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Version: 1.3Published: 22 September, 2022

PRIVACY POLICY

1. IN GENERAL

Speedy is part of the Paf Group and aims to offer customers a safe, socially responsible and personalised gaming service for fun and entertainment. In order to provide the gaming service www.speedyspel.se and related products and services (hereinafter referred to as the "Gaming Service"), Speedy needs to process your personal data. At Speedy, we are committed to  protect your privacy and undertake to protect your personal data when you use and visit the Gaming Service.

This Privacy Policy applies when you use the Gaming Service as a gaming customer at Speedy in accordance with Speedy’s terms of use (hereinafter referred to as the "Agreement") and/or when you visit the Gaming Service and this Privacy Policy applies to the entire Gaming Service. Speedy offers you the opportunity to, to a certain extent, control Speedys collection, use and dissemination of your personal data as described in this Privacy Policy, Cookie policy and through the settings in your gaming account.

It is important that you familiarise yourself with and read through this Privacy Policy and that you have confidence in Speedys processing of your personal data. Please feel free to contact us with any questions.

Speedy complies with applicable laws and regulations on data protection, including the Data Protection Regulation, (EU) 2016/769.

1.1 Data Controller

Speedy (Speedy Originals Ltd.) is the data controller and is responsible for all personal data collected by Speedy and for the processing of that personal data. Within the Paf Group, we have also appointed a data protection officer.

Speedy Originals Ltd
(Org. No. C 96612)

Address:
Quantum Place, Level 3, Triq Ix-Xatt, Ta’Xbiex, Gzira GZR 1052, Malta

Data Protection Officer

Address:
Lövdalsvägen 8, PB 241 AX-,22101 Mariehamn,Åland, Finland

2. CHANGES

The Gaming Service provided by Speedy is constantly evolving, and applicable data protection laws may change, which means that Speedy may need to update or change this Privacy Policy from time to time without any special notice. Significant changes will however be informed via Inbox messages or by email. Therefore it is important that you read through this Privacy Policy each time you visit the Gaming Service. The date when the most recent changes have been made is stated at the top of this Privacy Policy.

3. CHILDREN

In order to fulfill legal age requirements and for responsible gaming reasons, Speedy applies a strict age limit for using the Gaming service. Persons under the age of 18 may not, therefore, submit any personal data to Speedy.

4. DATA COLLECTED BY SPEEDY

4.1 Data you provide to Speedy

4.1.1 Registration

Speedy collects the personal data that you provide to Speedy in connection with your registration of a gaming account. In order to participate in online gaming, you must have a registered gaming account on the Gaming Service. When you register a gaming account, you will need to enter information such as your name, personal identity number, email address and country of residence.

4.1.2 Administration of the Gaming Service

Speedy also collects personal data that you provide to Speedy in connection with administration of the Gaming Service, including for the purpose of administering payments to your bank account, e-wallet or other registered payment method you have with Speedy. Speedy may also request that you verify your identity.

You may also provide data to Speedy when you contact Speedy or participate in Speedy’s activities or otherwise provide data to Speedy.

4.2 Data that Speedy collects from other sources

In addition to the data you provide to Speedy, Speedy may collect and/or update personal data through third parties, for example from various authorities and public records.

Data that Speedy collects from third parties comprises:

  1. Identification data such as name, personal identity number and address details from public records to ensure that Speedy has accurate data about you.

  2. Information from spelpaus.se – a natural person who is registered in this national self-exclusion register cannot register as a Gaming Customer with Speedy.

  3. Income information from the Swedish Tax Agency, partly to fulfill Speedy's obligations in accordance with the Act on Preventing Money Laundering and the Financing of Terrorism (2017: 630), and partly to enable Speedy to detect and take action in the event of any gambling problems.

  4. Data from gaming providers who provide Speedy with games on the Gaming Service that indicate whether cheating, fraud or other violations have occurred in breach of the Agreement, the gaming rules or applicable laws. Speedy also collects data generated by you from playing the games provided by the gaming provider which includes segmented data as well as profiled data.

  5. Data that Speedy must examine by law, for example, if you are a person in a politically exposed position under the Act on Preventing Money Laundering and Terrorist Financing. Speedy uses subcontractors to examine such data.

  6. Speedy uses subcontractors that offer solutions for the detection and prevention of fraud, other offences and improper conduct against Speedy and/or you as a gaming customer. These business services involve the examination of devices connected to the internet in order to evaluate the risk level of fraud and whether there is a history of fraudulent conduct so that Speedy can protect its business from persons who wish to commit crimes against Speedy or you as a gaming customer.

4.2.1 Use of the gaming service

Speedy also collects data generated through your use of the Gaming Service, including transactions to and from your gaming account. This means that Speedy stores and processes data on how you use the Gaming Service, for example the games you play, the tools you use, Speedy events in which you have participated, transfer of gaming funds between your external payment providers and Speedy’s bank accounts, and correspondence between you and Speedy.

5. OBJECTIVES OF SPEEDY'S PROCESSING OF PERSONAL DATA

Speedy's objectives are described below, that is, the purpose of processing your personal data and the legal basis for such processing.


Purpose:
Registration of gaming account

Justification of the necessity of processing:
Processing is necessary for you to be able to open a gaming account with Speedy. All online gaming requires that you as a gaming customer register a gaming account at the Gaming Service.

Legal basis:
Performance of contract - Collection and processing of personal data is necessary for Speedy to fulfil its obligations under the Agreement between you and Speedy and for you and Speedy to enter into the Agreement.

Performance of legal obligations - Processing is necessary to fulfil one or more legal obligations pertaining to Speedy.


Purpose:
Administration of the Gaming Service and your data

Justification of the necessity of processing:
Processing is necessary for the administration of the Gaming Service, including the transfer of gaming funds between your account, accounts of external payment providers and Speedy’s bank accounts, management of customer funds and administration of your data.

Administration of the Gaming Service is also necessary to maintain the customer relationship between you and Speedy.

Legal basis:
Performance of contract - Collection and processing is necessary for Speedy to fulfil its obligations under the Agreement between you and Speedy.


Purpose:
Delivery of a customised and personalised Gaming Service

Justification of the necessity of processing:
Processing is necessary for the creation of custom content on the Gaming Service by providing you as a gaming customer, with relevant game recommendations, presentation of specific offers and other similar actions.

Legal basis:
Performance of contract - Collection and processing is necessary for Speedy to fulfil its obligations under the Agreement between you and Speedy.


Purpose:
Supply and provision of fast and qualitative customer service

Justification of the necessity of processing:
Speedy offers customer service by phone, email and chat. Speedy uses the information you provide to investigate, respond to and resolve complaints and issues with the Gaming Service, for example bugs or winner payouts.

Speedy also records conversations and monitors keystrokes in real time in chat communication with customers in order to quality assure Speedy’s customer service, provide faster customer service and for training purposes, so as to improve and develop Speedy’s customer service.

Legal basis:
Performance of contract - Collection and processing is necessary for Speedy to fulfil its obligations under the Agreement between you and Speedy.

In the event that a person that is not a customer contacts Speedy customer service, processing is based on legitimate interest. Processing is necessary to meet both Speedy’s and your interests in the management of your issue.


Purpose:
Deliver and provide chat services in connection with certain games

Justification of the necessity of processing:
Processing is necessary for the provision to you of chat features, to enable you to contact Speedy and other players in connection with certain games.

Processing is also necessary to ensure that the content and your behaviour in the chat feature are appropriate, which means that the content may not be offensive, discriminatory or encourage crime.

Legal basis:
Performance of contract - Processing is necessary for Speedy to fulfil its obligations under the Agreement between you and Speedy.


Purpose:
Prevention of abuse of the Gaming Service and prevention, preclusion and investigation of violations against Speedy and/or you

Justification of the necessity of processing:
Processing is necessary for prevention and investigation of any fraud or other offences.

Processing is also necessary for the prevention and investigation of harassment, attempts to unlawfully log in to your gaming account or any other actions prohibited by law or by the Agreement between you and Speedy, as well as Speedy’s or the gaming provider’s gaming rules.

Furthermore, processing is necessary to provide a safe and secure Gaming Service, improve and develop Speedy’s IT environment, and to protect you and your gaming account from attacks and intrusion.

Legal basis:
Performance of contract - Processing is necessary for Speedy and you, as a gaming customer, to fulfil your obligations under the Agreement between you and Speedy.

In cases where processing is not necessary to fulfil the Agreement between you and Speedy, processing is based on a legitimate interest in protecting, preventing and precluding abuse of the Gaming Service and preventing and investigating any offence against Speedy or you as a gaming customer.


Purpose:
Responsible gaming

  • Provide socially responsible Gaming Service

  • Counter, prevent and preclude problem gambling

  • Offer customers tools and services that help customers make informed decisions about their gambling

Justification of the necessity of processing:
Speedy processes your personal data when you as a customer use:

  • Speedy’s tools and services to make informed decisions about your gambling, such as deposit limits, freezing of the gaming account or receiving reminders about how long you’ve been playing.

  • Speedy’s questionnaire and/or self-test to get information about your gaming habits.

Speedy also processes your data that has been generated by your use of the Gaming Service, including the profiling of your gaming behaviour to detect, counteract and prevent problem gambling.

Speedy also processes your personal data to verify that you are not registered in a self exclusion registry and to accommodate your request in the event you wish to be suspended from the Gaming Service.

Speedy reserves the right to suspend you from the Gaming Service if your gaming pattern strongly indicates that you may have problems with your gambling and may not take control of your gambling yourself or do not take the steps recommended by Speedy.

Speedy has implemented a mandatory loss limit which applies to all gaming customers. The processing is based on an automated process which means that once the Gaming Customer has reached the yearly (a calendar year) mandatory loss limit, the Gaming Customer cannot make any further bets until the beginning of the next calendar year or until a win changes the loss. Here is more information about Paf’s loss limits.

If you choose to use Speedy’s gaming insurance, Speedy will process your personal data to investigate whether you are entitled to the insurance and to provide the insurance to you.

Speedy also processes anonymous data in order to contribute to research in the field of gaming responsibility.

Legal basis:
Performance of legal obligations - Processing is necessary to fulfil one or more legal obligations pertaining to Speedy.

Consent - In the event that you as a gaming customer choose to use Speedy’s gaming insurance or to take Speedy’s survey or self-test, Speedy needs your consent to provide these services.

In cases where there is no legal obligation or consent, processing is based on a compelling legitimate interest of Speedy being a gaming company that takes responsible gaming seriously, preventing and protecting you from unhealthy gaming habits and problem gambling.


Purpose:
Administration of events and other occasions, promotions, competitions and tournaments including travel and prize givings

Justification of the necessity of processing:
You have the opportunity to participate in Speedy’s promotions, competitions, tournaments and events and other arrangements organised by Speedy. In order for you to participate in these arrangements, it is necessary to process your personal data to administer your participation.

Note that you as a Gaming Customer are only entitled to participate in one (1) welcome bonus.

Processing is also necessary if you participate in any of Speedy’s trips as well as processing of your friend’s personal data if you choose to bring a friend on the trip. As a participant, you can invite a friend to most trips and other events organised by Speedy.

Legal basis:
Performance of contract – Processing is necessary for Speedy to fulfil its obligations under the terms of the competition or the promotion.

Consent – In cases where the performance of an agreement cannot be applied and Speedy processes your friend’s personal data to administer the trip or some other event in which your friend is participating, Speedy needs your friend’s consent to process the personal data.


Purpose:
Marketing of the Gaming Service and Speedy events

Justification of the necessity of processing:
Speedy processes personal data to promote its products, services and promotions, including events.

Speedy also processes personal data through profiling in order to suggest customised offers and marketing to you as a gaming customer. You can at any time choose not to receive personal offers generated through profiling by declining personal offers and marketing on your gaming account.

As a gaming customer you can also choose not to receive direct marketing, or only receive direct marketing through certain communication channels through the settings in your gaming account.

If you are registered on spelpaus.se, Speedy processes your information to ensure that you do not receive any direct marketing.

Legal basis:
Legitimate interest - Processing is based on a legitimate interest in marketing Speedy and the Gaming Service, including various events organised by, or sponsored by Speedy.


Purpose:
Communications

Justification of the necessity of processing:
Speedy communicates with you through various communication channels, for example, via email, mobile phone, Gaming Service notifications, messages to your inbox at the Gaming Service and other similar ways. Messages from Speedy may contain news about Speedy, availability and security of the Gaming Service, reminders and marketing announcements from Speedy and Speedy’s business partners. You can change your communication settings on your gaming account at any time. Please note that you cannot opt out of Speedy service announcements, which includes customer information, security and legal notices.

Speedy also gives you the opportunity to communicate with others in connection with some games, please see "Deliver and provide chat services in connection with certain games".

Legal basis:
Performance of contract - Some communications are necessary for Speedy to fulfil its obligations under the Agreement between you and Speedy, such as providing information on security and legal matters.

Legitimate interest - Some communications are based on a legitimate interest in being able to send information about Speedy and marketing about Speedy’s services and products.


Purpose:
Develop the Gaming Service and conduct surveys as well as perform business analysis and statistical calculations

Justification of the necessity of processing:
Processing is necessary to develop and improve the Gaming Service and to make the Gaming Service user-friendly for you.

Speedy analyses usage patterns of the Gaming Service, among other things, in order to be able to take improvement and development measures.

Legal basis:
Legitimate interest - Processing is based on a legitimate interest in improving and developing the business, including the Gaming Service, and the interest in offering a user-friendly Gaming Service to Speedy’s customers.


Purpose:
Performance of legal obligations pertaining to Speedy

Justification of the necessity of processing:
Processing is necessary to fulfil Speedy’s legal obligations under legal requirements, court judgements or official decisions. Speedy has a duty to comply with applicable laws, for example laws regarding the provision of games, the prevention of money laundering and financing of terrorism, accounting and applicable license terms.

Legal basis:
Performance of legal obligations - Processing is necessary to fulfil one or more legal obligations pertaining to Speedy.


5.1 Processing for other purposes

The main rule is that your personal data is only processed for the specified purposes for which your personal data was collected. However, your personal data may be processed for other purposes provided that these purposes are consistent with the original purposes for which your personal data was originally collected. For example, Speedy may process your personal data for other purposes due to legal reasons.

6. DURATION OF THE DATA STORAGE

Speedy does not store your data for longer than is necessary for the specified purposes. In general, Speedy stores your personal data until three years after the customer relationship has ended, to provide you with support if needed and for business continuity in case you return to Speedy as a customer, as well as for your right to have any remaining gaming funds in your gaming account paid into your bank account, e-wallet or other payment method that you have registered with Speedy. Note that legal requirements or official decisions may extend this timeframe. Thereafter, the data is deleted or anonymised so that it can no longer be linked to you as a person. However, you may request that Speedy anonymise your personal information earlier, provided that the customer relationship has ended and that Speedy does not need the personal data to fulfil its legal obligations pursuant to law.

Speedy may store your personal data for less than three years after the customer relationship has ended. For example, Speedy stores your personal data in cases where you have attended any events or other arrangements, promotions, competitions or tournaments, including travel and prize-givings, until they have been completed and follow-up of the current event has been completed.

Specifically with regard to recorded customer conversations, Speedy stores these recorded calls for 90 days.

In the event that you do not wish to receive Speedy marketing, Speedy will discontinue the processing of your personal data for that specific purpose. Note, however, that Speedy will process your personal data in order to ensure that you won't receive any marketing. The same also applies to cases in which you withdraw your consent.

Chat services associated with certain games are provided by Speedy’s gaming providers and Speedy does not have access to the logs that the gaming provider saves. Speedy will only be notified if you as a gaming customer have acted improperly and do not comply with the terms set out in the chat service agreement. Therefore, Speedy only stores data relating to breaches of the terms of the chat service.

Speedy may store some of your personal data for more than three years after the customer relationship has ended, in order to fulfil its legal, regulatory, and/or licence terms. For example, Speedy has an obligation to retain some of your personal data for six years from the end of the year in which the accounting period has ended according to the Accounting Act (1997/1336) and between five to ten years from the termination of the customer relationship in accordance with the Act on Preventing Money Laundering and the Financing of Terrorism (2017: 630). Speedy then only processes the parts of your personal data that are required for these specific purposes.

Speedy may also process your personal data more than three years after the customer relationship has ended if the personal data is included in an ongoing legal process.

7. AUTOMATED DECISIONS FOR INDIVIDUAL PLAYERS

In order to fulfill the relevant legal requirements, Speedy verifies parts of your personal details and makes automated decisions based on those verifications. That includes decisions regarding your rights to use Speedy’s Gaming Service.

Speedy also applies automated decisions in regards to responsible gaming, including blocking customers from depositing further funds into their gaming account when they have reached the yearly loss limit. Automated decisions are also applied when limiting or locking customers’ gaming accounts. The aim of these decisions is to prevent, counteract and prohibit problem gambling, identify gambling problems and make customers aware of their gaming behaviour.

Speedy may also terminate a customer relationship or lock a gaming account based on a customer’s inactivity and the likelihood that the customer in question is not using the Gaming Service.

8. SHARING AND TRANSFER OF PERSONAL DATA

8.1 Disclosing of personal data

Speedy processes your personal data in the strictest confidence and only discloses your personal data to third parties in accordance with this Privacy Policy and to persons authorised to process personal data, who have undertaken to observe confidentiality or are subject to appropriate statutory confidentiality. Otherwise, Speedy will only share your personal data with a third party if you have given consent to such notification.

Speedy may disclose your personal data in cases where Speedy is required to do so by law, regulation or as a result of a request from an authority (police, tax office or other authorities) to disclose the data. Speedy may also disclose your data in cases where Speedy suspects that a crime has been committed.

8.2 Data processors

In order to provide parts of the Gaming Service, Speedy uses so-called data processors, companies that process personal data on Speedy’s behalf in accordance with Speedy’s instructions. Speedy uses the following categories of data processors:

  1. Game providers to be able to provide a varied range of games.

  2. IT companies that provide IT solutions for necessary operation, technical support and maintenance of the Gaming Service and Speedy’s other activities. This includes services such as IT infrastructure, backup, logging, monitoring, relationship management and profiling, communication, service enhancement, including profiling, personalisation and business analytics.

  3. Companies that provide payment solutions such as card payment companies, banks and other payment service providers.

  4. Companies that provide services to counteract and detect fraud, other crimes and/or other improper conduct.

  5. Companies that run marketing such as media and advertising agencies and affiliates.

The sharing of personal data to data processors takes place only for purposes that are consistent with the purposes for which Speedy has collected personal data, for example in order to fulfil Speedy’s commitment under the Agreement.

Speedy controls and ensures that each personal data processor provides sufficient guarantees regarding the security, protection and confidentiality of personal data. Speedy has written agreements with all data processors that regulate the undertakings of the data processors where they, inter alia, undertake to comply with Speedy’s written instructions, security requirements and the restrictions and requirements that apply to the transfer of personal data.

8.3 Within the Paf Group

For the purposes described in this Privacy Policy and the Agreement, your personal data may be transferred and processed within the Paf Group, located within the EU. The sharing of your personal data within the Group is primarily for managing your personal data and for handling various matters related to the Gaming Service. 

Sharing may also occur, for example being able to take measures within responsible gaming and take measures against money laundering and financing of terrorism, if you play on any gaming service provided by any of the companies within the Group, which are license holders for that specific gaming service.

8.4 Other companies

Speedy shares personal data with other companies with which Speedy is in cooperation, but which do not act as a data processor, i.e. the company is an independent data controller. This means that these companies decide independently how personal data will be processed. Speedy shares personal data with the following companies which are independently responsible for the personal data:

  1. Companies that provide payment solutions such as card payment companies, banks and other payment service providers.

  2. Companies that provide booking services for travel, airlines, hotels and similar companies for example to organise trips.

  3. Companies that supply prizes to those who have won a prize by participating in any of Speedy’s activities.

  4. Certain game suppliers that supply games to the Gaming Service.

  5. Insurance companies that provide gaming insurance.

  6. Research institutes. Speedy transfers anonymous data to research institutes in order to contribute to research in the field of gaming responsibility.

In cases where your personal data is shared with a company that independently processes your personal data, that company’s privacy policy and personal data handling is applicable.

For further information regarding the companies that independently processes your personal data , you will find more info here or by contacting Speedy.

8.5 Transfer of personal data

Speedy always strives to process your personal data as far as possible within the European Union (EU) and the European Economic Area (EEA). In cases where it is necessary to transfer personal data outside the EU/EEA, for example, for the sharing of personal data with a data processor who, either himself or through a subcontractor, is established or storing personal data in a country outside the EU/EEA, Speedy has taken the necessary and reasonable legal, technical and organisational measures to ensure that the level of protection is the same as in the EU/EEA. When transferring personal data to a country outside the EU/EEA, the level of protection is guaranteed either by decision of the EU Commission that the country in question ensures an adequate level of protection, or that the company has entered into the EU’s standard contractual clauses. Other appropriate safeguards are approved code of conduct in the recipient country and the application of internal binding company regulations. In the event Speedy transfers personal data outside the EU/EEA, the processing is primarily supported by the EU standard contractual clauses.

9. YOUR RIGHTS

9.1 Right to access

You are entitled to access your personal data, that is, a record of what personal data Speedy is processing about you, provided that the data does not affect the rights and freedoms of others, or access to personal data is forbidden due to legal requirements, for example the Act on Preventing Money Laundering and the Financing of Terrorism. Please note that in cases where Speedy receives a request for access to data, Speedy may request further information from you requesting access to your personal data, to ensure effective handling of the request and disclosure of the data to the correct person.

9.2 Right to rectification

You are entitled to have incorrect personal data that concerns you rectified as well as within the stated purpose, to supplement incomplete personal data.

As a gaming customer, you can update your contact details yourself via your gaming account. Other data that may need to be corrected or supplemented is handled by contacting Speedy.

9.3 Right to be forgotten

You are entitled to request that Speedy delete or remove all or some personal data, for example, if the personal data is no longer required for the purposes it was collected or otherwise processed.

Please note that Speedy may deny your request for deletion or removal of your personal data in cases where the processing is performed due to legal obligations which apply to Speedy, such as the Accounting Act or the Act on Preventing Money Laundering and the Financing of Terrorism. Speedy may also deny your request for deletion and removal of your personal data if Speedy has a compelling legitimate interest for the processing, or if it is necessary for Speedy to determine, claim or defend legal claims.

9.4 Right to restriction of processing

You are entitled to some extent to request that Speedy’s processing of your personal data be restricted, for example, if you contest the accuracy of your personal data or that the processing is illegal but you do not want your personal data to be deleted. The processing of your personal data may also be restricted to establishing, enforcing or defending legal claims and in cases where the processing is based on a legitimate interest to the extent necessary to determine whether Speedy has a compelling legitimate interest which carries more weight than your legitimate grounds.

Please note that Speedy is entitled to store your personal data during the restriction of processing of your personal data and process such personal data in order to determine, enforce or defend legal claims or to protect any other natural or legal person’s rights. Speedy may also process such data in cases where you have given your consent, or for reasons relating to an important public interest.

9.5 Right to object

You are entitled to object to certain types of processing, such as Speedy’s processing of your personal data for direct marketing and processing that is supported by a legitimate interest.

9.5.1 Direct marketing

You may object at any time to processing that relates to direct marketing, including profiling (analysis of personal data collected), to the extent that profiling is connected to such direct marketing.

As a gaming customer, you can select which communications channels Speedy may use to send marketing to you through the settings in your gaming account. If you do not want any marketing sent to you, Speedy will stop sending marketing to you and discontinue such processing of your personal data.

9.5.2 Legitimate interest

In the event that Speedy relies on legitimate interest to support processing, you can object to such processing.

However, please note that Speedy may continue the processing if Speedy has a compelling reason for processing the personal data. That is to say, Speedy’s interests carry more weight than your interests. Otherwise, Speedy may only process your personal data in order to determine, exercise or defend legal claims.

9.6 Right to data portability

If Speedy’s processing of your personal data is based on either your consent or on performance of an agreement between you and Speedy, and that your personal data is provided by you and that the processing is automated, you are entitled to request that your data be transferred to another data controller (right to data portability).

9.7 Withdrawal of consent

In cases where Speedy bases its processing of your personal data on your consent, you can withdraw your consent at any time, at no cost. You can withdraw your consent by contacting Speedy customer service.

Note that the withdrawal of consent does not affect the legality of the processing that takes place before the consent is withdrawn.

9.8 Right to lodge a complaint

If you consider that Speedy’s processing of your personal data does not comply with applicable data protection laws, you may submit a complaint to the Swedish Data Protection Authority or the Finnish Data Protection Ombudsman.

10. COOKIES

Speedy uses so-called cookies. Cookies are small text files that are saved on your device (e.g. your computer, mobile or tablet) when you visit the Gaming Service.

For more information about cookies and Speedy’s use of cookies, as well as which categories of cookies are used, please read Speedy’s Cookie Policy.

11. SECURITY

Speedy has taken all necessary and appropriate steps to protect your personal data from unauthorised procedures such as unlawful or unauthorised processing, which includes theft, deletion, alteration, disclosure and transfer of personal data. These measures include the greatest possible restriction of the circle of people that has the right to the personal data and limitation of the ability of the authorised persons to make changes, as well as technical barriers to infringement, including encryption during transmission and storage, firewalls, strict requirements for passwords, and alert functions with reporting upon attempted unauthorised infringement. Pseudonymisation is used to the fullest extent during our processing, to further protect your privacy. Speedy is also ISO 27001 certified.