Privacy Policy

This policy explains how we use any of your personal information we might collect.

1               BACKGROUND

1.1             Indextra AB, corporate id. no. 556619-6340 (“Indextra”) respects and protects your right to protection for your personal data. We want you to feel safe when we process your personal data. With this privacy notice (“Privacy Notice”) we want to inform you of how we ensure that your personal data is processed in accordance with applicable law.

1.2             In order to provide our service, we must use your personal data. This Privacy Notice applies to you as customer or retailer, as a contact person to the before mentioned, as someone who wishes to receive newsletters or information from us and as a visitor to our website.

2             DATA CONTROLLER

2.1           Indextra is the Data Controller for the processing of your personal data and therefore responsible for the use of your personal data. As Data Controller we are also obligated to ensure that the use of your personal data is in accordance with applicable legislation. We have moreover appointed a DPO. You can contact him at dpo@indextra.com. You can find our full contact information at the end of this Privacy Notice.

3             OUR USE OF YOUR PERSONAL DATA

3.1          We use your personal data in order to best provide you with our service. Your personal data is being used for the following purposes:

–     Administration and performance of agreements, and for the purpose of safeguarding our legal interests,

–     To prevent and detect fraud,

–     Marketing, including marketing e-mails,

–     Method and business development, and

–     Administration in connection with acquisitions, restructuring etc.

The schedules below provide you with more information about why we use your personal data, what personal data we use to achieve our purposes for processing and how long your personal data will be stored.


Purpose: Administration and performance of agreements, to provide you the service and for the purpose of safeguarding our interests with regard to legal claims

Personal Data:
Contact information such as name, address, telephone number and e-mail address.
Order- and payment details such as order history and payment information, for example your
credit or debit card information (such as card type and expiration date) and other financial
information that we need to process your payment. In addition, the payment processors generally
provide us with some information related to you.
Login information such as e-mail address, user name and password.

Device information such as Device ID.

Information on your use of the service such as monitoring and tracking of your use of the service,
which titles you have downloaded and/or opened and what pages you are reading.

Other information you may choose to submit to us, such as notes and other content you post in
the service, or allow us to gather from your mobile device, such as full name, profession,
specialty, institute, practice and/or hospital, and location.

What we do:

We use your data to provide, manage and customize our service, enable login to our web services and provide customer service to you as a user, for example providing customised, personalised, or localised content, recommendations and features on or outside of the service. For information that you may allow us to gather from your mobile device under section 4.2 we may process the information in question for the same purposes.

Your use of the service, such as downloaded book titles, is monitored in order for Indextra to be able to administrate and provide the publishing houses Indextra co-operates with a basis for the payment of book royalties. No personal data will be transferred to the publishing houses as the basis for the royalty payments will be transferred in an aggregated level.

If a dispute arises, for example regarding payment, we have the right to use your dataibn order to settle, defend or allege the legal claim.

Legal basis:

Performance of agreement for the information we need in order to fulfill the user agreement of the service.

For information that you allow us to gather from your mobile device the legal basis is your consent.

If a legal dispute arises, we are entitled to use your personal data based on a balance of interest.

Retention time:

The data is stored throughout the contractual relation-ship and up to 24 months from the date of termination of the agreement.

The data may be stored longer if it is required in order to comply with legal requirements, such as for example a retention time of 7 years under the Swedish Accounting Act.

The data may also be stored longer in order to settle, defend or allege a legal claim, for example in case of a dispute regarding payment.

Your rights: You have the right to object to the use of your personal data on the legal basis of balancing of interests. You also have the right to withdraw your consent for the use of personal data gathered from you mobile device based on your consent. If you withdraw your consent you will no longer be able to enjoy customized, personalized, or localized content customized for you. Please see section 9 if you would like to read more about your rights.


Purpose: Protecting Indextra against fraud and misuse of the service

Personal Data:
Contact information such as name, address, telephone number and e-mail address.
Order- and payment details such as order history and payment information, for example your
credit or debit card information (such as card type and expiration date) and other financial
information that we need to process your payment. In addition, the payment processors generally
provide us with some information related to you.
Login information such as e-mail address, user name and password.

Other information you may choose to submit to us, such as full name, profession, specialty, and institute, practice and/or hospital.

What we do:

We use your data to protect Indextra from fraud and misuse by preventing and detecting fraud and misuse of the service, for example by conducting an initial check when you first sign up for the service as well as monitoring your use of the service.

Legal basis:

A balance of interest. We evaluate that our interest of protecting our business from fraud and misuse that may harm Indextra overrides your interest of protecting your personal data

Retention time:

The data is stored throughout the contractual relation-ship and up to 12 months from the date of termination of the agreement. The data may be stored longer if is required in order to comply with legal requirements.

The data may also be stored longer in order to settle, defend or allege a legal claim, for example in case of a dispute.

Your rights: You have the right to object to the use of your personal data on the legal basis of a balance of interest. If you object to the use of your personal data based on a balance of interest, we will only continue to use your personal data if we have compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. Please see section 9 if you would like to read more about your rights


Purpose: Marketing, including newsletters and information via e-mail

Personal data:
Contact information such as name, phone number and e-mail address.
Order - and payment details such as order history and payment information.

What we do:

We use your personal data within for our marketing purposes and segmentation. With segmentation we mean that we categorize our customer basis by demographical selection criteria, such as age, sex, civil status or residence. This processing of personal data is carried out in order to send you marketing, information and newsletters that are not customized regarding offers, services, news and contests to you via e-mail.

Legal basis:

A balance of interest. We evaluate that our interest of sending general and segmented marketing to you weighs heavier than your interest of protecting your personal data (for marketing via postal, phone, social media - and for marketing via e-mail, text message, multimedia messages and other automatic systems if the legal requirements in the Swedish Marketing Act are fulfilled).

Retention time:

For customers, the data will be saved and used throughout the contract period and up to 12 months after the completed contract period. That requires that you have not opposed the direct marketing during that time.

For those of you who are not yet customer: We have the right to keep your data in purpose to send marketing to you during 3 months from the time that we got your contact information. That requires that you have not opposed the direct marketing.

Your rights: You always have the right to request that we stop the using of your personal data for direct marketing purposes. You can configure what kind of e-mail notifications and communication you want to receive from us under My account in the service. You also have the right to object to the use of your personal data on the legal basis of a balance of interest. If you object to the use of your personal data based on a balance of interest, we will only continue to use your personal data if we have compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. Please see section 9 for more information about your rights.


Purpose: Method - and business development and innovation

Personal data: Contact information such as name, phone number and e-mail address.
Order - and payment details such as order history and payment information.
Demographical information such as age, sex, civil status, address and education.

Usage, log data and other information on your interaction with us such as your type of subscription and your interactions with the service, the queries you make to us and the date and time of your request, user content you post to the service, including messages you send and/or receive via the service, this is for the benefit of users, in order to synchronize content with other users whenever they wish, URL, IP address, device and browser type, language, information enabling digital rights management, operating system, and application version and motion-generated or orientation-generated mobile sensor data (e.g., accelerometer or gyroscope).
Browsing habits and visit history such as which pages you have visited on our (and others) websites and how long the visit there lasted.

What we do: We use your personal data to ensure technical functionality of the service, develop new products and services, and analyze your use of the service. We moreover use your personal data for our marketing- and customer analysis. The analysis is carried out mainly through statistics, usage information and data from completed marketing segmentation and customer satisfaction rating. We use the result of our analysis as a basis to improve, replace or produce new services, processes or working method in purpose to meet your and other customer expectations and wishes. We could for example want to use the personal data to improve our customer service, offer new services or alter our website after our customers’ requests. We want to assure you that we always try, as far as possible, to anonymize or pseudonymize your personal data when we fulfill his purpose.

Legal basis: A balance of interest. We evaluate that our interest of analyzing the using of our products and services in purpose to improve, replace or produce new services weighs heavier than your interest of protecting your personal data.

Retention time: We save and use your personal data for this aim during the contract period and up to 12 months after.

Your rights: You have the right to object to the use of your personal data on the legal basis of a balance of interest. If you object to the use of your personal data based on a balance of interest, we will only continue to use your personal data if we have compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. Please see section 9 for further information about your rights.


Purpose: Administration in conjunction with acquisitions, restructuring etc.

Personal data: Contact information such as name, phone number and e-mail address.

Order - and payment information such as purchase - and transaction history.

All other information that we may process about you under the schedules above.

What we do: If Indextra will be restructured, for example gets divided into different operations, or if a third party wish to acquire Indextra or our customer data base, Indextra will provide the takeover company with your and other customers’ personal data. That company will in that case continue to use your personal data for the same purposes that we have stated in this Privacy Notice, if you do not get any other information in conjunction with the restructuring.

Legal basis: A balance of interest. We evaluate that our interest of enabling a company takeover or a restructuring process weighs heavier than your interest of protecting your personal data. This assumes that the takeover company conducts the same operation as Indextra.

Retention time: If Indextra ceases to exist, for example through a merger, liquidation or bankruptcy, or if Indextra's customer data base is being transferred to a takeover company, we will erase your personal data as long as we do not have to save it to fulfill legal requirements.

If Indextra gets acquired by another company or divided in conjunction with a restructuring, we will continue to save and use your personal data according to this Privacy Notice, if you do not get any other information in conjunction with there structuring.

Your rights: You have the right to object to the use of your personal data on the legal basis of a balance of interest. If you object to the use of your personal data based on a balance of interest, we will only continue to use your personal data if we have compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. Please see section 9 to get information of your rights.


4         WHERE DOES YOUR PERSONAL DATA COME FROM?

4.1       The personal data that we use have been given to us by you. When you register as a user, order and pay for the service and when using the service, you provide us with information about you such as name, e-mail address and phone number. We do not obtain information from other sources.

In order to enter an agreement with us at Indextra and for us to be able to provide you with our products and services we require that you provide us with your personal data. If you do not provide us with the personal data that we need from you to drift our operation, we can unfortunately not enter an agreement with you or provide any of our products or services.

4.2        Your mobile device

4.2.1      Our access to your mobile application data is governed and protected by the operating system, but we have restricted the access even further.

4.2.2      We may provide features of the service that rely on the use of additional information on your mobile device or require access to certain services on your mobile device that will enhance your Indextra experience but are not required to use the service. For example, we might allow you to upload photos to your profile, connect with friends, or let you use voice commands to control the service.

4.2.3      Granting us access does not mean you are granting us unlimited access to that information or that we will access information on your mobile device without your permission. On the contrary, for each type of personal data listed in this section, we will ask for your permission before we access the personal data or the services on your mobile device. If you consent to the collecting of personal data, we will collect the personal data only for the specific purposes explained at the time we ask for your permission

4.2.4      You do not have to consent to us gathering personal data from your mobile device in order to use the service, and to confirm that you have read and understood this Privacy Notice does not mean that you have granted us permission to access personal data from your mobile device.

4.2.5      Personal data that you may choose to allow us to collect from your mobile device:

Photos and Camera: We will not access your photos or camera without first getting your explicit consent and we will never scan or import your photo library or camera roll. If you give us permission to access photos or your camera, we will only use images that you specifically choose to add to your notes. You may use our application to select the photo or photos you choose to add, but we will never import the photos you review except those you explicitly add to your notes.

Location: We will not gather or use the specific location of your mobile device (by using, for example, GPS or Bluetooth) without first getting your explicit consent. And if you choose to share location information but change your mind, you will always have the ability to stop sharing that information.

Voice: We will not access your microphone without first getting your explicit consent. You will always have the ability to disable microphone access.

Contacts: We will not scan or import your contacts stored on your mobile device without first getting your explicit consent to do so. We will only use the contact information to help you find friends or contacts who use Indextra if you choose to do so, and we will not use your contacts for any other purpose without first getting your separate explicit consent. Local law may require that you seek the consent of your contacts to provide their personal information to Indextra, who will use the information for the purposes specified in this section.

5            AUTOMATED DECISION MAKING

5.1          We do not use any automated processes when we make decisions which significantly affects you.

6             FOR HOW LONG DO WE STORE YOUR PERSONAL DATA?

6.1          We only store your personal data as long as necessary in order to fulfill the purposes for which we process your personal data under this Privacy Notice. We will remove your personal data from our systems, data bases and back-ups when we do not longer need it. In the schedules above under section 3 you can see how long we store your personal data for different purposes.

We may also have to store your personal data for other reasons, for example to fulfill legal requirements or in order to observe our legal interests or any other compelling interest.

7             TO WHOM DO WE SHAREYOUR PERSONAL DATA?

7.1           Indextra may share your personal data to a third party, such as IT-suppliers and companies that we cooperate with in order to provide our service. We will therefore share your personal data to Braintree, Amazon, Mailchimp. In some cases, we could also have to share your data on the request of authorities or to other parties during for example court- or company takeover processes.

We will not sell or trade your personal data to anyone else.

8            WHERE DO WE USE YOUR PERSONAL DATA?

8.1          Indextra will only use your personal data within the EU/EEA.

9             YOUR RIGHTS

9.1          Our responsibility to fulfill your rights

9.1.1        Indextra, as the Data Controller, is responsible for your personal data and that your personal data is used in accordance with law, as well as ensuring the fulfillment of your rights. You have the right to contact us at any time if you want to exercise your rights. You can find our contact details at the end of this Privacy Notice.

9.1.2       Indextra is obligated to respond to your request to exercise your rights within one month after you contacted us. If your request is complicated or if we recently have received a large amount of requests, we have the right to extend that deadline by two extra months. If we consider us incapable of doing what you request us to do, we are obligated to notify you the reason of our incapability within one month after receiving your request, and inform you about your right to complain to the supervisory authority.

9.1.3       All information, communication and all measures performed by us are free of charge for you. If your request to exercise your rights is manifestly ill-founded or unreasonable we have the right to charge an administrative fee for fulfilling your right of for example access, or refuse to grant your request.

9.2         Your right of access, rectification, erasure and restriction

9.2.1       You have the right to request that Indextra gives you:

a)         Access to your personal data. That means that you have the right to request a record from a register of our use of your personal data. You also have the right to get a free copy of the personal data that we use. We have the right to charge an administrative fee for contingent additional copies. If you submit your request electronically, for example by e-mail, we will provide you with the information in a commonly used electronic form.

b)         Rectification of your personal data. On your request or by our own initiative, we will correct, anonymize, erase or complete data that we found are inaccurate, incomplete or misleading. You have right to complete incomplete personal data with further data.

a)        Erasure of your personal data. You have the right to request that we erase your personal data if we do not have a lawful reason for using the personal data. The personal data shall be erased if:

i.         the personal data no longer is necessary to fulfill for the purpose we collected it for,

ii.        we use your data with your consent as a legal basis and you withdraw your consent,

iii.       you object to the use your data and after a balancing of interest we do not have any compelling legitimate grounds for the processing which override your interests,

iv.       the personal data have been unlawfully processed, or

v.        we have a legal obligation to erase the personal data.

However, there may be legal claims or other compelling reasons for us to not erase your personal data immediately. Then we will stop using your personal data for purposes other than legal obligations or another compelling reason.

b)        Restriction of processing. Restriction means that we temporarily restrict the use of your personal data. You have the right to request restriction of processing when:

a.        you consider your personal data to be incorrect and you have requested rectification in accordance with section 9.2.1 b), during our analysis regarding the correctness of the data,

b.        the use of your personal data is illegal and you do not want the data to be erased,

c.        we, as Data Controller, no longer need the personal data in order to fulfill our purposes but you need it to settle, allege or defend a legal claim, or

d.        if you have objected to the use of personal data in accordance with section 9.3, during the assessment on whether our interests overrides yours.

9.2.2        We will take every reasonable measures that we can to inform everyone that has received personal data according to section 7 if we have corrected, erased or limited the access to your personal data after your request to do so. On your request we will inform you about whom we given the personal data to.

9.3           Your right to object

9.3.1         You have the right to object to the use of your personal data on the legal basis of a balancing of interest (see section 3 above). If you object to the use of your personal data on the legal basis of a balancing of interest, we will only continue to use the personal data if we have important reasons to do so and these reasons override your interests.

9.3.2          If you do not want Indextra to use your personal data for direct marketing, you always have the right to object to such use by contacting us. We will stop using the personal data in marketing purposes as soon as we receive your objection.

9.4            Your right to withdraw your consent

9.4.1          In case we use your personal data with your consent as legal basis (see section 3 above) you have the right to withdraw your consent at any time by contacting us. You find our contact details at the bottom of this Privacy Notice. If you withdraw your consent there is possible that you no longer can use our services as intended to.

9.5           Your right to data portability

9.5.1         You have the right to data portability. It involves a right to receive a part of your personal data in a structured, widely used and machine-readable format, and to transfer this data to another Data Controller. You only have a right to data portability when the use of your personal data is automated and we base our use on your consent or on an agreement with you. It means for example that you have the right to receive and transfer all personal data you have been putting in, in order to create an account with us.

9.6           Your right to complain to the supervisory authority

You have the right to lodge eventual complaints on our using of your personal data to the Swedish Data Inspection Board.

10             WE PROTECT YOUR PERSONAL DATA

You should always feel safe when we use your personal data. Therefore, Indextra has taken all appropriate measures to protect your personal data from undue access, change and erasure. If a safety incident occur that may affect you or your personal data in any significant way, for example when there is a risk for fraud or identity theft, we will get in touch and inform you what can be done to minimize the risk.

11             COOKIES

We use session cookies in order to access the user area of the website. You can read more on our use of cookies in our Cookie Policy www.indextra.com/cookie

12             CHANGES OF THIS PRIVACY NOTICE

The Indextra has the right to change this Privacy Notice at anytime. You will get information about the changes and what they mean to you before they start to apply, with regard to changes that are not only linguistic or editorial. If we need your consent to fulfill our commitments towards you and you do not accept the changed terms, you have the right to terminate the agreement before the terms become effective.

13             CONTACT INFORMATION

Do not hesitate to contact us at Indextra if you have any questions regarding this Privacy Notice, our use of your personal data or if you would like to use your rights.


Indextra AB, org.nr. 556619-6340
Address: Box 7304, 103 90 STOCKHOLM
Phone: +46 8 7832007
Website: www.indextra.com
E-mail address: dpo@indextra.com

_____________________________________

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