Tiny Tinkle is an app designed to support kids who wet themselves. Based on scientific research, Tiny Tinkle offers a structured 12-week training program to help children build healthy bathroom routines. With the involvement of parents, children track their progress in a fun, encouraging way.
Effective as of October 10, 2023.
This privacy policy (the “Privacy Policy”) describes how Retail Software Stockholm AB, reg. no 559070-0463, (“Tiny Tinkle”, “we”, “us” and “our”), process your personal data when you sign up to use and interact with us.
We respect and safeguard your personal integrity. It is therefore important for us to protect your personal data and ensure that our processing of your personal data is correct and lawful. By installing or using our apps, products, services, campaigns, or website (collectively our "Services"), you agree to and accept the practices and policies outlined in this Privacy Policy (“Policies”) and hereby consent to that we will collect, use and share your personal data as is set out in this Privacy Policy.
We may at any time revise this Policy at our sole discretion. If we make changes, we will post the revised Policy and update the revision date above. If required by law we will notify you, for example by sending an email notification to the address associated with your account or providing notice through our Services. Revisions are effective and binding when posted on the Services. Any continued use of any of the Services following any revision means you agree to the revisions.
Unless otherwise stated in this Privacy Policy, Tiny Tinkle is the data controller in regard to the processing of your personal data within the scope of this Privacy Policy and thus responsible for the processing of such personal data under applicable data protection laws and regulations.
If you have any questions regarding the processing of your personal data, please contact Tiny Tinkle at info@tinytinkle.com or by post at:
Retail Software Stockholm AB
Eriksbergsgatan 32
114 39 Stockholm, Sweden
Please note that this Privacy Policy does not apply to third party products or services that Tiny Tinkle do not own or control or people that we don’t manage, but that you might come to interact with by using the Sevices.
2.1.1. We process your personal data in the way and for the purposes described in this Section 2, and we are accountable in the role as data controller for the processing activities described in each table.
2.1.2. We need to base each purpose on a lawful basis. A lawful basis can for example be (i) your consent to the specific processing activity, (ii) that the processing is necessary for the performance of a contract to which you as data subject is party, or (iii) that we, based on weighing of interests, have a legitimate interest to process your personal data, which is not overruled by your interest of not having your personal data processed. In the tables below in this Section 2, you will find information on what lawful basis we process your personal data, for what purpose we process your personal data as well as for what time period we will keep your personal data.
2.1.3. Do note, we are not the data controller for such personal data processing occurring locally on your device whereas the personal data processing is not being shared with the Services.
Purpose: In order to create, maintain and manage your user account.
Processing activities: Registering, administering, and storing of your user account, including you login details and invited co-caregivers.
Categories of personal data: Your first name and surname. Login details including email address and password. Contact information, including email address and sometimes phone number. Email address and name of your invited co-caregivers.
Lawful basis: Processing of personal data connected with your user account is necessary in order for us to enter into and perform our contractual obligations in the Terms and conditions and thus provide the Services to you who have signed up to be a user.
Retention period: We process and keep your personal data for as long as the contract is valid. We regularly review the data and erase or anonymize the data when we no longer need it and, in any event, after a maximum of two (2) years after the data was provided to us (or collected as the case may be). We may be required to keep personal data for a longer period of time for other purposes, for example for establishment, exercise or defence of legal claims, to comply with legal obligations, such as bookkeeping obligations according to bookkeeping legislation.
Purpose: In order to share progress and interactions of users you are invited to follow as a co-caregiver.
Processing activities: Contact and communicate with you in the role of a co-caregiver via email about the progress and interactions of users of the Services.
Categories of personal data: First name and surname. Login details including email address and password. Year of birth. Gender. Medical diagnosis. Information provided to us when we communicate.
Lawful basis: As a co-caregiver you have been invited to follow a user on the Services as a so-called team member. The Terms and conditions apply between you and us as long as you are registered, the lawful basis for the processing of your personal data is therefore the same as for the user above (who registered the user originally and who invited you). The processing is necessary in order for us to enter into and perform our contractual obligations and thus provide the Services to you.
Retention period: We process and keep your personal data as long as you are invited and connected as a team member with the account. We regularly review the data and erase or anonymize the data when we no longer need it, for a maximum of one (1) year from the expiration of the user’s license to the account.
Purpose: In order to improve the functionality, experience and the usage of the Services.
Processing activities: Storing and analysing use of the Services. Troubleshooting and protecting against errors. Scheduling marketing activities
Categories of personal data: Usage information, including users’ interaction with the Services. User account details. User device details.
Lawful basis: It is in our legitimate interest to develop and improve the functionality, experience and usage of our products and services, including the Services.
Retention period: We process and keep information of user behaviour on the Services for as long as the information is necessary in order to fulfil the purpose. When your account has been deleted, all personal data related to your account will be deleted. Anonymized information, such as usage data, may remain with us even after deletion.
For the purposes set out above in section 2, Tiny Tinkle analyse the usage of the Services in order to provide you as a user with the most relevant features of the Services with regard to bladder training. Analysing the usage of the Services may include elements of so-called profiling. Profiling means the processing of your and other users’ personal data to analyse aspects of your behaviour on and use of the Services. We will process actions taken by you in the Services.
We may process your personal data collected and processed as set out above in this section 2, in order to comply with legal obligations according to legislation which is applicable to our operations and organisation, such as to satisfy tax or reporting obligations. We may also process your personal data in order to comply with a decision by public authority or court which requires us to keep and process your personal data.
We may also process your personal data because you, ourselves or affected third party shall be able to establish, exercise or defend a legal claim, for example upon forthcoming or ongoing dispute.
We process personal data which are collected directly from you, through various technologies that automatically collect information about your device and about your activities when you use the Services or from third parties.
You can choose not to provide us with certain information (including personal data), but that may result in you being unable to use the Services or certain features of the Services, because such information may be required for the functionality of the Services.
Access to your personal data is limited to parties which needs access to the data in order to fulfil the purposes described under Section 2 above; these are:
a) Service providers. We will engage third parties such as Amazon Web Services to act as our service providers and perform certain tasks on our behalf, such as processing or storing data, including personal data, in connection with your use of the Services;
b) Business partners. Subject to your consent or other legal ground, as the case may be, we may share your personal data with third parties with whom we transact or collaborate with to provide, purchase and deliver products, solutions or services and/or third parties with whom we seek to develop and deliver new or improved products, solutions or services with;
c) Others at your discretion. We may share personal data with others at you discretion and/or with your consent, such as with your invited team members if you add these to your account; and,
d) Authorities. We may share your personal data with governmental and/or state authorities (such as the Medical Products Agency or the Swedish Tax Agency) when required by law, regulation or by a court order.
We use administrative, technical, and physical safeguards to protect your personal data, taking into account the nature of the personal data and the processing, and the threats posed. We are constantly working to improve on these safeguards to help keep your personal data secure.
We may transfer your personal data to countries outside of the European Union (“EU”)/European Economic Area (“EEA”). If the European Commission has not issued a decision that the country to which your personal data are transferred has an adequate level of protection for your personal data, then we will provide a description of what safeguarding measures we have taken and what lawful basis we base the transfer upon in order to ensure that the transfer of your personal data is done in accordance with European data protection legislation. Please contact us by sending us a written notice to info@tinytinkle.com if you want to have more information about whether we have transferred your personal data outside of EU/EEA and what safeguarding measures we have taken to protect the transfer.
In this section we describe your rights under applicable European data protection legislation. You will not be charged if you want to exercise your rights and you can exercise them by contacting us. Do not hesitate to contact us if you have any questions regarding your rights.
Please note that we will always do an assessment of a request of exercising a right in order to determine whether the request is legitimate. Not all rights listed below are absolute, exemptions may apply.
Your rights are the following:
a) Right of access. You have the right upon request to get a copy of your personal data which we process and to get complementary information regarding our processing of your personal data.
b) Right of rectification. You have the right to have your personal data rectified and/or complemented if they are wrong and/or incomplete.
c) Right to erasure. You have the right to request that we erase your personal data without undue delay in the following circumstances:
i. the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
ii. you withdraw your consent on which the processing is based (if applicable) and there is no other legal ground for the processing;
iii. you object to our processing of personal data and we do not have any overriding legitimate grounds for the processing;
iv. the processed personal data is unlawfully processed; or
v. the processed personal data has to be erased for compliance with legal obligations.
d) Right to restriction. You have the right to restrict the processing of your personal data in the following circumstances:
i. you contest the accuracy of the personal data during a period enabling us to verify the accuracy of such data;
ii. the processing is unlawful, and you oppose erasure of the personal data and request restriction instead;
iii. the personal data is no longer needed for the purposes of the processing, but are necessary for you for the establishment, exercise or defence of legal claims; or
iv. you have objected to the processing of the personal data, pending the verification whether our legitimate grounds for our processing override your interests, rights and freedoms.
e) Right to data portability. If your personal data has been provided by you and our processing of your personal data is based on your consent or on the performance of a contract with you, you have the right to receive the personal data concerning you in order to transmit these to another service provider.
f) Right to object. You have the general right to object to our processing of your personal data when it is based on our legitimate interest. If you object and we believe that we may still process your personal data, we must demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
g) Right to object to direct marketing. You have the right to at any time object to processing which is done for the purpose of direct marketing. If you object to such processing, we will no longer process your data for such purposes.
h) Right to withdraw consent.When our processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. Please note that the lawfulness of any processing based on your consent before its withdrawal is not affected by the withdrawal.
If you have any questions or concern about this Privacy Policy (including collection, use or disclose of personal data in compliance with privacy laws), or wish to contact our support, please contact us by email by using the address info@tinytinkle.com. Any personal data shared by you for questions about the Policies or receiving support, will be used only for assessing the question or the issue and then in return contracting you about the question or issue raised. The personal data will not be used for any other purpose or with any third party. You may contact or make a complaint with the data privacy authority in your country if you are not satisfied with our response to your contact or support in relation to data privacy matters.