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Last updated: 2023-11-24

The information below describes our processing of your personal data. The first section is addressed to you as a user of our health services, the second section is addressed to you as a visitor on our website, for example when you contact us through the website. The third section concerns our application Twitch on Demand.

1. Information on Twitch processing of your personal data as a user of services

Twitch processes your personal data as a user of our services to be able to provide and administer the services. The types of personal data processed by us depends on which service you are using as set out below.

Data Controller and contact information

Twitch Health Capital, reg. no. 556599-8001, is the data controller of the processing of your personal data. If you have questions concerning our processing of personal data, you can contact us by e-mail to info@twitch.se.

Personal data and how it is collected

  • All services: Name, e-mail address, employer, login credentials.
  • Booking service: Booking information regarding i.e. massage or naprapathy.
  • Digital lifestyle survey: Information that you voluntarily provide in the digital lifestyle survey, such as telephone number, address, answers to the health questions regarding i.e. behaviour and perceived health;
  • Health challenges: Type of exercise and other healthy behaviour registered in the health challenge.
  • Physiological tests and blood tests: Personal identity number, level of fitness, waist circumference, body composition, results of blood tests and other information required for proper record keeping.

If personal data has not been provided to Twitch by you, we have received them from your employer. If so, such personal data may consist of name, e-mail address and employer.

What we use your personal data for

Twitch processes your personal data only for the purposes set out below.

Purpose Legal ground
To provide and administer your user account and the health challenges you choose to participate in. Necessary for our performance of the contract with you (i.e.provide the services requested by you).
To provide and administer the digital lifestyle survey you ordered. Necessary for our performance of the contract with you (i.e.provide the services requested by you).The digital lifestyle survey may entail that we process special categories of personal data concerning health. Such processing is based on your explicit consent. Without your consent, we will not process your health information.
To provide and administer physiological tests and blood tests. Necessary for the purposes of provision of health care and to fulfil legal obligations such as the Swedish Patient Data Act to which Twitch is subject.
To provide and administer bookings regarding i.e., massage or naprapathy. Necessary for our performance of the contract with you (i.e.provide the services requested by you).
To administer and answer questions to our service desk/support. Necessary for our legitimate interest to provide support and ensure your communication with us.
To perform marketing analyses, system tests, business, and method development. Necessary for our legitimate interest to ensure that the services and our systems are meeting your and our needs over time.
To perform direct marketing and provide offers from Twitch. Necessary for our legitimate interest to inform about our business and/or new services. You can always unsubscribe from direct marketing and offers from us, see below under your rights.

Who we share your personal data with

To fulfill the purposes described above, we may need to share your personal data with our suppliers when they perform services to us, for example suppliers of support and maintenance of our IT systems. Twitch remains responsible for the processing of your personal data performed by our suppliers on our behalf and such suppliers may not use the personal data for purposes other than those specified by us.

When we share your personal data as described above, the personal data may be transferred to suppliers both within and outside of EU/EEA. Any transfer of data outside the EU/EEA is made in line with data protection laws. If processing is performed outside of EU/EEA, it is based on that the EU Commission has decided that the receiving country ensures an adequate level of protection or other adequate safeguards in the form of the EU Commission’s standard contractual clauses.

In the booking service, we will share your bookings with the party with whom your time is booked. If required, we may also provide information about bookings and certain personal data to a third party in order to fulfil requirements in service agreements. If we share your personal data with such a party, the party is the data controller of its processing of your personal data after receipt from us. The sharing is made for purposes such as enabling invoicing or salary deductions from your employer.

Storage periods

We will process your persona data during the term of the agreement with your employer regarding our services. We will thereafter delete your personal data within 12 months unless laws or regulations obliges us to continue the processing. For example, patient records must be kept for 10 years.

In certain cases, where your personal data is no longer necessary for the purposes for which it was collected, it will be deleted earlier, for example after a completed health challenge. If your employment with the employer who has the agreement regarding the services with Twich is terminated, or if you want to cease using our services for other reasons, notify us on the e-mail address under contact information above and let us know that your personal data should be deleted.

Third party apps

Please note that this information only applies to processing of personal data for which Twitch is the data controller. We may recommend certain third-party apps to you, for example in conjunction with the outcome of your digital lifestyle survey. Such apps are not controlled by us, and we are not responsible for any processing of your personal data performed by the third party. We recommend that you control the relevant third party’s privacy policy for further information.

Your rights

You are entitled to the following rights under applicable data protections laws:

  • The right to access: You are entitled to receive certain information on our processing of your personal data. Such information is provided in this information document. Further, you have the right to receive a copy of the personal data we process relating to you. Upon request, we will provide a copy of your personal data in a commonly used electronic form.
  • The right to rectification: You are entitled to obtain rectification of inaccurate personal data and to have incomplete personal data completed.
  • The right to erasure (“right to be forgotten”): You may under certain circumstances request us to delete your personal data. Please note that this right is not unconditional. Therefore, an attempt to invoke the right might not lead to an action from us.
  • The right to restriction of processing: You may under certain circumstances request from us to restrict the processing of your personal data. Please note that this right is not unconditional. Therefore, an attempt to invoke the right might not lead to an action from us.
  • The right to data portability: You are entitled to receive your personal data (or have your personal data directly transmitted to another data controller) in a structured, commonly used and machine-readable format.
  • The right to object: You are entitled to object to certain processing activities conducted by the us in relation to your personal data, such as our processing of your personal data based on our legitimate interest. The right to object also applies to processing of your personal data for direct marketing purposes.

If you have questions concerning our processing of your personal data, or want to invoke your rights, contact us at info@twitch.se. You also have the right to lodge a complaint with Datainspektionen, the supervisory authority in Sweden.

2. Information on Twitch processing of your personal data as a visitor on our website

When you visit and use services provided at twitchhealth.se, Twitch will process your personal data. Below you will find information on how and why we process your personal data and your rights in connection with our processing.Twitch Health Capital AB, reg. no. 556599-8001, is the data controller of the processing of your personal data.Twitch is not responsible for your integrity or the content on external websites, to which we may provide links on our website.

What personal data to we process?

We process personal data when (i) you sign up for our subscription service for newsletters, (ii) you apply for a job with us through the website, (iii) you ask for contact with us/ask questions in a contact form (iv) we invite you to events and meetings, or (v) you are the contact person at a Twitch customer or supplier. Such personal data will include the personal data you provide when using the services, such as name, e-mail address, telephone number and other information you voluntarily provide to us (such as information in a CV if you are applying for a job).

Why do we process your personal data?

Twitch processes your personal data only for the purposes set out below. For how long we are processing your personal data for the respective purpose is set out in the column to the right.

Purpose Legal ground Storage period
News letters. Administer and provide the subscription service regarding newsletters. The processing is necessary for our performance of the contract with you, i.e. provide the news letters according to your request. If you unsubscribe from our marketing, we will no longer process your personal data for this purpose. You can unsubscribe in each e-mail we send to you. We will also erase your personal data, unless there is another legal ground for keeping your data (for example for the purposes required if you are a user of our health services).
Job applicants. Evaluate your application and contact you upon interesting job opportunities with us. The processing is necessary for our performance of the contract with you, i.e. evaluate your application according to your request. We will delete your personal data 24 months after receiving your application.
Contact forms. Contact you and answer your questions/information requests. The processing is necessary for our and your legitimate interest to ensure that we can contact you in accordance with your request. We will delete your data after having contacted you and finalizing the administration of your request.
Events and meetings. Contact you and invite you to relevant events. The processing is necessary for our legitimate interest to arrange events and meetings and invite relevant people. If you unsubscribe from our invitations, we will no longer process your personal data for this purpose. You can unsubscribe in each e-mail we send to you. We will also erase your personal data, unless there is another legal ground for keeping your data (for example for the purposes required if you are a user of our health services).
Contact persons. Administer and perform the cooperation and the agreement with the customer or supplier. The processing is necessary for our legitimate interest to perform our agreement with the customer or the supplier. We will delete your personal data when the cooperation with the customer or the supplier is terminated.If we become aware that the information is no longer relevant for the purpose, or at your request, the processing will cease earlier.

Who do we share your personal data with?

To fulfill the purposes described above, we may need to share your personal data with our suppliers when they perform services to us, for example suppliers of support and maintenance of our IT systems. Twitch remains responsible for the processing of your personal data performed by our suppliers on our behalf and suppliers may not use the personal data for purposes other than those specified by us. When we share your personal data as described above, the personal data may be transferred outside of EU/EEA. Any transfer of data outside the EU/EEA is made in line with data protection laws. If processing is performed outside of EU/EEA, it is based on that the EU Commission has decided that the receiving country ensures an adequate level of protection or other adequate safeguards in the form of the EU Commission’s standard contractual clauses.

Your rights

You are entitled to the following rights under applicable data protections laws:

  • The right to access: You are entitled to receive certain information on our processing of your personal data. Such information is provided in this information document. Further, you have the right to receive a copy of the personal data we process relating to you. Upon request, we will provide a copy of your personal data in a commonly used electronic form.
  • The right to rectification: You are entitled to obtain rectification of inaccurate personal data and to have incomplete personal data completed.
  • The right to erasure (“right to be forgotten”): You may under certain circumstances request us to delete your personal data. Please note that this right is not unconditional. Therefore, an attempt to invoke the right might not lead to an action from us.
  • The right to restriction of processing: You may under certain circumstances request from us to restrict the processing of your personal data. Please note that this right is not unconditional. Therefore, an attempt to invoke the right might not lead to an action from us.
  • The right to data portability: You are entitled to receive your personal data (or have your personal data directly transmitted to another data controller) in a structured, commonly used and machine-readable format.
  • The right to object: You are entitled to object to certain processing activities conducted by the us in relation to your personal data, such as our processing of your personal data based on our legitimate interest. The right to object also applies to processing of your personal data for direct marketing purposes.

If you have questions concerning our processing of your personal data, or want to invoke your rights, contact us at info@twitch.se. You also have the right to lodge a complaint with Datainspektionen, the supervisory authority in Sweden.

3. Information on Twitch processing of your personal data in Twitch on Demand

The information below describes our processing of your personal data when you use our app Twitch on Demand.

Data controller and contact information

Twitch Health Capital, reg. no. 556599-8001, is the data controller of the processing of your personal data. If you have questions concerning our processing of personal data, you can contact us by e-mail to info@twitch.se.

Personal data and how it is collected

When you use our services through Twitch on Demand, we collect and process the personal data you provide when you create an account, such as your name, e-mail address, phone number, birth date, gender and login credentials. You may also choose to provide information on your height, weight and other body measures.

When you use the services in Twitch on Demand, we will process information on the training activities you have performed, your heart rate, walking and running distance and other information generated by your recorded or logged activities. If you choose to activate GPS outdoor tracking, we will also process location data.

If you choose to connect third party application(s) to the services (e.g. Apple Health or Garmin), we will collect and process the personal data from such third party application that you choose to synchronize with the services in Twitch on Demand.

Purposes and legal grounds for our processing

To provide and administer your user account and your requested services

When you use Twitch on Demand, we will process your personal data to deliver the services you request and use. The information on training activities may include information that you added regarding the activities or information that have been generated during your performance of the activity, for example location data or movement data. The processing is necessary for our performance of the contract with you (i.e. provide the services requested by you). The services may entail that we process special categories of personal data concerning health. Such processing is based on your explicit consent, which you are asked to provide in your account. Without your consent, we will not process health information.

To administer and answer questions to our service desk/support

If you request support or ask questions through our support channels, we will process your personal data to be able to assist you with the relevant matter. The processing is necessary for our legitimate interest to provide support and ensure your communication with us.

To perform, improve and maintain Twitch on Demand and our services

We may use information on how you use our services to improve your user experience and to help us diagnose technical problems and administrate Twitch on Demand. The processing is necessary for our legitimate interest to ensure that the services and our systems are meeting your and our needs over time.

To provide information, perform direct marketing and provide offers from Twitch

We may provide news relating to our services and marketing information to you. The processing is necessary for our legitimate interest to inform about our business, the services and/or new services. You can always unsubscribe from direct marketing and offers from us, see below under your rights.

Who we share your personal data with?

To fulfill the purposes described above, we may need to share your personal data with our suppliers when they perform services to us, for example the supplier of the application used for Twitch on Demand. Twitch remains responsible for the processing of your personal data performed by our suppliers on our behalf and such suppliers may not use the personal data for purposes other than those specified by us.

When we share your personal data as described above, the personal data may be transferred to suppliers both within and outside of EU/EEA. Any transfer of data outside the EU/EEA is made in line with data protection laws. If processing is performed outside of EU/EEA, it is based on that the EU Commission has decided that the receiving country ensures an adequate level of protection or other adequate safeguards in the form of the EU Commission’s standard contractual clauses.

Storage periods

We will process your personal data for as long as required for the purposes described above. Generally, that means that we will process your personal data during the time you have an account for Twitch on Demand. We will thereafter delete your personal data unless laws or regulations obliges us to continue the processing.

You can delete or change your personal yourself when logged in to your account. For example, you can delete information relating to recorded training activities and delete or change information regarding your user information in the account.

Your rights

You are entitled to the following rights under applicable data protections laws:

  • The right to access: You are entitled to receive certain information on our processing of your personal data. Such information is provided in this information document. Further, you have the right to receive a copy of the personal data we process relating to you. Upon request, we will provide a copy of your personal data in a commonly used electronic form.
  • The right to rectification: You are entitled to obtain rectification of inaccurate personal data and to have incomplete personal data completed.
  • The right to erasure (“right to be forgotten”): You may under certain circumstances request us to delete your personal data. Please note that this right is not unconditional. Therefore, an attempt to invoke the right might not lead to an action from us.
  • The right to restriction of processing: You may under certain circumstances request from us to restrict the processing of your personal data. Please note that this right is not unconditional. Therefore, an attempt to invoke the right might not lead to an action from us.
  • The right to data portability: You are entitled to receive your personal data (or have your personal data directly transmitted to another data controller) in a structured, commonly used and machine-readable format.
  • The right to object: You are entitled to object to certain processing activities conducted by the us in relation to your personal data, such as our processing of your personal data based on our legitimate interest. The right to object also applies to processing of your personal data for direct marketing purposes.

If you have questions concerning our processing of your personal data, or want to invoke your rights, contact us at info@twitch.se. You also have the right to lodge a complaint with Datainspektionen (soon to be named “Integritetsskyddsmyndigheten”), the supervisory authority in Sweden.

Terms of service Twitch on Demand

Please read these terms of use (the "Terms") carefully before downloading, accessing, or using Twitch on Demand, Twitch’s digital services for providing i.e. workouts and training programs, courses and health challenges (the "Services") The Terms apply between you, the user, and Twitch Health Capital AB, reg.no. 556599-8001 ("Twitch").

By downloading the Twitch on Demand app and accessing and/or using the Services, you accept the Terms. If you do not accept the Terms, do not download, access, or use the Services.

General on your use of the services

All information presented by Twitch in the Services is provided for personal workout purposes only and is not intended to replace or substitute any expert medical opinion of your doctor, physical trainer, coach, or health professional. If appropriate, you should consult with a doctor or health professional before starting any workout program.

User account

You are responsible for any use of the Services through your account and for selecting secure log-in credentials and taking all necessary precautions to keep such credentials secret and secure.

You may not (i) register false information in applying for or amending your access to the Services, (ii) use information of a third party without proper authorization, or (iii) allow another person or a third party to use your account or access the Services. If you find that your log-in credentials are compromised or used by a third party, you must immediately restore the credentials and notify us thereof.

Intellectual property rights

Subject to the terms and conditions of the Terms, Twitch grants you a personal, fully revocable, non-exclusive, non-transferable, limited right to use the Services strictly for your own personal purposes.

You acknowledge that Twitch and/or its licensors owns the Services (including the Twitch on Demand app) and all intellectual property rights in or to the Services and any and all methods, techniques, tools or processes used in creating, developing, applying or maintaining the Services. Twitch hereby reserves all rights not expressly granted herein. No rights shall be licensed by implication under the Terms.

You shall not, and you shall not permit others to, without Twitch’s prior written consent (i) duplicate, alter, modify, create derivative works from, distribute, publicly display, publicly perform, or sublicense the Services; (ii) access or use the Services or Twitch’s confidential information to create a product or service similar to or competitive with the Services; (iii) time-share the Twitch on Demand app or the Services or use it in a service bureau arrangement or for the benefit of any third party; (iv) permit or allow any person to remove any proprietary or other legend or restrictive notice on the Service or containing media; (v) permit any person to reproduce any such media or the Services; (vi) use the Services for any illegal activity; (vii) use the Services to disrupt or interfere with any other networks, websites, or security; (viii) use the Services to distribute any libelous, harassing, defamatory, violent, illegal, vulgar, offensive, slanderous, or otherwise objectionable material of any kind; or (ix) in any manner or under any circumstances use, copy, modify, enhance, merge, reverse engineer, reverse assemble, decompile, disassemble or in any way alter the Services or any copy, adaptation, transcription, or merged portion thereof.

Availability and modifications to the services

We will use commercially reasonable efforts to ensure the Services’ availability. We will not be liable for: (a) scheduled downtime; or (b) any unavailability caused directly or indirectly by circumstances beyond our reasonable control, including without limitation, (i) force majeure events; (ii) Internet service provider or public telecommunications network failures or delays, or denial of service attacks; (iii) a fault or failure of your computer systems or networks; or (iv) any breach by you of the Terms.

Twitch reserves the right to modify, update, suspend or discontinue, temporarily or permanently, the Services, including change of functionality in the Services, or any service to which it connects, with or without notice and without liability to you.

Costs for the services

There is no cost related to your download of the Twitch on Demand app. For the use of the Services, certain content is free of charge and for certain content, you will have to pay a fee to use the Services. If you sign up for a subscription of the Services, your subscription fee will include access to all Services in the Twitch on Demand app.

Twitch reserves the right, at its discretion, to amend the fees for the Services. However, if you have an active subscription, the subscription fee will not change during the current subscription period.

Termination and suspension

The Terms shall remain in force until terminated by you or Twitch. You may also stop using and accessing the Services at any time, in which case the Terms will be terminated.

If you have paid for a subscription of the Services, you will not get a refund of the subscription fee upon termination.

In the event that you are in breach with any provision of the Terms, Twitch may suspend your access to the Services permanently or temporarily and/or immediately terminate the Terms, without prior notice from Twitch.

Limitation of liability

Twitch will not be liable for indirect, special, incidental, or consequential damages including loss of profit, revenues, goodwill or loss resulting from business interruption or loss of data arising in connection with the Terms or the usage of the Services.

Nothing in these Terms shall operate to exclude or restrict either party’s liability for any damage caused by wilful misconduct or gross negligence.

Twitch’s aggregate liability under the Terms will not exceed the aggregate fees actually paid by you to us under the Terms during the twelve (12) months period immediately preceding the date upon which the applicable cause of action arose.

Disclaimer of warranty

Twitch makes no representations or warranties of any kind, whether express or implied or otherwise regarding the use, the inability to use or operate, or the results of the use of the Services and disclaim all warranties, including (a) of satisfactory quality, fitness for a particular purpose, non-infringement, or (b) that the Services will be uninterrupted or error free, or (c) that content will be secure or not otherwise lost or damaged. Twitch does not make any representations regarding the benefits or results that you shall obtain from the Services.

Personal data

For the purpose of providing, you with the Services, it is necessary for Twitch to process your personal data. For more information regarding Twitch’s processing of your personal data, please see the privacy notice provided to you when you register or accept your account (which may also be found here).

Severability

If any provision of the Terms is held to be unenforceable or invalid, such provision will be changed and interpreted to accomplish the objectives of such provision to the greatest extent possible under applicable law and the remaining provisions will continue in full force and effect.

Amendments to the terms

Twitch reserves the right, at its sole discretion, to modify or replace the Terms at any time. If a revision is material, we will provide at least 30 days' notice prior to any new terms taking effect. What constitutes a material change will be determined at our sole discretion. Your continued use of the Services after such changes to the Terms will constitute your consent to the revised terms.

Governing law and disputes

The Terms shall be governed by and construed in accordance with the substantive laws of Sweden.

Any dispute, controversy or claim arising out of or in connection with the Terms, or the breach, termination, or invalidity thereof, shall be finally settled in the general courts of Sweden, with the District Court of Stockholm as the court of first instance. Notwithstanding the aforesaid, disputes shall be settled by the Stockholm Chamber of Commerce, should there be an on-going parallel dispute regarding the same subject-matter or incident before the Stockholm Chamber of Commerce.

Contact information

If you have any questions regarding the Terms, please feel free to contact us:

Twitch Health Capital AB
Surbrunnsgatan 10
114 27 Stockholm
Sverige
info@twitch.se