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Data Request Policy

Last Updated: 26 September 2025

1. Introduction

Like many organizations, Bothub Global AB (company no. 559431-4493, registered office: Kungsgatan 32, 111 35 Stockholm, Sweden) occasionally receives requests from Users and from courts, government agencies, or regulators for access to or deletion of data outside the ordinary operation and provision of the Services.

This Data Request Policy explains how we handle such requests in a fair, transparent, and lawful manner. It complements our Privacy Policy, Terms of Service, and related policies.

We may update this Data Request Policy from time to time to reflect legal, regulatory, or operational changes. The most recent version will always be available on our Website with the “Last Updated” date at the top.

2. Data Requests by Users

Users may exercise their rights under the GDPR and applicable law by submitting a Data Subject Access Request (DSAR) through our dedicated online form or by contacting us at: [email protected]

These rights include, but are not limited to:

  • Access to personal data.
  • Rectification of inaccurate personal data.
  • Erasure (“right to be forgotten”).
  • Restriction of processing.
  • Data portability.
  • Objection to processing.
  • Refusal of automated decision-making/profiling.
  • Withdrawal of consent.
  • Marketing opt-out.
  • Submitting questions or claims regarding data processing.

Identity Verification:
 To protect your data, we may request additional information or email confirmation to verify your identity. If verification fails or we have reasonable doubts about the User’s identity, we will inform you of our concerns and why we cannot proceed.

Response Time:

  • We respond within 30 calendar days of receiving a complete and verified request.
  • This may be extended by up to 60 additional days for complex or multiple requests, with notice provided.

3. Data Requests by Authorities

All official requests for User data from courts, government agencies, law enforcement, or regulators must be sent to: [email protected]

Requests must include:

  • The requesting authority and contact information.
  • The relevant case or matter (criminal, civil, or regulatory).
  • A clear description of the specific User’s personal data being requested.

Our Commitments:

  • We will only disclose User data if required to do so by law or where we have a good-faith belief that disclosure is necessary to:
    • Comply with applicable law or valid legal process.
    • Protect and defend our rights, property, or Users.
    • Respond to allegations of intellectual property infringement.
    • Protect the personal safety of Users, staff, or the public.
  • We review the legality of each request and may challenge any that appear unlawful, overly broad, or disproportionate.
  • Where not prohibited, we will notify affected Users before disclosing data, so they may seek protection, unless doing so would risk harm or impede investigations.

Cost Recovery: We may seek reimbursement for costs associated with official requests where permitted by law, particularly for unusual or burdensome requests.

4. Transparency and Accountability

  • All requests and our responses are documented internally.
  • We handle requests based on the principles of necessity, proportionality, and user protection.
  • Our approach prioritizes compliance with law while safeguarding User privacy.

5. Miscellaneous

  • Effective Date. This Policy is effective as of the date above.
  • Governing Law. This Policy is governed by Swedish law. Disputes shall first be addressed through 30 days of good-faith negotiations, and failing that, resolved by the Swedish courts, with Stockholm District Court as the first instance.
  • Interpretation. Headings are for convenience only. Undefined terms follow the meaning in our Privacy Policy and Terms of Service.
  • Language. This Policy is available in English. In case of translation discrepancies, the English version prevails.

6. Contact Information

For questions about this Data Request Policy, please contact us:

You may also contact the Swedish Authority for Privacy Protection (IMY) or your local Data Protection Authority for independent advice or complaints:
https://edpb.europa.eu/about-edpb/about-edpb/members_en

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