Privacy policy

Effective: June 7th, 2020.

General Statement of Privacy

At Schmugan AB ("us", "we", or "our"), we are committed to protecting your privacy.

Our apps (“Apps”) are intended and designed for the whole family, including for use by young children, whereas our website located at www.schmugan.com ("Site"), is intended for adult use only.

In this Privacy Policy, “Personal Information” means information or an information set that identifies or could be used to identify an individual directly or indirectly. Except as described in this Policy, we will not give, sell, rent, or loan any Personal Information to any third party. The term “Non-Personally Identifiable Information” refers to information that does not directly identify a user.

Inspired by the GDPR we keep stored data at a bare minimum and if you don’t agree with our Privacy Policy or our Terms of Service, you should not use our Apps and Site.

About our Apps

Our Apps are designed and are safe for children, with particular attention to online privacy. We don’t analyse usage of our Apps, they are COPPA and GDPR compliant. 

In short our Apps:

• Do not collect any personal information

• Do not collect location data.

• Do not display third party advertisements.

• Do not use in-app purchases

• Do not use push notifications.

• Is not connected to social media

Collection and Use of Personal Information via our apps: 

We do not collect any personal information through our apps. 

Collection and Use of Non-Personal Information via our apps: 

We do not collect non-personal information, and we do not use tools or third-party analytical software to gather or analyze non-personal information.

Parental Gate

Our apps provide parents with access to the privacy policy and support email. This information is behind a parental gate. 

Third-party advertising

Our apps do not use and/or display third-party advertising. Our apps may contain information or links to other apps by us and in this case links are also child-locked and accessible only by adults.

Push notifications and Location Data

Our apps do not use push notifications and they do not collect location data.

About our Site

Children's Privacy

The Site is not intended for individuals under the age of 18 ("Children").

We do not knowingly collect any personal information from children under the age of 18 via our website. If you believe we have mistakenly collected such information, please contact us at privacy@schmugan.com so we can resolve the issue. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

What We Collect and Receive


In order for us to provide you the best possible experience on our websites, we need to collect and process certain information. Depending on your use of the Services, that may include:

• Contact us via email — when you ask for support, send us questions or comments, or report a problem, we will collect your email address, message, etc. We use this data solely in connection with answering the queries we receive.
• Sign up for a newsletter — when you sign up for a newsletter, we ask you to provide us with information such as email address. The subscribed e-mail address is used specifically to inform you of app updates, new app releases, new products and sales via a low volume newsletter. You have the ability to unsubscribe at any time simply by clicking on the ‘unsubscribe’ button provided on the sent newsletter email.
• Usage data — when you visit our Site, we will store: the website from which you visited us from, the parts of our Site you visit, the date and duration of your visit, your anonymised IP address, information from the device (device type, operating system, screen resolution, language, country you are located in, and web browser type) you used during your visit, and more. We process this usage data in Google Analytics for statistical purposes, to improve our Site and to recognize and stop any misuse. You can prevent cookies from being installed by disabling the corresponding setting in your browser software; however, we advise that in this case the full functionally of our website may not be able to be used. You can also prevent the collection of the data generated by the cookie about your use of our website (including your IP address) and the processing of this data by Google by downloading and installing a browser add-on (https://tools.google.com/dlpage/gaoptout?hl=en).
• Cookies — we use cookies (small data files transferred onto computers or devices by sites) for record-keeping purposes and to enhance functionality on our Site. You may deactivate or restrict the transmission of cookies by changing the settings of your web browser. Cookies that are already stored may be deleted at any time.

We use the following cookies:

• Strictly necessary cookies
• Analytical/performance cookies
• Functionality cookies
• Third-party cookies

Do Not Track

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

Your Rights

In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws. 

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
 

Will Your Information Be Shared with Anyone?

We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.

We may process or share data based on the following legal basis:

• Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.

• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract. 

• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). 


• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

Third party services we use


When you visit our websites we use the following third party services which may collect personal data:

• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Site, which will enable them to collect data about how you interact with the Site over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.  

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. 

• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

• Business Partners. We may share your information with our business partners to offer you certain products, services or promotions. 

• Other Users. When you share personal information or otherwise interact with public areas outside of the Site, such personal information may be viewed by all users and may be publicly distributed outside the Site in perpetuity. If you interact with other users of our and register through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you outside of our Site , and view your profile.   

Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Data Retention

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.  

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 90 days.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

You may write to us at any time if you wish to have us remove your Personal Information from our database. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

California Residents Specific Privacy Rights

If you are a resident of California, you are granted specific rights regarding access to your personal information.  

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. 

Governing Law


This Privacy Policy, the privacy practices of Schmugan AB, and any dispute arising out of or relating thereto will be governed by the laws of Sweden, without regard to its conflict of law provisions. You agree to submit to the exclusive jurisdiction of the general courts of Sweden to resolve any legal matter arising from this Privacy Policy and the privacy practices of Schmugan. Notwithstanding the foregoing, you agree that the Schmugan AB shall be allowed to apply for injunctive relief (or an equivalent type of urgent legal relief) in any jurisdiction. Schmugan AB makes no representation that this Privacy Policy and such practices comply with the laws of any other country. Visitors who use the Site and reside outside of Sweden do so on their own initiative and are responsible for compliance with local laws if, and to the extent, local laws are applicable.

Privacy Policy Changes

We may amend this policy from time to time to reflect changes in our products, the services we offer, or changes in the law. Any changes are effective upon posting unless another date is specified. This policy is part of our Terms of Service that explain the rules, rights and responsibilities for using our Site and its associated apps, products and services.