PRIVACY POLICY FOR STORYTEL

1. GENERAL

1.1.
Storytel is an internet based digital subscription service that gives you (hereinafter “You” or the “User”) access to audio books and e-books in Your mobile phone or on Your tablet or other device (the “Service”) pursuant to the terms and conditions of the User Agreement (the “Terms”). The Service is provided by Storytel Sweden AB, corporate identity number 556696-2865, (hereinafter ”Storytel” or “we”). This privacy policy explains Storytel’s practices regarding its collection, use and disclosure of certain information, including Your Personal Information when we provide the Service to You. It serves to inform You about our processing of Your Personal Information and ensure You that Your Personal Information is treated with respect and in accordance with the applicable data protection legislation when using the Service.
1.2.
You should always feel safe when sharing Your Personal Information with Storytel. Storytel has taken the technical and organizational security measures that are required to ensure that Your Personal Information is protected from unauthorized access, use, modification and deletion.

2. PERSONAL DATA CONTROLLER

2.1.
Storytel Sweden AB is the data controllers for the processing of Your Personal Information handled by Storytel. Information on how to contact us can be found in section 14.

3. WHEN DOES STORYTEL COLLECT PERSONAL DATA?

3.1.
Storytel collects Personal Information about You when:
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You set up an account with Storytel and use the Service,
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You order an add-on service or a product from Storytel,
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You register as a subscriber to Storytel’s newsletter,
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You report errors or contact Storytel’s customer services for any other reason,
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You link the Service to Your Facebook account or a similar third-party service that independently controls Personal Information,
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You answer a survey, including but not limited to customer satisfaction questionnaires or marketing surveys or reply to communication from Storytel, or
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It is otherwise necessary to manage the relationship between You and Storytel.
3.2.
Storytel also collects information through our own or third-party cookies and similar tracking technologies that may track Your activities and choices, i.e. when You use the Service or visit our Website. Further information about Storytel’s use of cookies is stated in Storytel’s cookie policy.
3.3.
Storytel acquires information from other trusted sources to update or supplement the information you provided or we collected automatically. Local law may require that you authorize the third party to share your information with us before we can acquire it.
3.4.
Please keep in mind that when you provide information to us on a third-party site or platform (for example, via our Website), the information you provide may be separately collected by the third-party site or platform. The information we collect is covered by this privacy policy and the information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our Website.

4. WHAT PERSONAL DATA DOES STORYTEL COLLECT?

4.1.
When You set up an account with Storytel or contact Storytel’s customer services, Storytel collects Personal Information about You. Basic user data that Storytel collects includes Your name and/or user name and/or password, e-mail address and/or phone number and Your payment details. Storytel may also collect data regarding Your date of birth, gender and additional contact details such as Your address. Storytel may also collect Personal Information that You provide about Your family members (including Your family members’ names, dates of birth and their interests). When using the Service or any additional Storytel services and products, and when visiting Storytel’s Website, Storytel may also collect data concerning usage, viewing and technical data, including Your IP address and any other device identifier information. If, when You signed up as a customer with Storytel You signed up as an invoice customer, Storytel may also need to collect and process some of the information You provide to Storytel’s payment service provider to facilitate such invoicing.
4.2.
If You choose to link the Service to Facebook or a similar third-party service that controls Personal Information, Storytel may collect and process information which You give Facebook, or such other third-party, permission to share with Storytel.
4.3.
Further Storytel may also collect and process Information that You provide in public forums on Storytel’s Website or to Storytel when You use Storytel’s Website, Storytel’s sites on third-party platforms such as social networking sites or link Your profile on a third-party site or platform with Your personal account.
4.4.
Storytel may also collect and process certain information related to Your chosen method of payment. The Personal Information collected by Storytel for this purpose serves to check Your eligibility to the Service and to identify Your method of payment. However, as Storytel cooperates with third party payment service providers who operate independently in systems separated from Storytel, no complete payment data, such as complete credit card numbers, will be stored or collected by Storytel.
4.5.
Further Storytel may collect following categories of information:
i.
Transaction information you provide when you request information or purchase a service from us on Storytel’s Website, including your postal address, telephone number and payment information;
ii.
Information you provide in public forums on Storytel’s Website;
iii.
Information sent either one-to-one or within a limited group using our message, chat, post or similar functionality, where we are permitted by law to collect this information;
iv.
Information you provide to us when you use Storytel’s Website, Storytel’s Website on third-party sites or platforms such as social networking sites, or link your profile on a third-party site or platform with your registration account;
v.
Location information when you visit Storytel’s Website, including location information either provided by a mobile device interacting with our Website, or associated with your IP address, where we are permitted by law to process this information.
4.6.
You understand, acknowledge and conditionally grant consent to Storytel to use and process your Personal Information for marketing and promotional purposes as set out in this Privacy Policy. In the event you do not wish to receive any marketing and promotional offers then you may unsubscribe. See instructions

5. INFORMATION THAT CANNOT BE UPLOADED

5.1.
You shall not host, display, upload, modify, publish, transmit, update or share any information on Storytel’s Website that:
i.
belongs to another person and to which you do not have any right to;
ii.
is grossly harmful, harassing, blasphemous defamatory, obscene, pornographic, paedophilic, libellous, invasive of another's privacy, hateful, or racially, ethnically objectionable, disparaging, relating or encouraging money laundering or gambling, or otherwise unlawful in any manner whatever;
iii.
harms minors in any way;
iv.
infringes any patent, trademark, copyright or other proprietary rights;
v.
violates any law for the time being in force;
vi.
deceives or misleads the addressee about the origin of such messages or communicates any information which is grossly offensive or menacing in nature;
vii.
impersonates another person;
viii.
contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer resource;
ix.
threatens the unity, integrity, defence, security or sovereignty of India, friendly relations with foreign states, or public order or causes incitement to the commission of any cognisable offence or prevents investigation of any offence or is insulting any other nation.

6. HOW LONG IS THE DATA KEPT?

Storytel will keep Personal Information regarding You only as long as it is necessary, having regard to the purpose of the processing. This means that Personal Information collected and processed for marketing purposes will be stored for as long as You have an account and deleted twelve (12) months after Your subscription has ended unless You have given Storytel Your voluntary consent to continue to process such data. In order to monitor usage of gift cards and Free Trial periods, we will store the basic information You have provided at sign up (Your name and/or user name, e-mail address and/or phone number and payment details) for a period of twenty-four (24) months after Your subscription, use of a gift card or Free Trial has ended. We will also, during the same period, keep Your personal Storytel audio/e-book library information, to facilitate Your easy return. Storytel may store data for longer if required by law or if required in order to monitor Storytel’s legal interests, for example if there are ongoing legal proceedings.

7.
WHY DOES STORYTEL PROCESS INFORMATION ABOUT YOU?

7.1.
Storytel processes Your Personal Information for various purposes. Primarily, Storytel processes Your Personal Information for internal data processing and/or to provide, manage, develop and customize the Service and its features, to manage the customer relationship with You and to meet security and other statutory requirements. Your Personal Information may also provide the basis for market and customer analysis, market research, statistics, business monitoring and business and methodological development for Storytel. This may e.g. include processing of personal data for the purpose of creating customer audiences on third party platforms.
7.2.
Storytel also processes Your Personal Information to provide better and more personalized offers and services. Personal Information may, for example, be processed, linked, segmented and analyzed in order, by means of targeted marketing by way of e-mails and/or in app push notifications, to provide information, offers or recommendations on Storytel’s or its partners’ goods and services, which are tailored to Your preferences, behaviors, needs or lifestyle. Storytel may also analyze and combine the information about You to which Storytel has access via the Service from Your online visits or other records (e.g. Facebook or other similar social media providers) for purposes specified in this section.
7.3.
In addition to the above, Storytel processes Your Personal Information to prevent, detect and investigate potential prohibited or illegal activities, including fraud, and to enforce our terms of use (e.g. determining whether You are eligible for a Free Trial period or for any other offer or marketing campaign as the case may be).

8.WHAT IS THE LEGAL BASIS FOR THE PROCESSING?

8.1.
A majority of the Personal Information that Storytel processes about You are processed because it is necessary for Storytel’s performance of the Terms, i.e. in order for Storytel to be able to provide and administer the Service and its features. Such is the case when Storytel processes, inter alia, Your contact information such as Your e-mail address or Your phone number and information from the payment service provider.
8.2.
Some of the Personal Information which Storytel processes are processed based on a balance of interest, i.e. Storytel’s interest of processing the data outweighs the impact and risk the processing may have on Your integrity. Such is the case when Storytel processes Your data for marketing purposes and when we store Your Storytel audio/e-book library information after your subscription has ended.
8.3.
Additionally, some data is processed based on Your consent. This is the case for the processing of such data that Storytel gets access to via Your Facebook account and for marketing of Storytel’s partners’ goods and services.
8.4.
To the extent that processing is carried out on the basis of a consent, it is voluntarily for You to give such a consent and You may at any time, wholly or partly, withdraw Your consent. If You choose to withdraw Your consent, and Storytel’s processing is such that it requires Your consent, the processing will be carried out in accordance with Your most recently given consent.

9.DATA SECURITY AND INTEGRITY

The security, integrity and confidentiality of Your Personal Information is all important to us. We have implemented technical, administrative and physical security measures that are designed to protect Your Personal Information from unauthorized disclosure, use and modification. From time to time, we review our security procedures in order to assess the need to implement additional measures or to make technical upgrades to existing procedures. Please be aware that, despite our best efforts, few security measures are impenetrable, and we therefore kindly ask that You inform us immediately of any suspicious activities that You notice in the Service.

10.WHO DOES STORYTEL GIVE THE DATA TO?

10.1.
Storytel may disclose Your Personal Information to affiliates, business partners and other third parties in order to fulfil the agreement with You or to fulfil agreements with Storytel’s suppliers and partners.
10.2.
Storytel may also disclose Personal Information to companies that process Personal Information on our behalf, such as our IT system providers, customer service companies and affiliates. If Personal Information is disclosed to such companies that process data on Storytel’s behalf, Storytel enters into data processing agreements with such parties in order to ensure that a high level of security for Your Personal Information is maintained.
10.3.
Personal Information may also be disclosed, if needed, to comply with statutory legal requirements or requirements from authorities or agencies, to safeguard Storytel’s legal interests or to detect, prevent, or pay attention to fraud and other security or technical issues.
10.4.
Your Personal Information may be transferred to or stored in a country outside the India. If Your Personal Information is transferred or stored outside the India, special safety measures will be taken, we will e.g. ensure that such transfer is carried out in accordance with this privacy policy and as permitted by the applicable laws on data protection.
10.5.
We operate globally and may transfer your Personal Information to third parties in locations around the world for the purposes described in this privacy policy. Wherever your Personal Information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your Personal Information.

11.CHILDREN’S PRIVACY

11.1.
Use of the Stoytel’s Website is available only to persons who can form a legally binding contract under the Indian Contract Act, 1872. If you are a minor i.e. under the age of 18 years, you may use the Website only with the involvement of a parent or guardian.
11.2.
However, we recognize the need to provide further privacy protections with respect to Personal Information we may collect from Children on Stoytel’s Website. Some of the features on Stoytel’s Website are age-gated so that they are not available for use by Children, and we do not knowingly collect Personal Information from Children in connection with those features. When we intend to collect Personal Information from Children, we make best endeavors to take additional steps to protect Children’s privacy, including:
i.
Notifying parents about our information practices with regard to Children, including the types of Personal Information we may collect from Children, the uses to which we may put that information, and whether and with whom we may share that information;
ii.
In accordance with applicable law, obtaining consent from parents for the collection of Personal Information from their Children, or for sending information about our products and services directly to their Children;
iii.
Limiting our collection of Personal Information from Children to no more than is reasonably necessary to participate in an online activity;
11.3.
Giving parents access or the ability to request access to Personal Information we have collected from their Children and the ability to request that the Personal Information be changed or deleted.

12.LINKS TO EXTERNAL WEBSITES

Information provided by Storytel may contain links to websites operated or owned by someone other than Storytel. Storytel is not responsible for the processing of Personal Information carried out on these websites. Storytel encourages You to read through the information regarding processing of Personal Information that is available at the respective website.

13.CHANGES TO THE PRIVACY POLICY

This privacy policy may be revised from time to time. If Storytel makes any significant changes to the privacy policy, Storytel will inform You by e-mail or through the Service before the changes take effect. The privacy policy will also be published on Storytel’s Website. If any change requires Your consent, Storytel will obtain a new consent from You.

14.RIGHT TO REQUEST INFORMATION AND CORRECTIONS ETC.

14.1.
You have the right to be given free information about, inter alia, the Personal Information that Storytel processes on You and for what purpose Storytel is processing Your Personal Information (so-called record extract). Any such request for a record extract must be made in writing and be signed by You.
14.2.
You are also entitled to have inaccurate, misleading or incomplete data corrected, anonymized or deleted. You are also entitled to request Storytel to restrict the processing of Your Personal Information and to object to the processing. Furthermore You may exercise Your right to data portability, which means that You have the right to receive the Personal Information processed about You in a structured, commonly used and machine-readable format.
14.3.
Please note that some of the rights above only may be exercised in certain situations, e.g. the right to data portability, which only applies when the processing is carried out on the basis of an agreement or a consent and if the processing is carried out by automated means. In case You have any questions regarding how Storytel processes Your Personal Information, want to exercise any of Your rights or want to know more about the rights, You may contact us as indicated below.

E-mail address: [email protected]

14.4.
If You do not want Storytel to process Your Personal Information for direct marketing, You can give written notice thereof to Storytel. In each newsletter, You will also be informed that You can opt out of receiving further newsletters.
14.5.
You are also entitled to lodge a complaint with a supervisory authority if You consider that Your Personal Information has been processed in contradiction with applicable data protection legislation.

15.Definitions

15.1.
Children. Children means individuals who we have identified are not of legal age to consent to the collection and processing of their Personal Information. In India, the term “children” refers to individuals under 18 years of age.
15.2.
“IP address” An IP address is associated with the access point through which you enter the Internet and is typically controlled by your Internet Service Provider (ISP. We may use IP addresses to collect information regarding the frequency with which our guests visit various parts of our Website, and we may combine IP addresses with Personal Information.
15.3.
“Notice” Notice may be by email to you at the last email address you provided us, by posting notice of such changes on our Website, or by other means, consistent with applicable law.
15.4.
“Parents” Parents mean a natural or legal guardian of the Children.
15.5.
“Personal Information” means and includes any Sensitive Personal Information including but not limited to any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
15.6.
“Public Forums” Our Website may offer message boards, conversation pages, blogs, chat rooms, social community environments, profile pages, and other forums that do not have a restricted audience. If you provide Personal Information when you use any of these features, that Personal Information may be publicly posted and otherwise disclosed without limitation as to its use by us or by a third party. To request removal of your Personal Information from a public forum on our Website, please contact [email protected].
15.7.
“Sensitive Personal data” Sensitive Personal data shall have the meaning ascribed to it under the applicable law and is presently defined to mean such personal data which consists of information relating to (i) passwords; (ii) financial information such as bank accounts or credit card or debit card or other payment instrument details; (iii) physical, physiological and mental health conditions; (iv) sexual orientation; (v) medical records and history; (vi) Biometric information; (vii) any detail relating to the above clauses as provided to body corporate for providing service; and (viii) any of the information received under above clauses by body corporate for processing, stored or processed under lawful contract or otherwise; provided that any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal data.
15.8.
“Website” shall mean www.storytel.in.

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Last reviewed on 1 March 2018
Storytel Sweden AB