Privacy Policy

Last updated: April 21, 2026

1. Introduction  
Your privacy matters. Our goal is for you to feel confident when sharing your personal data with us. This Privacy Policy explains:  
- What personal data we collect
- How we use it
- Your rights
- How you can exercise those rights  

By using our learning platform and/or services, you acknowledge this Privacy Policy.  

2. Data Controller  
This learning platform is operated by RewardSmarter Learning Sweden AB, which acts as the data controller for all personal data you provide to us.
This includes data shared via:  
- Email
- Phone
- Social media
- Meetings, courses, or seminars

3. Scope of This Policy  
This policy applies when:  
- You enter into an agreement with us
- You use our services
- You request to be contacted  

Personal data refers to any information that can identify you directly or indirectly, such as:  
- Name
- Email address
- Phone number

4. What Data We Collect and Why

Purpose of Processing  
We primarily process your personal data to:  
- Deliver our services
- Fulfill contractual obligations
- Communicate with you
- Provide relevant offers and information

Categories of Processing  
We act as data controller for processing related to:  
- Purchase of services
- Participation in courses or events
- Communication (email, phone, social media)
- Direct marketing

Legal Basis  
We process personal data based on:  
- Contract (to deliver services)
- Consent (e.g., marketing)
- Legitimate interest (e.g., business communication)

Types of Personal Data  
We mainly process:  
Contact details:  
- Name
- Job title
- Company address
- Email address
- Phone number  

Billing information:  
- Company name
- Organization number
- Billing address
- Reference  
- Reference ID

5. Data Sharing and Security  
We are responsible for ensuring that your personal data is processed securely and in accordance with GDPR.  We may share data with trusted third parties (data processors) for administrative and operational purposes. These providers:  
- Act only on our instructions
- Are bound by data processing agreements
- Must implement appropriate security measures  

We do not sell personal data to third parties.  Personal data may be disclosed if required by law, regulation, or authority decision.  

6. Direct Marketing  
If you are a customer or have shown interest in our services, we may send you relevant information and offers via email.  We comply with applicable marketing laws and industry guidelines. You can opt out at any time via unsubscribe links or by contacting us.  

7. External Links  
Our platform may contain links to third-party websites.  This Privacy Policy does not apply to those websites. You should review their policies before sharing personal data.  

8. Your Rights Under GDPR  
You have the right to:  
- Access your data
Request information about how your personal data is processed
- Data access (register extract)
Receive a copy of the data we hold about you
- Rectification
Request correction of inaccurate or incomplete data

Right to Erasure (“Right to be Forgotten”)  
You can request deletion of your data if:  
- It is no longer needed for its original purpose
-  You withdraw consent
- Processing is based on legitimate interest and your rights outweigh ours
- The data has been processed unlawfully
- You object to direct marketing  

Note: This right does not apply where we are legally required to retain data (e.g., accounting laws).  

Additional Rights
- Data portability (when based on consent or contract)
- Restriction of processing
- Right to object to processing
- Right to lodge a complaint with a supervisory authority  

In Sweden, this is the Swedish Authority for Privacy Protection (IMY).  

9. How to Exercise Your Rights 
To exercise your rights, contact us at: info@rewardsmarter.com.  

10. Data Retention  
We retain personal data only as long as necessary to:  
- Fulfill contractual obligations
- Comply with legal requirements
- Resolve disputes

11. Changes to This Policy  
We may update this Privacy Policy from time to time.  If significant changes are made, we will notify affected users via email.