Funladder BETA

Privacy Policy

Version: 1.00
Last Updated:

Privacy Policy

Effective Date: August 26, 2025
Last Updated: August 26, 2025

1. Introduction

1.1 Our Commitment

Funladder AB ("Funladder", "we", "us", "our") is committed to protecting your privacy and ensuring the security of your personal data. This Privacy Policy explains how we collect, use, share, and protect your information when you use our mobile application and website (collectively, the "Service").

1.2 Data Controller

Funladder AB, organization number [To be provided], with registered office in Stockholm, Sweden, is the data controller responsible for your personal data processed through the Service.

1.3 Compliance

We process your personal data in accordance with:

  • The General Data Protection Regulation (EU) 2016/679 ("GDPR")
  • The Swedish Data Protection Act (2018:218)
  • Other applicable data protection laws

2. Information We Collect

2.1 Information You Provide Directly

Account Information

  • Identity Data: First name, last name, display name
  • Contact Data: Email address, phone number (optional)
  • Profile Data: Profile picture, bio, preferred sports/games
  • Authentication Data: Account credentials via Clerk.com

Competition Data

  • Match results and scores
  • Opponent information
  • Game preferences and skill levels
  • Tournament participation

Location Data

  • Primary location/city preference
  • Venue check-ins and preferences
  • Country code for regional services

2.2 Information Collected Automatically

Technical Data

  • Device Information: Device type, operating system, unique device identifiers
  • Connection Data: IP address, browser type, time zone settings
  • Usage Data: App interactions, feature usage, session duration
  • Cookie Data: Session cookies, preference cookies, analytics cookies

Location Data

  • GPS Data: Precise location (only with your explicit consent)
  • IP-Based Location: Approximate location from IP address
  • Venue Proximity: Distance calculations for match suggestions

2.3 Information from Third Parties

Authentication Provider (Clerk.com)

  • User ID and authentication tokens
  • Email verification status
  • Profile updates and changes
  • Account deletion requests

Google Places API

  • Venue names and addresses
  • Business hours and contact information
  • Geographic coordinates

Payment Processors (Stripe)

  • Transaction confirmations
  • Subscription status
  • Payment method type (not full details)

3. Legal Basis for Processing

We process your personal data based on the following legal grounds under GDPR Article 6:

3.1 Contract Performance

We process data necessary to:

  • Create and manage your account
  • Provide matchmaking services
  • Maintain rankings and leaderboards
  • Process premium subscriptions

3.2 Legitimate Interests

We process data based on our legitimate interests for:

  • Service improvement and optimization
  • Fraud prevention and security
  • Dispute resolution
  • Aggregated analytics
  • Direct marketing (with opt-out rights)

3.3 Consent

We obtain your explicit consent for:

  • GPS location tracking
  • Marketing communications
  • Cookie placement (non-essential)
  • Participation in surveys or research

3.4 Legal Obligations

We process data to comply with:

  • Tax and accounting requirements
  • Legal proceedings and court orders
  • Regulatory requirements
  • Law enforcement requests

4. How We Use Your Information

4.1 Service Provision

  • Matchmaking: Connect you with compatible opponents
  • Rankings: Calculate and display skill ratings
  • Venues: Suggest nearby locations for matches
  • Communication: Enable in-app messaging between users

4.2 Service Improvement

  • Analyze usage patterns to enhance features
  • Develop new functionalities
  • Optimize user experience
  • Fix bugs and technical issues

4.3 Safety and Security

  • Verify account authenticity
  • Detect and prevent fraud
  • Enforce Terms & Conditions
  • Investigate policy violations
  • Protect user safety

4.4 Communications

  • Service announcements and updates
  • Match notifications and reminders
  • Marketing messages (with consent)
  • Customer support responses

4.5 Legal and Compliance

  • Fulfill legal obligations
  • Respond to legal requests
  • Establish, exercise, or defend legal claims
  • Comply with tax requirements

5. Information Sharing and Disclosure

5.1 Public Information

The following information is publicly visible by default:

  • Username and display name
  • Match results and scores
  • Rankings and ratings
  • Competition history
  • Public profile information

5.2 Other Users

Depending on your privacy settings, other users may see:

  • Your profile and bio
  • Your general location (city level)
  • Your availability for matches
  • Your preferred venues

5.3 Service Providers

We share data with trusted third-party providers:

Provider Purpose Data Shared
Clerk.com Authentication Email, profile data
Stripe Payment processing Transaction data
Google Places Venue information Location queries
Google Analytics Analytics Usage statistics
AWS/Cloud providers Hosting All service data
Intercom Customer support Support inquiries

5.4 Legal Disclosures

We may disclose information when required:

  • To comply with legal obligations
  • To respond to lawful requests from authorities
  • To protect our rights and safety
  • To prevent fraud or security threats
  • In connection with legal proceedings

5.5 Business Transfers

In case of merger, acquisition, or asset sale, your data may be transferred. We will notify you before your information becomes subject to a different privacy policy.

5.6 No Selling of Data

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

6. Data Retention

6.1 Retention Periods

Data Category Retention Period Justification
Active account data Duration of account + 30 days Service provision
Match history Indefinite (anonymized after deletion) Ranking integrity
Payment records 7 years after last transaction Tax obligations
Support tickets 3 years after resolution Service improvement
Marketing consent Until withdrawn + 3 years Compliance proof
Legal compliance logs 5 years Legal requirements
IP logs and sessions 90 days Security purposes

6.2 Deletion and Anonymization

When you delete your account:

  • Personal identifiers removed immediately
  • Email moved to deleted_email field
  • Match data anonymized but retained
  • Backups purged within 90 days
  • Legal compliance data retained as required

7. Your Data Protection Rights

Under GDPR, you have the following rights:

7.1 Right to Access

Request a copy of your personal data we hold, including:

  • Categories of data processed
  • Purposes of processing
  • Recipients of your data
  • Retention periods

7.2 Right to Rectification

Request correction of inaccurate or incomplete personal data.

7.3 Right to Erasure ("Right to be Forgotten")

Request deletion of your personal data when:

  • Data is no longer necessary
  • You withdraw consent
  • You object to processing
  • Data was unlawfully processed

7.4 Right to Restriction

Request restricted processing when:

  • You contest data accuracy
  • Processing is unlawful
  • We no longer need the data
  • You've objected to processing

7.5 Right to Data Portability

Receive your data in a structured, commonly used, machine-readable format and transmit it to another controller.

7.6 Right to Object

Object to processing based on legitimate interests, including direct marketing and profiling.

7.7 Rights Related to Automated Decision-Making

Not be subject to decisions based solely on automated processing that significantly affects you.

7.8 Right to Withdraw Consent

Withdraw consent at any time where processing is based on consent, without affecting prior processing lawfulness.

7.9 Exercising Your Rights

To exercise these rights, contact us at privacy@funladder.com. We will respond within 30 days. We may request identity verification for security.

8. Location Data and Geo-Positioning

8.1 Types of Location Data

Precise Location (GPS)

  • Collection: Only with explicit consent
  • Purpose: Find nearby venues and opponents
  • Control: Disable via device settings anytime
  • Precision: Within 10 meters

Approximate Location (IP-Based)

  • Collection: Automatic for all users
  • Purpose: Regional content and compliance
  • Control: Use VPN to mask location
  • Precision: City or region level

8.2 Location Data Uses

We use location data exclusively for:

  • Showing venues within specified radius
  • Matching with nearby opponents
  • Displaying regional leaderboards
  • Providing location-based recommendations
  • Emergency response (if applicable)

8.3 Location Data Sharing

  • Never sold to third parties
  • Not used for advertising targeting
  • Only shared with mapping services for functionality
  • May be disclosed for legal/safety requirements

9. International Data Transfers

9.1 Transfer Mechanisms

Your data may be transferred outside the EU/EEA. We ensure protection through:

  • EU Standard Contractual Clauses
  • Adequacy decisions by the European Commission
  • Certified providers under EU-US Data Privacy Framework
  • Your explicit consent for specific transfers

9.2 Third-Country Processing

Primary data processing locations:

  • EU: Primary data storage and processing
  • United States: Clerk.com (authentication), Stripe (payments)
  • Global CDN: Content delivery networks for performance

10. Data Security

10.1 Security Measures

We implement appropriate technical and organizational measures:

Technical Safeguards

  • Encryption in transit (TLS/SSL)
  • Encryption at rest (AES-256)
  • Secure authentication (OAuth 2.0)
  • Regular security audits
  • Intrusion detection systems
  • DDoS protection

Organizational Safeguards

  • Limited access controls
  • Employee confidentiality agreements
  • Regular security training
  • Incident response procedures
  • Vendor security assessments

10.2 Data Breach Notification

In case of a personal data breach:

  • Notify supervisory authority within 72 hours
  • Notify affected users without undue delay if high risk
  • Document all breaches and responses
  • Implement measures to prevent recurrence

10.3 Your Security Responsibilities

  • Maintain strong, unique passwords
  • Keep account credentials confidential
  • Report suspicious activity immediately
  • Use secure networks when accessing the Service
  • Keep your device software updated

11. Children's Privacy

11.1 Age Restriction

The Service is not intended for children under 18. We do not knowingly collect data from minors.

11.2 Parental Rights

If we discover data from a minor has been collected:

12. Cookies and Tracking Technologies

12.1 Types of Cookies We Use

Cookie Type Purpose Duration Can be Disabled
Essential Session management, security Session No
Functional User preferences, language 1 year Yes
Analytics Usage statistics, performance 2 years Yes
Marketing Ad targeting, campaign tracking 90 days Yes

12.2 Cookie Management

  • Browser settings to block/delete cookies
  • In-app privacy settings
  • Third-party opt-out tools
  • Do Not Track signal recognition

12.3 Third-Party Cookies

We use cookies from:

  • Google Analytics (analytics)
  • Stripe (payment processing)
  • Intercom (customer support)

13. Marketing and Communications

13.1 Marketing Communications

With your consent, we may send:

  • Product updates and new features
  • Competition announcements
  • Partner venue promotions
  • Tips and best practices
  • Surveys and feedback requests

13.2 Opt-Out Options

You can opt-out anytime via:

  • Unsubscribe link in emails
  • Account notification settings
  • Contacting privacy@funladder.com
  • Mobile push notification settings

13.3 Transactional Communications

We will always send (cannot opt-out):

  • Account security alerts
  • Payment confirmations
  • Terms & Privacy Policy updates
  • Legal notices

14. Third-Party Links and Services

14.1 External Links

The Service may contain links to third-party websites. We are not responsible for their privacy practices.

14.2 Social Media Integration

If you connect social media accounts:

  • We access only permitted data
  • Review platform privacy settings
  • Disconnect anytime in account settings

14.3 Venue Websites

Venue information may link to external sites. These are not controlled by Funladder.

15. California Privacy Rights

15.1 California Residents

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

  • Right to know categories and specific pieces of personal information
  • Right to delete personal information
  • Right to opt-out of sale (we do not sell personal information)
  • Right to non-discrimination

15.2 Shine the Light

California residents may request information about disclosures to third parties for direct marketing.

16. Changes to This Privacy Policy

16.1 Updates

We may update this Privacy Policy to reflect:

  • Changes in our practices
  • New features or services
  • Legal requirements
  • User feedback

16.2 Notification

We will notify you of material changes via:

  • Email notification
  • In-app announcement
  • Website banner
  • Update to "Last Updated" date

16.3 Review

We encourage you to periodically review this Privacy Policy for any changes.

17. Data Protection Officer

17.1 Contact Our DPO

For privacy-related questions or to exercise your rights:

Data Protection Officer
Funladder AB
Email: privacy@funladder.com
Phone: [To be provided]
Address: [To be provided]
Stockholm, Sweden

17.2 Response Time

We aim to respond to all privacy inquiries within 30 days, or as required by applicable law.

18. Supervisory Authority

18.1 Swedish Authority

You have the right to lodge a complaint with:

Integritetsskyddsmyndigheten (IMY)
Swedish Authority for Privacy Protection
Box 8114
104 20 Stockholm, Sweden
Website: www.imy.se
Email: imy@imy.se
Phone: +46 8 657 61 00

18.2 Other EU Authorities

You may also contact the supervisory authority in your EU member state of residence.

19. Legal Basis Summary Table

Processing Activity Personal Data Legal Basis
Account creation Name, email, profile Contract performance
Match recording Scores, opponents, venues Contract performance
Rankings Match history, ratings Legitimate interest
Location services GPS coordinates Consent
Marketing emails Email, preferences Consent
Security monitoring IP address, activity logs Legitimate interest
Payment processing Transaction data Contract performance
Legal compliance All relevant data Legal obligation

20. Contact Information

For questions about this Privacy Policy or our privacy practices:

Funladder AB
Organization Number: [To be provided]
Email: privacy@funladder.com
Phone: [To be provided]
Address: [Address to be provided]
Stockholm, Sweden

EU Representative:
[To be designated]

This Privacy Policy is provided in English. A Swedish translation is available upon request. In case of discrepancies, the English version shall prevail.

By using Funladder, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, and disclosure of your information as described herein.

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