Privacy Policy

Qwaya Privacy Policy and Cookie Information

Date of last revision: 16 May 2018

This Privacy Policy, including cookie information, has been adopted by Funnel Operations AB (“Qwaya”), and applies to our processing activities in relation to visitors of our website, users of our services (trial users and customers), and individuals communicating with us.

Qwaya is committed to protect and respect your privacy. Therefore, you are encouraged to carefully read this policy. If you have any concerns, please contact us as set out below in section 9.

1. What is personal data?

Personal data is all information that directly or indirectly (i.e. together with other information) may identify an individual. This means that a wide range of data, such as names, contact details, IP addresses, and behaviour and choices made online can be personal data.

Data processing is any operation or set of operations performed upon personal data, whether or not by automatic means, such as collection, recording, organisation, storage, adaptation or alteration, blocking, erasure or destruction of personal data.

2. How do we process your personal data?

2.1 Visitors to our website

When you are browsing our website, we process:

We process your data for the purpose of:

2.2 Users of our services (trial users and customers)

When you are using our services, through our website or our app, we process:

We process your data for the purpose of:

2.3 When you communicate with us

When you communicate with us we may process:

We process your data for the purpose of:

3. Legal ground for our processing

Qwaya processes personal data in accordance with applicable personal data protection legislation. Within the EU/EEA, the general data protection regulation (”GDPR”) will apply from 25 May 2018.

We will process your personal data when it is necessary to: (i) fulfil our agreement with you or respond to your inquiries; and (ii) comply with a legal obligation. Your data may also be processed when it is necessary for the purposes of a legitimate interest for Qwaya, inter alia, to market and improving our services. If a processing of data requires your prior consent, we will collect such consent before carrying out the processing in question.

Personal data that we request from you and indicated as mandatory is required to be provided in order for us to provide the service, e.g. for statutory, contractual, administrative or technical reasons.

4. How long do we keep your information?

We will only keep your information for as long as we need it: (i) to provide you with our services; (ii) to improve our services or to communicate with you; and (iii) for legal and audit purposes. We have routines in place to ensure that personal data are deleted thereafter.

5. How do we share your information?

We may share your information with other companies within the Funnel Group.

We may also engage third parties for the provision of services to Qwaya, such as provision of IT-systems, services and other activities. Your data may be shared with and processed by such service providers on behalf of Qwaya as required for the provision of the services to Qwaya. Within the use and provision of such services, your personal data may be transferred to countries outside the EU/EEA (third countries). In relation to such third country transfers, certain security measures will be taken in order to protect your data and ensure that the data keeps an adequate level of protection, e.g. by entering into a data transfer agreement including model clauses issued by the EU Commission and available on the EU Commission’s website.

Personal data may be disclosed to a third party if we are required to do so according to applicable laws and regulations or in order to detect and prevent fraud or security or technical problems.

Companies which are processing personal data on behalf of us are obliged to sign an agreement with us in order to ensure a high level of protection for your personal data.

6. Information security

We strive to provide a high level of protection in all our personal data processing. We have therefore taken organisational and technical security measures in order to protect your personal data from unauthorised access, use, alteration and erasure.

Your password protects your Qwaya account, so you should use a unique and strong password, limit access to your computer and browser, and log out after having signed in to your Qwaya account.

7. Our use of cookies

7.1 The use of cookies

This section describes our use of cookies. For further information about how the information may be used and shared by Qwaya, please see above.

7.2 What are cookies and how do we use them?

A cookie is a small text file that is placed on your computer, mobile phone, or other device when you visit a website. A cookie enables recognition of your computer and the collection of information on what websites and functions you have visited. It also helps maintain your settings when you are navigating a website or return to the same website at a later point.

We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device for a set period of time or until you delete them). We use the following types of cookies for the purposes explained in this list:

7.3 Consent to the use of cookies

When you visit a website, you have the right to receive certain information such as how cookies are used.

Furthermore, you need to consent to our use of cookies. If you do not consent to the use of cookies, it may affect your user experience and you may not get full access to all features and functions on our website.

In case you have given your consent to the use of cookies, you can easily withdraw your consent and choose to block and/or delete the cookies. For more information on how to block/erase cookies, please see section Manage your cookies and other preferences.

7.4 Processing of personal data

Some of our cookies collect personal data. In case you have signed up for a trial, we will be able to use the information for the purpose of creating a more personalized online experience for you, e.g. to provide marketing material that is relevant for you.

In case you are only browsing our website, the data collected by the cookies will only be used for statistical purposes and to improve our website and we will not be able to identify you through that data.

For more information about how we use your personal data, please see section 2 above.

7.5 Cookies placed by third parties

The website may contain content and sharing tools embedded from various social networks, such as Facebook. These suppliers may use and place cookies on our website. We do not have access to, and cannot control, these cookies or the personal data and information that they may collect.

You therefore need to check the websites of these suppliers to get further information on how they manage cookies and what information their cookies collect.

7.6 Manage your cookies and other preferences

Most web browsers allow you to manage your preferences. You can set your browser to refuse cookies or delete certain cookies. You can find out more about how to manage cookies on or click help in your browser menu. If you have any questions or comments about our use of cookies, please contact us at the address specified in section 9.

Please note that if you block our use of cookies, you may be unable to access certain areas of our website and certain functions and pages will not work in the usual way.

8. Your rights under applicable data protection legislation

According to applicable data protection legislation, you are entitled to certain rights. If you want to exercise any of these rights, please contact us at the address specified in section 9 below. Your rights are:

You are also entitled, at any time, to submit complaints to the relevant supervisory authority if you think that your personal data is being processed in violation of the applicable data protection legislation.

9. Contact information

Funnel Operations AB is the data controller for the processing of personal data described in this policy. If you have any questions regarding the processing or want to exercise any of your rights, you may reach out to us via the following contact details.

Funnel Operations AB
Adress: Drottninggatan 89, 11360, Stockholm, Sweden

10. Updates to the policy

We may update the policy from time to time, e.g. by making new versions available on our website or by providing the update by other appropriate means. You are recommended to visit our website from time to time to learn of any updates.