means you receive points that can be withdrawn as PayPal money in exchange for participating in surveys.
Storage period: We will store your personal data until the withdrawal is finalized.

If you interact with us on social media

To communicate with you on social media
What processing we perform	What personal data we process	Our lawful basis for the processing
To communicate with you on our social media account (Facebook), e.g. if you communicates with us on our page	Information from your profile on the social media in question (user name and any picture you have chosen for your account) Information which you provide on our page	Legitimate interest Our legitimate interest to process your personal data to communicate with you on our social media platform.
Storage period: Your personal data will be removed if you ask us to remove it or if you yourself delete the content, but we will otherwise store the personal data on the social media platform until further notice.

Other processing activities

To provide customer service
What processing we perform	What personal data we process	Our lawful basis for the processing
Answer and administer customer service matters	Name Contact information you provide in our contact Other information you provide regarding the matter, e.g. a problem with a function	Legitimate interest Our legitimate interest to process your personal data to answer and administer customer service matters.
Storage period: We will store your personal data until the account is removed.

To improve our services
What processing we perform	What personal data we process	Our lawful basis for the processing
To improve our services and website’s functions based on your feedback	Information you provide to us, e.g.: Name Contact details (e-mail) Other information you provide to us when sending us feedback	Legitimate interest Our legitimate interest to process your personal data to handle your feedback and improve our services.
Storage period: We will store your personal data until account is removed

To handle any claims and rights
What processing we perform	What personal data we process	Our lawful basis for the processing
Handle any consumer rights such as your right to make complaints Defend ourselves against claims and complaints Initiate any claims	Name Contact details you have chosen to use, e.g. email address and/or phone number Information from our communication with you in relation to the claim, e.g. information about the relevant booking or information about your stay	Legal obligation The processing is necessary to comply with legal obligations to which we are subject, i.e. comply with a legal obligation that we are subject to. Legitimate interest Our legitimate interest to process your personal data to defend ourselves against a possible legal claim and to initiate any claim.
Storage period: We will store your personal data until we have processed the complaint, until we have handled the right or for the duration of the dispute.

To comply with bookkeeping and accounting legislation
What processing we perform	What personal data we process	Our lawful basis for the processing
Store information in bookkeeping and accounting	Name History regarding withdrawals and payments made Other information that constitutes accounting records	Legal obligation The processing is necessary to comply with legal obligations to which we are subject, i.e. bookkeeping and accounting legislation.
Storage period: We will store your personal data until and including the seventh year after the end of the calendar year for the fiscal year to which the personal data relates.

Balancing of interests assessments

As we state above, for some purposes, we process your personal data based upon our “legitimate interest”. By carrying out a balancing of interests assessment concerning our processing of your personal data, we have concluded that our legitimate interest for the processing outweighs your interests or rights which require the protection of your personal data.

If you want more information in relation to our balancing of interests assessments, please do not hesitate to contact us. Our contact details can be found in the beginning of this privacy policy.

This privacy policy was established by Ebuno AB on 2021-08-18.