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Privacy Policy

Introduction

Introduction Welcome to Srcful AB ("Srcful"), corporate identity number 559382-0458 (“we”, “our” and “us”), providers of the www.srcful.io website along with our other products and services. The privacy and security of our users are taken seriously. This Privacy Policy contains information on when and how we process your personal data and what rights you have when it comes to this data processing.

Data controller

Srcful is the data controller for the processing of your personal data and is responsible for ensuring that all processing is carried out in accordance with applicable law.

How we process your personal data and why

To analyse how our website is used in order to make improvements

What processing we performWhat personal data we processOur legal basis for the processing
  • Analyse how you use our website to improve our website and services. To do this we use our own analytic cookies and the analytic service from Google Analytics
  • The analytic service means that we place a random ID on your device to distinguish your device from other visitors and to acknowledge patterns in how our website is used. We will however not know who you are
  • The personal data we collect will be used e.g. to optimise functions and to adapt the websites to suit our visitors
  • An encrypted version of your IP address which Srcful cannot connect to you as an individual
  • Information about your device/browser (which area in the country you use our website from and your screen resolution)
  • Information about your activities on the website
  • Other information Google has about you, e.g. information about from which site you found us
Consent (6.1 (a) GDPR)

Your personal data will be processed based on your consent. You can withdraw such consent at any time by contacting us.

You can prevent Google Analytics from using your personal data by downloading and installing this browser add on.
Storage

Storage period: We will store your personal data for a period of twenty-six (26) months after your visit on our website. Google will continue to use your personal data for their own purposes and Google will inform you separately about such processing.

To handle your notice of interest to use our services

What processing we performWhat personal data we processOur legal basis for the processing
  • Store your answer to our Notice of Interest form
  • Handle your request for information on when the Srcful Gateway is available for purchase
  • Name
  • Email address
  • Contact details
Legitimate interest.

Your personal data will be processed based on our legitimate interest to reach out to customers who have signed up for more information about Srcful.
Storage period

The data is stored until your request is handled and one year thereafter.

To enter into an agreement with you and provide hardware devices

What processing we performWhat personal data we processOur legal basis for the processing
  • Enter into an greement with you
  • Provide hardware device
  • Administrate and forward your order to the supplier/manufacturer of the hardware device
  • Name
  • E-mail address
  • Postal address
  • Payment information
  • (Solana public wallet address)
The processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Storage period

The data is stored for as long as necessary to provide the hardware device in accordance with the contract, and to handle any claims based on the provision of the hardware device.

To handle refunds in accordance with consumer legislation

What processing we performWhat personal data we processOur legal basis for the processing
  • Store information in sales documentation
  • Name
  • E-mail address
  • Postal address
  • Payment information
  • (Solana public wallet address)
Legal obligation.

The processing is necessary to comply with legal obligations to which we are subject, i.e. consumer sales legislation.
Storage period

The data is stored until claims for refunds under the Swedish Consumer Sales Act or other applicable mandatory consumer legislation can no longer be enforced.

To handle damages according to the product liability legislation

What processing we performWhat personal data we processOur legal basis for the processing
  • Store information in sales documentation
  • Name
  • E-mail address
  • Postal address
  • Payment information
  • (Solana public wallet address)
Legal obligation.

The processing is necessary to comply with legal obligations to which we are subject, i.e. product liability legislation.
Storage period

The data is stored until claims for damages under the Swedish Product Liability Act or other applicable mandatory product liability legislation can no longer be enforced.

To comply with accounting legislation

What processing we performWhat personal data we processOur legal basis for the processing
  • Store information in accounting material
  • Name, history regarding payments that have been made and other information that constitutes accounting records.
Legal obligation.

The processing is necessary to comply with legal obligations to which we are subject, i.e. accounting legislation.
Storage period

We will store any document constituting accounting material and the personal data included therein according to the storage period stated in the accounting legislation.

For instance, in Sweden this means that we will store your personal data for seven to eight years, i.e. until and including the seventh year after the end of the calendar year for the fiscal year to which the personal data relates.

To enable usage of the Srcful Energy Gateway and the receivement of SRC tokens

What processing we performWhat personal data we processOur legal basis for the processing
When linking your Solana wallet to the Srcful platform, we store your dataSolana public wallet address

Your Solana public wallet address may in some cases be regarded as personal data.
Legitimate interest.

Your personal data will be processed based on our legitimate interest to connect you as a user to the Srcful Platform to ensure you can use the Srcful Energy Gateway.
Storage period

The data is stored for as long as you Solana Wallet is connected to the Scrful Platform.

Who can gain access to your personal data and why?

Srcful will process your personal data. When a third party, such as our IT and system suppliers, processes your information on our behalf, we have signed a data processing agreement with them. This means that they are obliged to process the information securely, accurately and confidentially.

Our data processors are:

  • Google Workspace - cloud services.
  • Google Analytics – cookies.

We also transfer your personal data to recipients who are not processors. The recipients are independent data controllers for their processing. Such recipients include, for example, public authorities if such disclosure is required by law, banks, and payment service providers.

Transfers of personal data to countries outside EU or EEA (“third countries”)

As a general rule, we and our suppliers and partners process your personal data only within the EU/EEA. In cases where personal data are processed outside the EU/EEA, we base the processing either on a decision from the European Commission that the relevant third country ensures an adequate level of protection, or appropriate safeguards, e.g. standard data protection clauses, to ensure that your rights are protected.

In the following cases, we may transfer personal data to third countries:

  • Personal data, such as e-mail address, that is provided by customers in Google Forms or in e-mail correspondence with us might be transferred by Google to the USA. The transfer is based on a decision from the European Commission that the relevant third country ensures an adequate level of protection as Google is subject to the EU-US Data Privacy Framework.
  • If you use our website and have consented to us using Google Analytics, your personal data may be transferred by Google to the USA. The transfer is based on a decision from the European Commission that the relevant third country ensures an adequate level of protection as Google is subject to the EU-US Data Privacy Framework.

If you wish to receive a copy the safeguards taken by us or information regarding where these safeguards have been made available, please contact us by using the contact details stated below.

How do we protect your personal data?

We, and in relevant cases third parties, have taken several security measures to protect the personal data that is being processed. We have firewalls and anti-virus software to protect and prevent unauthorised access to our networks and systems. Our employees have strict instructions to process all personal data in accordance with applicable laws and regulations.

Your rights

Right to withdraw a given consent (Article 7.3 GDPR)

You have the right to withdraw your consent at any time, with effect from the date of withdrawal.

Right to access (Article 15 GDPR)

You have the right to obtain confirmation as to whether we are processing personal data concerning you or not. You can make a request by contacting us. If we do process your personal data, you also have a right to obtain a copy of the personal data processed by us as well as information about our processing of your personal data.

Right to rectification of processing (Article 16 GDPR)

You have the right to obtain, without undue delay, the rectification of inaccurate personal data concerning you. 

Right to erasure (“the right to be forgotten”) (Article 17 GDPR)

You have the right to obtain erasure of your personal data, if any of the following applies:

  • the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed,
  • you object to the processing pursuant to Article 21.1 GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21.2 GDPR,
  • the personal data have been unlawfully processed, or
  • the personal data have to be erased for compliance with a legal obligation in Union or Member State law that applies to us.

Please note that our obligation to erase and inform according to above shall not apply to the extent processing is necessary:

  • for exercising the right of freedom of expression and information,
  • for compliance with a legal obligation which requires processing by Union or Member State law which applies to us, or
  • for the establishment, exercise or defence of legal claims.

Right to restriction of processing (Article 18 GDPR)

You have the right to obtain from us restriction of the processing of your personal data if:

  • the accuracy of the personal data is contested by you, during a period enabling us to verify the accuracy of the personal data,
  • you have objected to processing pursuant to Article 21.1 GDPR pending the verification whether our legitimate grounds override yours,
  • the processing is unlawful, and you oppose the erasure of the personal data and instead request the restriction of their use, and
  • you need the personal data for the establishment, exercise or defence of legal claims even though we no longer need the personal data for the purposes of the processing.

Right to data portability (Article 20)

If you have given your consent, or if we base the processing on a contract with you, you have the right to obtain the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format and to transmit it to another controller or to obtain our assistance in transmitting it to another controller where technically feasible.

Right to object (Article 21 GDPR)

You have the right to object, on grounds relating to your situation, at any time to processing of your personal data which is based on Article 6.1 e (public interest) or 6.1 f (legitimate interest) GDPR, including profiling based on those provisions. We shall no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Right to lodge a complaint with a supervisory authority (Article 77 GDPR)

You have the right to lodge a complaint with a supervisory authority. The supervisory authority in Sweden is the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY).

Contact us

If you have any questions or if you wish to exercise any of your rights, do not hesitate to contact us at sales@srcful.io.