The Preglife application (“Preglife”) is operated by Preglife AB (corporate identity number 556768-4278) (“we”, “our”, “us”). Preglife AB is the data controller for the processing of personal data in the Preglife app. We care about protecting the personal privacy of our users and therefore strive to maintain the highest possible standard in the protection of personal data. Toward this end, we commit to following this personal data policy (“The Personal Data Policy”). The Personal Data Policy includes information about how we collect your personal data as user (“User”), how we use the data and how we protect the data. We therefore encourage you to read the Personal Data Policy before you start using Preglife.
The Personal Data Policy is a supplement to our Terms of Use (“Terms and Conditions”). In the event of any conflicts between the Personal Data Policy and the Terms and Conditions, the Personal Data Policy takes precedence.
If you would like to contact us about this Personal Data Policy, or if you have questions regarding our processing of personal data, you will find the contact details to Preglife and our data protection representative under Clause 14 Contact Details.
1 About the data protection regulation
1.1 For data that Users provide (according to the below definition) and which is considered to be personal data, we are required to comply with applicable personal data legislation, including the General Data Protection Regulation 2016/679 (GDPR) and the Swedish Data Protection Act 2018:218 with complementary provisions to the EU’s General Data Protection Regulation. All personal data that Users provide us with through the framework of Preglife will be processed by us in the capacity of controller.
1.2 If you enter personal data about other people in Preglife, such as names or pictures of other people, you should ensure that you have these people’s consent to enter such data in Preglife.
1.3 To the extent that your personal data is entered in Preglife by another person, you are also covered by this Personal Data Policy and we are the data controller for the processing of such data.
2 About different users
2.1 When you register yourself, an Account is created for you and you become User. As User, you can access your Account from other devices and the information is stored with us (as well as on local devices that you login on). If you have not registered yourself, information is stored only on your device. This means that we do not process your personal data, but it also means that you cannot access your account from elsewhere or get help to recreate data that you have mistakenly deleted.
2.2 Preglife is primarily intended for pregnant women, those close to pregnant women wanting to follow the pregnancy as well as new parents and those close to these parents wanting to follow the child’s development. When registering an account, you can enter if you are the person who is pregnant, expecting a child/partner, or friend or family member of the mother to be. The purpose of processing data is to provide you with relevant information based on your choices. It is possible to use Preglife even if you are not following a particular pregnancy or child. In that case, choose the alternative “I have no children and I am not pregnant but I want to use the app.”
3 Personal data, purpose and legal basis
3.1 Account information – To register an Account, you must provide the following information:
- Email address
- Password
The purpose of processing data is to provide a secure login to your Account, and to enable us to contact you with important information, such as updated terms and conditions or to reset your password.
The legal basis for the processing is the contract with you as User. You can also register your or your partner’s name. You can use an alias or your real name, and you can change or erase it at any time. It is not required for registration. 3.2 We also use your e-mail address to be able to send e-mail with relevant information which may contain targeted or general offers and other advertisement. All such e-mails will be provided with a link which you may follow and thereby be able to choose not to receive such advertisement e-mails.
3.2 Estimated due date – If you want to follow a specific pregnancy, you must provide an estimated due date, or the date of the first day of the most recent period in combination with the pregnant woman’s menstruation cycle (number of days), in which case the estimated due date is calculated based on the date you enter. The estimated due date helps ensure that you receive relevant information and offerings based on where you are in the pregnancy. The purpose of this data is to enable Preglife to show relevant information and offerings for the pregnancy that you want to follow and based on the child’s age if you enter the date of birth.
The legal basis for the processing is your consent, which we secure before the processing can commence. Please refer to Clause 5 about Processing of Personal Data based on Consent.
3.3 Data about the child – After the pregnancy, or when you start using the app, you have the option to enter the date of birth to track the child’s age. This will provide you with relevant information about the child’s first two years of development. You can also enter data about children who are already born (in other words, the child need not be registered in Preglife before birth). You can also enter the child’s name, gender, data about weight and length at birth and the child’s development “milestones”, such as baby’s first smile or word together with the date, and a picture of this milestone. In this regard, we encourage you to contact any other guardians before you enter information about a child.
The purpose of this data is to enable Preglife to show relevant information and offerings based on a child’s age.
The legal basis for the processing is your consent, which we secure before the processing can commence. Please refer to Clause 5 about Processing of Personal Data based on Consent.
3.4 Diary and pictures – The diary function gives you the option to make entries in the diary and post pictures. You control the content yourself and which personal data will be processed. This means that health related data may be processed.
The purpose is to be able to provide diary documentation and pictures that you choose to upload in Preglife.
The legal basis for the processing is your consent, which we secure before the processing can commence. Please refer to Clause 5 about Processing of Personal Data based on Consent.
3.5 Medical conditions, vaccines and other health-related data – Preglife offers Users the option to save health-related data, vaccines, hereditary and current medical conditions as well as data to calculate length and weight curves. This data may pertain to both mother and child. In this regard, we encourage you to contact any other guardians before you enter information about a child.
Other health-related data includes information generally collected by authorized medical staff, such as blood test results for Rubella, RhD, HB G/L as well as blood pressure and glucose levels.
As User you can also opt to save information about whether you are a first-time mother or if you have given birth previously, if you are expecting twins (or more), planning a Cesarean Section, and if you have any hereditary or ongoing medical conditions, such as pre-eclampsia, diabetes, a liver disease, thrombosis, high blood pressure, a thyroid disease and cell changes from a screening. You can also register how you feel (state of health) and enter various symptoms such as nausea that you experience during and after the pregnancy.
The purpose is to be able to provide functions that enable you to document your health data in Preglife and to give you more relevant content based on the data you’ve entered. For example, if you enter that you are expecting your second child, some of the content in Preglife will be adjusted so that it is more relevant and so that we can offer better information during and after the pregnancy.
The legal basis for the processing is your consent, which we secure before the processing can commence. Please refer to Clause 5 about Processing of Personal Data based on Consent.
3.6 Newsletters – As a Preglife User, you can receive newsletters with information and offerings that are sent to your email address if you give your consent. If you have entered an estimated delivery date or the age of the child, you can receive newsletters in which the content has been adapted. There is a link in every newsletter that you can click on if you do not wish to receive any more newsletters.
The purpose is to be able to provide you with Preglife’s newsletters, containing information and offerings.
The legal basis for the processing is your consent, which we secure before the processing can commence. Please refer to Clause 5 about Processing of Personal Data based on Consent.
3.7 Metadata – In addition to information that you provide to us directly, we will collect metadata on your device (cell phone, tablet, etc.). Examples of such information are:
- Data about the operating system and version
- Language settings
- Screen resolution
The purpose of processing such data is to make it technically possible to provide you with Preglife, but also to be able to adapt Preglife according to your settings.
The legal basis is the contract with you as User.
3.8 Data about user behavior – We will also use data about your use of and behavior in Preglife (for example, how many times you open Preglife, which articles you read, etc.). This data is rendered anonymous.
The purpose of the processing is to develop Preglife and continue to provide a good service to you as user.
The legal basis is Preglife’s legitimate interest in developing our services and improving these for our users.
3.9 Payment information - Premium account – Most of the content in Preglife is free of charge, but some content is made available only after payment has been made. Payment is made primarily through Google or Apple’s services, but may also include purchases through other providers such as Klarna or PayPal. In the event of a purchase, the following information is processed: what was purchased, the method of payment, the time of the purchase and the price. In conjunction with a payment, we transfer payment data to the selected payment service provider who is, in turn, the data controller for the processing of your personal data.
The purpose of the processing is to be able to complete the desired purchase.
The legal basis for the processing is the contract with you as User.
3.10 Surveys – We conduct recurring surveys where you as a user, for example, can answer a number of questions about your experience of Preglife and your experience of pregnancy. Participation is completely voluntary. Your answers will be anonymized.
The purpose of the processing is to gain insights into our users’ experiences of Preglife and pregnancy so that we can develop our services and improve them for our users.
The legal basis for the processing is Preglife’s legitimate interest in developing our services and improving these for our users.
3.11 Information about geographic area – We also use information about your device’s IP address. The IP address tells, among other things, which geographical area you use your device in.
The purpose of the processing is to adapt the marketing of Preglife. We use IP addresses to tailor our marketing to regions/cities that have more than 10 000 Preglife users. The marketing is not based on how you use Preglife, but only that you are in a certain geographical area. In this way, we can adapt the marketing and show relevant advertisements to our users.
The legal basis for the processing is Preglife’s legitimate interest in displaying advertisements and offers that are relevant to our users.
4 Special information about children’s date of birth and other personal data about children
4.1 To the extent that you yourself provide data about a child, the data will be processed in accordance with the stipulations under Clause 3 above, Personal data, purpose and legal basis. From birth, your child has his or her own rights in accordance with the personal data legislation.
4.2 The only information that we use that is directly linked to your child is the date of birth. However, it is possible to identify the child when combined with the information that you yourself upload in Preglife. This means that we may process your child’s personal data.
4.3 We have no interest in identifying your child since it is to you as User that we provide Preglife and process only personal data about your child to the extent that you have registered this data in Preglife.
4.4 Regardless of whether the personal data legislation is applicable or not, we ask that you consider your child’s personal privacy and right to control his or her own personal data, and that you contact any other guardians/parents before you enter information about a child.
4.5 We recommend that you erase your child’s personal data from Preglife, or discuss the matter with the child, as soon as your child is old enough to understand and have an opinion about privacy-related matters.
5 Special information about consent as legal basis for processing
5.1 In Preglife, you have the option to enter how far you are in your pregnancy and other pregnancy-related health data. This means that Preglife needs your consent in order to process this health data and thereby be able to deliver the application in the manner in which you want to use it. All usage of the application is done voluntarily and it is always you as User who decides which information you want to enter.
5.2 Since health data is required for many of the basic functions, you will have the opportunity to give your consent when you create an account. If you do not choose to give your consent, in full or partially, you will be able to use Preglife to a limited extent and have the opportunity to give your consent later when you want to use specific functions.
5.3 You may withdraw your consent at any time. The easiest way to do so is to go to Settings and adjust which consents you want to withdraw. You can also contact Preglife. Use the contact details provided under Clause 14 below. Important! If you withdraw your consent, there is a risk that the information in the relevant functions will be deleted. To ensure that data is not deleted by mistake, extra verification will be required and you will receive a reminder about this when you withdraw a consent that entails a risk that information may be deleted.
5.4 If you withdraw a consent, the relevant function will not be available and you will not be able to enter new information there. If you want to erase certain data, the easiest way to do so is to directly delete the relevant information in Preglife (for example, if you have entered your blood pressure or made an entry in your diary).
6 Separate information about consent for shared accounts
6.1 Users have the option to share their account with those close to them, who then gain access to the information that Users have saved in Preglife.
6.2 It is the User who shares the account who manages consent for the shared account. This means that the User who is assigned an account is not authorized to give or withdraw consent for the shared account.
6.3 If a User shares an account, the User with whom the account is shared may also add information to the shared account. The information is then available to all Users granted access to the account.
6.4 The User who has shared an account may at any time revoke the sharing of the account, at which point the User who was previously assigned access to the account will be logged out the next time they open Preglife. Also, the User who is assigned access to an account may at any time choose to disconnect from the shared account. The User who is disconnected, or who chooses to disconnect from an account, will therefore no longer have access to information in the saved account.
This applies also to information that the User who has been disconnected, or who has chosen to disconnect, has uploaded to the previously shared account.
7 Manage your personal information
The length of time that we store personal data depends on the legal basis we have for the processing. Personal data will be stored until such time as there is no longer any legal basis. The same data can be processed on different bases and will therefore be deleted when all bases are irrelevant.
7.1 Personal data that we use because the data is required to perform a contract with you is processed until such time that you close your Account and request the data be deleted. If you do not specifically request deletion, account information and other information you uploaded yourself (over which we have no control) will be saved for a maximum 24 months to make it possible to reset your Account.
7.2 When you close your account, a question will be sent to you if you want us to continue to save your data. We will save the data only so that you personally can access it (for example, to show to your child in the future) and we will not use the data for anything else.
7.3 Personal data that we use, provided you have given your consent, is processed until such time that you withdraw your consent. If you close your Account, the data will be saved in the same way we save account information. You withdraw your consent by following the instructions in Clause 5 above or by deleting the data in Preglife yourself.
7.4 Data about user behavior will be processed by us as long as you use Preglife. You are entitled to object to such processing. To do so, send an email to privacy@Preglife.com. When we receive such a request, we will decide whether we will stop processing the data or not. We will notify you of our decision, and if we decide to continue the processing, we will state the reasons why.
7.5 Data about your child’s/children’s date of birth will be processed by us until you yourself erase the data from your Account. The child or anyone who has parental responsibility for the child may object to such usage. When we receive such a request, we will decide whether we will stop processing the data or not. We may ask you for your opinion on the matter before we make a decision. We will notify you (and the person who made the request) of our decision and explain the reason.
8 Your rights
When Preglife processes your personal data, you have certain rights when you are registered. Briefly, you are entitled to receive information about which data we process about you, to see that the data is correct, and to complain of you feel that we are doing something that is wrong.
8.1 More specifically, the following rights may apply to you:
- The right to receive information about the personal that we process about you.
- The right to have any incorrect personal data rectified or blocked for a period so we can verify that the data is incorrect.
- The right to have your data deleted after your Account has been closed.
- The right to request that the processing of your data is restricted under certain conditions if so specified in Article 18 of the General Data Protection Regulation (GDPR); for example, if you feel that the data is incorrect or if there is no legal ground but you do not want the data to be deleted.
- The right to data portability, meaning the right to obtain data that you have provided us with in a “structured, commonly used and machine-readable format”.
- The right to make a complaint about how we process your personal data. We welcome comments and any complaints in order to be able to improve our services, but you also have the right to make a complaint to the relevant supervisory authority (the Swedish Authority for Privacy Protection, in Sweden).
9 Security and transfer to third country
9.1 We are intent on protecting your personal privacy and your interest in ensuring that your and your child’s personal data is treated with great caution. Subsequently, we apply high security standards and do our utmost to ensure high data security.
9.2 We will take all measures that can reasonably be demanded to ensure that your personal data is processed in a secure manner and in accordance with the Personal Data Policy. However, when it comes to internet security, no system is foolproof. The transfer of data is therefore done at your own risk. If a security breach occurs, Preglife will naturally take action as soon as possible to rectify the problem.
9.3 To the extent that Preglife uses personal data processors that process personal data outside the EU/EES, this is only allowed when we have concluded that it is suitable or necessary, and after sufficient security measures have been taken and documented. Please contact us for more information concerning any transfers to a third country.
10 Disclosure of personal data to third parties and personal data processors
10.1 We will never, under any circumstances, sell or share any personal data from Preglife to third parties unless required of us by law or otherwise stipulated in this Clause 10.
10.2 You can provide personal data to our partners in Preglife. For example, if you want to use a current offering or in conjunction with payment through an external payment services provider. The providing of such information is completely voluntary and is not necessary for the use of Preglife.
10.3 If you provide personal data to our partners through a special form in Preglife, such partners are then data controllers for the processing. We recommend that you carefully read the relevant partner’s personal data policies before you provide personal data.
10.4 If you provide personal data to our partners through special forms in Preglife, we may also send information about the estimated delivery date to such partners where the partners need that information in order to be able to deliver the service/offer to you as a customer.
10.5 Preglife uses external companies that serve as Personal Data Processors for the processing of your personal data, for example, in regard to storing data on servers. We collaborate only with serious companies of good repute that can ensure your personal data is processed in a correct manner. Such Personal Data Processors may never process your personal data in any way other than as instructed by us and in accordance with the Personal Data Policy.
10.6 We will not use your email address to send unwanted email communication or share your email address to a third party without your consent. Any emails sent from Preglife will comply in full with the Personal Data Policy and the Terms and Conditions.
11 Information at an aggregate level (not referring to any one person)
11.1 As described under point 3 above, we will anonymize your personal data in certain cases. When personal data is anonymized, you as an individual user can no longer be identified based on the data. The anonymization of your personal data does not affect your experience of our service. We use the aggregated information to develop our services and improve them for our users.
12 Links to other websites
12.1 Preglife may contain links or references to other websites where the Personal Data Policy does not apply. If you follow such links, and thereby leave Preglife, We are not responsible for how these websites manage your personal data. We recommend that you always read the Personal Data Policy and other terms and conditions that apply for the websites you visit.
13 Amendments
13.1 We may, now and again, make changes in our Personal Data Policy. All amendments will automatically take effect 30 days after they are published in Preglife. If we make amendments in the Personal Data Policy deemed necessary to perform our obligations in accordance with laws or government agency statements or decisions, the new Personal Data Policy will take effect immediately after it is published in Preglife.
14 Contact information
14.1 The easiest way to contact Preglife is to send an email to privacy@preglife.com
14.2 If you would like to send a letter, please address it to: Data controller: Preglife AB Regeringsgatan 93 SE-111 39 Stockholm
14.3 Contact details data protection representative: Matilda Weinberger, Insatt AB, dso.preglife@insatt.com