Roughly Right cares about privacy and protecting the Personal Data handled by us. All Personal Data is Processed in accordance with Applicable Law. In this Policy we describe how and the purposes for which we use your personal information as well as what lawful basis we use and what measures we take to protect Personal data. We also provide information on how you exercise the rights you have linked to our Processing of Personal data.
Why and who?
The intended recipient of the information provided in this Policy is:
- Users of the Services
- Employees of potential customers
- Employees of existing customers
- Visitors of our website
"Applicable Law" refers to the legislation applicable to the processing of Personal Data, including the GDPR, supplementary national legislation, as well as practices, guidelines and recommendations issued by a national or EU supervisory authority.
"Controller" is the company/organisation that decides for what purposes and in what way personal data is to be processed and is responsible for the Processing of Personal Data in accordance with Applicable Law.
"Data Subject" is the living, natural person whose Personal Data is being processed.
"Personal Data" is all information relating, directly or indirectly, to an identifiable natural person.
"Processing" means any operation or set of operations which is performed on Personal data, e.g. storage, modification, reading, handover and similar.
"Processor" is the company/organisation that processes personal data on behalf of the Controller and can therefore only process the Personal Data according to the instructions of the Controller and the Applicable Law.
"The Services" Roughly Right is an online business management tool.
The definitions above shall apply in the Policy regardless if they are capitalised or not.
Roughly Right's role as a Controller
The information in this Policy covers Personal Data Processing for which Roughly Right is the Controller. As a Controller we are responsible for the Processing for which we decide the purpose of ("the why") and the means for the Processing (what methods, what personal data and for how long it is stored). The Policy does not describe how we Process Personal Data in the role of a Processor - i.e. when we process Personal Data on behalf of our customers.
Roughly Right is an online tool created for creative agencies and consultancy businesses manage their time and money. It contains time tracking, planning, project analysis, forecasts and invoicing and can be integrated with the business's accounting.
Roughly Right's processing of personal data
We have a responsibility to describe and demonstrate how we fulfill the requirements that are imposed on us when we Process your Personal Data. This section aims to describe:
- That Processing of Personal Data is necessary is for the purpose
- That we have identified the lawful basis for the Processing
Performance of a contract - The Processing is necessary for the performance of a contract entered between us and the Data Subject, or to prepare for entering into an agreement with the Data Subject.
Legitimate interest - Roughly Right may process Personal Data if we have assessed that a legitimate interest overrides the interest of fundamental rights and freedoms of the Data Subject, and if the processing is necessary for the purpose in question.
For how long do we store your personal data?
We will keep your personal data as long as it is necessary for the purpose for which it was collected. Depending on the lawful basis on which we support the Processing, this may a) be regulated in a contract, b) be dependent on valid consent, c) be stated in legislation or d) followed by an internal assessment based on a legitimate interest assessment (LIA). In the list below, we indicate, where possible, the period during which the Personal Data will be stored and the criteria used to determine the storage period.
- Processing and purpose of processing: A user can request a demo or a meeting. We need to store the user's contact information in order to contact them and process their request. Personal data: E-mail, name Source: Directly from the user. Lawful basis: The legitimate interest of returning the user's request to learn more about the product. Storage period: 24 months
- Processing and purpose of processing: We collect data about the user to analyse their behaviour on our website in order to inform our product development and improve the customer experience. Personal data: IP-address, information about the user's browser and device Source: User generated Lawful basis: The legitimate interest of improving the service. Storage period: 26 months
- Processing and purpose of processing: Sourcing from publicly available sources of contact information for potential customers. Personal data: Name, e-mail, telephone number, company. Source: Sourcing from publicly available sources such as potential customer's websites, LinkedIn etc. Lawful basis: The legitimate interest of increasing our sales. Storage period: 24 months
- Processing and purpose of processing: Save information about registered users or potential customers who have opted out for further information. Personal data: Name, e-mail, company Source: Directly for the user Lawful basis: The legitimate interest of fulfillling the user's wish not to receive further information. Storage period: 24 months
You are the one in control of your Personal data and we always strive to ensure that you can exercise your rights as efficiently and smoothly as possible.
Access - You always have the right to receive information about the Processing of data that concerns you. We only provide information if we have been able to verify that it is you that are requesting the information.
Rectification - If you find that the Personal Data we process about you is incorrect, let us know and we will fix it!
Erasure - Do you want us to completely forget about you? You have the right to be forgotten and request deletion of your Personal Data when the Processing is no longer necessary for the purpose for which it was collected. If we are required to retain your information under applicable law or a contract that we have entered with you, we will ensure that it is processed only for the specific purpose set forth in such applicable law or contract. We will thereafter erase the information as soon as possible.
Objections - Do you disagree with our assessment that a legitimate interest for Processing your Personal Data overrides your interest in protecting your privacy? Don’t worry - in such cases, we will review our legitimate interest assessment. Of course, we add your objection to the balance and make a new assessment to see if we can still justify our Processing of your Personal Data. If you object to direct marketing, we will immediately delete your personal information without making an assessment.
Restriction - You can also ask us to restrict our Processing of your Personal Data
- Whilst we are Processing a request from you for any of your other rights;
- If, instead of requesting erasure, you want us to limit the Processing of Personal Data for a specific purpose. For example, if you do not want us to send advertising to you in the future, we still need to save your name in order to know that we should not contact you; or
- In cases where we no longer need the information in relation to the purpose for which it was collected, provided that you do not have an interest in retaining it to make a legal claim.
Data portability - We may provide you with the data that you have submitted to us or that we have received from you in connection with a contract that we have entered with you. You will receive your information in a commonly used and machine-readable format that you can transfer to another personal data manager.
Withdraw consent - If you have given consent to one or several specific processing(s) of your Personal Data, you have the right to withdraw your consent at any time and thus ask us to terminate the Processing immediately. Please note that you can only withdraw your consent for future processing of Personal Data and not for Processing that has already taken place.
How you use your rights
Contact us at firstname.lastname@example.org and we will help you.
Transfer of personal data
In order to run our business, we may need help from others who will process Personal Data on our behalf, so-called Processors.
In cases where our Processors transfer Personal Data outside the EU/EEA, we have ensured that the level of protection is adequate, and in compliance with Applicable Law, by controlling that either of the following requirements are fulfilled:
- the EU Commission has determined that the level of protection is adequate in the third country where the data is processed;
- the Processor has signed up to the EU Commission's standard contract clauses (SCCs) for data transfer to non-EU/EEA countries; or
- the Processor has taken other appropriate safeguards prior to the transfer and that such safeguards comply with Applicable law.
We have entered into Data Processing Agreements (DPA) with all our Processors. The DPA sets out, among other things, how the Processor may process the Personal Data and what security measures are required for the Processing.
We may also need to disclose your personal information to certain designated authorities in order to fulfill obligations under applicable law or legally binding judgements.
Processor: Google (GSuite)
Personal data being processed: E-mail, name, company and other potential information that is disclosed by the user in e-mail conversation.
Instructions: We use G-mail as our e-mail provider.
Personal data being processed: E-mail, name
Instructions: We use postmark to send automated e-mail through the tool
Processor: Amazon Web Services (AWS)
Personal data being processed: E-mail, name, company
Instructions: Amazon Web Services (AWS) is the world’s most comprehensive and broadly adopted cloud platform.
Roughly Right has taken technical and organisational measures to ensure that your Personal Data is processed securely and protected from loss, abuse and unauthorised access.
Our security measures
Organisational security measures are measures that are implemented in work methods and routines within the organisation.
- Login and password management
Technical security measures are measures implemented through technical solutions.
- Secure network
- Regular security inspection
- Two-step verification
If we don’t keep our promise
If you think that we are not Processing your Personal Data correctly, even after you have notified us of this, you are always entitled to submit your complaint to the Swedish Authority for Privacy Protection.
More information about our obligations and your rights can be found at https://www.imy.se/ You can contact the authority via e-mail at: email@example.com
Changes to this policy
We reserve the rights to make changes to this Policy. In the event that the change affects our obligations or your rights, we will inform you about the changes in advance so that you are given the opportunity to take a position on the updated policy.
Please contact us if you have questions about your rights or if you have any other questions about how we process your personal information: