Remainly - Online Couples Therapy

Privacy Policy

Parweb Scandinavia AB is committed to protecting and respecting your private information and use both technical and organisational security measures to protect your integrity when you use our service Remainly (the “Service”), in accordance with the General Data Protection Regulation (“GDPR”). This privacy policy explains how your personal data is processed when you use the Service, your rights and how to enforce them.

‍

The data controller responsible for the processing specified in this privacy policy is Parweb Scandinavia AB, Sweden, company registration number 559211-3491 ("Parweb", "we", or "us").

Information that we collect

When registering your user profile on Remainly, you must provide some information about yourself and you will throughout the use of the Service be able to provide us with voluntary information. We collect the following information:

  • ‍User data, email-address, password, username, age (year) and gender. We want to make the user aware that we do not register your family name, date of birth, personal adress, social security numbers or national insurance numbers regarding our users, nor do we want our users to give us this information.
  • Communications data, meaning all information included in your correspondence with us. Communication data may include user data and other relevant information you share with us about yourself. For example, we collect relevant information about your customer support interactions with us, such as the date, time, method of contact and subject of the conversation. Please note that we receive any information you send to us. Because email communications are not always secure, we encourage you to not include sensitive data in your emails to us and avoid sharing sensitive data with us.
  • Personality data, meaning information regarding your qualities  and personal traits that you submit during personality tests and the  result from those tests.
  • Reports, on the differences and similarities in qualities and personal traits between you and your partner.
  • ‍Personal information in free-text fields, meaning any additional and voluntary information you choose to submit in the Service, for example in your couple’s log. Please note that any personal information you submit on a voluntary basis may reveal information that is considered by law to be sensitive: ethnic background, sexuality, nationality, health, union membership, religious, political or philosophical beliefs, and criminal offenses. If you choose to enter such information, we hope you understand that this is voluntary and that we process such information based on your consent.
  • Technical data. We will collect technical data from devices trough which you access the Service, such as IP address, browser type and version, screen resolution, preferred language, operating system and computer platform. Technical data may also include information about how you use the Service, and if you encounter any technical errors. Even though we do not normally use technical data to identify individuals, sometimes individuals can be recognized from it.  
  • ‍User survey data, if any personal information is given to us when voluntarily responding to user surveys. We may contact you to participate in user satisfaction surveys. If you decide to participate, we will process any personal information you choose to include in your answers to such survey.

How we collect your information

Information that you give to us. Most of the information we process about you is received from you. You may directly or indirectly give us information about yourself in different ways, for example when you order a service or product from us, subscribe to our publications and/or newsletters, use the Service or otherwise in your communication with us. You can always choose not to provide us with certain information. However, some personal data is necessary in order for us to provide you with the Service. Not providing such personal data may prevent us from providing you with the Service or other services you expect from us.

‍

Information that we collect about you. We will furthermore automatically receive information and statistics about your use of the Service (technical data), however as described above this information will as a main rule not be your personal data as we will only process the information on an aggregate and anonymous level.

Cookies and pixels

Remainly uses technology (such as cookies) that enables storage and access to information on your computer and other devices (such as mobiles and tablets). Such technology is used in part because it is necessary for the Service to work and easier for you to use the Service, but we also use these technologies for analysing how we can improve the Service and for marketing. For more information regarding cookies and pixels, see our cookie policy.

What we use your personal information for

We use your personal information to provide the Service and the features you have requested. We let you and your partner communicate with each other and follow a common progression in the paths. If you have selected a product with a test, we show you your individual test report and when your partner also takes the test, you both get a matching report that says something about the properties you are matched on. These tests are made according to good psychology practice (search for "psychometry" if you want to know more). The point of offering individual or matching reports is to provide better communication opportunities about individual differences. We use your email to notify you when your partner has come as far as you so you can continue. Otherwise, we will use your email to a very limited extent to notify you of new offers or services from Remainly. Only your username will be. It makes sense to use your first name as a username, but there is nothing in the way of registering as something random like Donald or Dolly Duck. Remainly has no interest in linking identifiable information with test results or other information that couples enter, for example, in the couple’s log. However, we have listed the information as personal data we process as we have no control over whether you use your own or a made-up name as a username.

‍

We use the information for the following purposes:

  • To register your account. We will process your personal data to register your account. This is necessary to enter into a contractual relationship with you regarding the Service, our Terms of Use, and to pursue our legitimate interests, such as our interest in simplifying the registration process for our users and administering the contractual relationship.
  • To assess your qualities and personality  through the Big Five methodology and match it with those of your partner. As part of the Service we provide to you, you will answer questions in personality tests.

The methodology used is called The Big Five personality traits, also knownas the five-factor model (FFM). How this works is that the Serviceapplies factor analysis (astatistical technique) to personality survey data (your answers). The base for the methodology is that some words used to describeaspects of personality are often applied to the same person and for example,someone described as conscientious is morelikely to be described as "always prepared" rather than"messy". This theory is therefore based on the association between words and not on neuropsychological experiments.

‍

We will then match your and your partner’s different qualities and personalities in order to provide you with relevant educational material regarding how to approach your differences and similarities. This means that profiling is a part of the Service, i.e. for the purpose of providing you with insights about you and your partner. This profiling is necessary for the performance of our contract with you (the Terms of Use), were we have committed to provide you with the Service, including relevant educational material based on results from personality tests taken by you and your partner.

‍

‍Please note, that we only process your personal data in relation to the purposes stated herein and therefore will not use it in any manner incompatible with these purposes.

  • To provide you with reports of your and  your partner’s different qualities and personalities, together with relevant educational material. As part of the Service and based on results from personality tests taken by you and your partner, we provide you with reports of your and your partner’s qualities and how your different qualities may affect your relationship together with tips and relevant educational material. This is part of the Service and the processing necessary for the performance of our contract  with you, i.e. the Terms of Use.
  • To provide you with a feature to write, and if you choose – to share your thoughts with your partner through the Service. As part of the Service, we provide you with the possibility to write a log about your feelings and thoughts, and sometimes we also recommend that you write as part of the tasks. Furthermore, this feature enables you to talk to your partner digitally, through our Service. This information is encrypted, and we will never decrypt it unless you give us the permission to. As this is one of the core features of our Service, we base this processing on performance of our contract with you, as the feature is part of the Service we have promised to provide to you in accordance with our Terms of Use.
  • To communicate with you. Your contact information will be used to send you reminders, confirmations, application messages and other relevant information about the Service. This processing may be necessary for performance of our contract with you and to provide you with the Service (e.g. send important administrative messages required) or otherwise necessary for our legitimate interests in enhancing and maximizing your use of the Service and to communicate effectively with you.
  • To provide support. Your personal data (e.g. contact information, technical data) may be used to investigate, respond to and resolve complaints and problems with the Service (e.g. bugs). This processing is necessary to provide you with the Service and upholding our obligations towards you as set out in the Terms of Use and for our legitimate interest in the functionality of the Service.
  • To conduct user surveys. Your contact information may be used to contact you regarding user surveys. By continuously collecting qualitative feedback from you and other Users, we can gain a deeper understanding of our users’ problems and needs.

We will contact you based on our legitimate interest in gathering feedback for developing and improving the Service. Participation in user surveys is however optional any potential personal data provided to us in connection with the answers to the survey will be processed based on your consent.

  • To create  aggregated data for developing the Service and its features, including the tests, matching procedure and educational  material.

We use technical data, and other aggregated and non-personal information to develop and improve the Service, including troubleshooting, data analysis, research, statistical purposes and testing (such as beta testing and evaluation of new features). For example, we may collect and evaluate technical data about your use of the Service for analytical purposes, to understand how people use the Service in order to make it more intuitive. The technical data is collected in connection with your use of the Service or your interactions with us.

‍

Regarding answers to personality tests, we process test results linked to age and gender inorder to have the possibility to improve our tests and the advice andeducational material we provide. For example, Woman (34) with PersonalityProfile A has as a partner Man (34) with Personality Profile B. This type of data will only be used at group level and it will not be possible to track individual users based on such data.

The processing of converting user activity data, technical data, test- and matching results to aggregated data is based on our legitimate interest in being able to gather statistics that can help us improve the Service and its features or – if it is necessary to enable you to use the Service as intended – based on performance of our contract with you, i.e. the Terms of Use.

  • To market us and our services and products. Your contact information will be used to send newsletters or other information regarding the Service or other services and products that we offer. This processing is based on our legitimate interest of being able to market us and our services to our existing users. You are always free to follow the unsubscribe instructions contained in the material received from us.
  • To fulfil our legal obligations. We are obligated to follow Swedish law. This means that your personal data will be processed to the extent necessary for us to fulfil our legal obligations, for example the Swedish Accounting Act.
  • To protect our legitimate business interests and legal rights. We will use information about you where we believe it is necessary for our legitimate interest in being able to protect and enforce our legal rights, interests and the interests of others, for example in connection with legal claims, compliance, regulatory and audit functions. Examples of personal data processed for this purpose is storage of communication with us, as well as invoices and agreements.
  • In connection with a merger or acquisition. In connection with, due to strategical or business-oriented reasons, a potential merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company, the personal data we retain about you may be processed, shared or transferred, to parties involved in the process. This processing is based on our legitimate interest of being able to develop our business.
  • Concerning special categories of data. We will not ask you to provide us with any special categories of data, as defined in the GDPR. This means data concerning your e.g. religious or philosophical beliefs, political opinions, health, sex life or sexual orientation.  However, if you choose to include such data in the free text fields in the Service, e.g. in the couple’s log, or in your communication with us, we will only process such information to the extent necessary and justified, based on your consent.
  • With your consent. Your personal data may be used for other purposes than stated above if you ask us to or you give us your consent.

Sharing of your personal information with others

We do not sell, rent or otherwise disclose personal data relating to our registered users, to third parties, unless otherwise stated below.

‍

We may share personal information you register in the Service with the following types of third parties:

  • Service providers, such as data storage providers, that enable us to offer you the Service.
  • The mail communication feature in the Service is provided by a third party, Mailchimp. To read more about how Mailchimp processes personal data, click here.
  • We use Firebase, a cloud computing service created by Google and Microsoft Azure, a cloud computing service created by Microsoft for building, testing, deploying, and managing applications and services through Google and Microsoft managed data centres.
  • Public authorities such as law and order authorities, if we are legally obliged to do so or if we must protect our rights or the rights of third parties;

    - To our subsidiaries and affiliates, if any; or
    ‍
    - A new owner, co-owner or operator of the Service and its advisors in connection with the merger, restructuring, or sale of substantially all of our shares and / or assets or other corporate restructuring, pursuant to this Privacy Policy.

We may also share information with third parties in an aggregate format that is not considered personal information, and which does not allow the identification of any individuals.

Transfer of personal information abroad

Your personal information may in certain situations be transferred to, and stored at, a destination outside of the EU/EEA territory. Please note that privacy laws in countries outside of the EU/EEA may not be the same as, and in some cases may be less protective than, privacy laws in your country. However, we always select our service providers carefully and take all the necessary steps to ensure that your personal data is processed with adequate safeguards in place in accordance with the GDPR. These safeguards are either that we sign the EU Commission Standard Contractual Clauses or ensure that the service provider is located in a country which the EU Commission has deemed as having adequate privacy protection including, if the company is located in the United States, abides by the Privacy Shield.

You can always contact us for information about the applicable safeguards.

How long we store your personal information

The personal information will not be stored any longer than necessary to achieve the purpose for which it was collected.


Upon termination of your account (for any reason), Remainly will delete your personal data immediately and all backups within 6 months. And if you have not been active in your account for three (3) years, we will delete your accent and connected personal data.

Personal data processed on the basis of your consent will be deleted when your consent is withdrawn or upon expiry of the purpose for which your consent was given.

And longer if necessary, by law or for our legitimate interests. Even if you delete your account or withdraw your consent, we keep your data if and to the extent we believe it is necessary to protect our legal rights, legitimate interests and the interests of others.

Your personal information may also be stored for a longer period if required by applicable statutory retention periods, such as applicable periods for customer claims from consumers and accounting legislation.

Your rights and how to exercise them

You have the following rights regarding the personal data we hold about you:

  • The right to know what information we have about you. If you want to know what personal information we process about you, you can log in to the Service and go through your account settings. There we show you the information you have provided to us. The information that is automatically collected will normally only be available at the group level. You have the right to receive a transcript of all personal data we process about you and the first transcript is free of charge. Upon repeated and unreasonable requests for transcripts we may however charge an administrative fee.
  • The right to correct inaccurate information. The easiest way to correct, delete or update the personal information you provided for the Service is to log in to the Service and make any necessary changes to your own account on Remainly.
  • The right to have your information deleted ("the right to be forgotten"). You can contact us on mail at contact @remainly.com to have your user account deleted. When we delete your user account from Remainly, all identifying information will be deleted. That is, it will no longer be possible to link your email address or username, i.e. you, to your test results or couple’s log.
  • The right to object. You have right to object to the processing that we carry out based on our legitimate interests. This means we may no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests. You can always contact us for more information on the balance test that has been made.

You furthermore have an unconditional right to object to your personal data being processed for direct marketing purposes. All inquiries with electronic direct marketing you receive from us, such as e-mails and instant messages, will give you the opportunity to choose not to receive such inquiries from us in the future. Please note that if you object to processing for direct marketing purposes we may have to, in our legitimate interest of being able to fulfil our legal obligation to not contact you – keep e.g. your name or email-address and the fact that you have objected to marketing.

  • The right to transfer your data to another controller ("the right to data portability"). You have the right to, regarding the personal data you have provided us with that we process either based on your consent or fulfilment of the contract with you, receive a copy of your personal data to transfer to another data controller.
  • The right to restriction. You are entitled to request that the processing of your personal data should be limited until inaccurate or incomplete information about you has been corrected, or until an objection from you have been handled.
  • The right to withdraw your consent. You may at any time withdraw any consent you have given us. However, please note that it will not affect any processing that has already taken place.  
  • Right to complain. You have the right to lodge a complaint to the supervisory authority (as defined in the GDPR) in the country you live or work in, if you believe that we have not complied with our obligations regarding your personal data. For Swedish purposes, such authority is Datainspektionen.

If you have any other questions about what kind of information we have stored about you, about the correction, deletion or updating of the personal information we hold about you or about electronic direct marketing from us, please contact us using the details in the end of this policy.

Please note that legal rights or obligations (such as confidentiality, accounting and tax legislation) may prevent us from disclosing or transfer all or part of your information, or from immediately deleting your information.

Security

We use standard industry technology to ensure that our users' information is secure with us. Your personal password is confidential and encrypted to guarantee your security. With your password you have the opportunity to change your personal information via the member pages. If you want to delete your personal information, contact us at contact@remainly.com.

Children's privacy

You must be at least eighteen (18) years of age to register and use the Service.

Changes to the Privacy Policy

Occasionally, we may make changes to our Privacy Policy. If we make a major change that requires us to collect a consent, we will do so before the change takes effect and we will inform you about significant changes e.g. by email or on our website. We also recommend that you review this privacy policy from time to time to ensure you are aware of any amendments.

Contact us

If you have any questions regarding these privacy policies, your privacy in connection with the use of the Service or the protection of the personal information we hold about you, please contact us.

‍

Parweb Scandinavia AB, Varberg, Sweden
Company registration number: 559211-3491

Email: contact@remainly.com

‍