Privacy Policy

 Last updated December 26th, 2020

This Privacy Policy describes the processing of personal information that is provided under the Bower, a service offered at and in related mobile applications (“Service” / “Services”). The services are provided by Sugi Group AB, org nr 559009-0378.

When you use Services, you entrust us with your information. In this privacy policy, we explain what data we collect, why we collect it, and what we use it for. This is important! We hope you will spend some time reading the policy carefully.

In order to make our service more relevant, we collect certain data about our users. By looking at historical user data and behavior patterns, we can deliver a more tailor-made experience for you as a user.

Bower is currently based on unique user accounts created when you create an account in the app. In connection with this, we will ask you for your e-mail, and telephone number and you will have to choose a password. If you choose to create your user account through the Facebook link, you agree that we collect your authentication information, such as Your username and encrypted credentials. The same is if you choose to create your user account through Google. We may also collect other information available through your Third Party Application account including your name, profile image, country, hometown, email address, date of birth, gender, friend’s name and profile, and network. Your Facebook picture will not be saved for us at all, but it will be loaded from Facebook directly. We also collect certain data about what kind of mobile and operating system you are using.

When you use the Bower, your location and what you click on in the app, and how the app is used will be logged. You also have the option to volunteer age and gender to get better custom offers. The personal data we collect will never be used outside our service or shared with any other company.

We neither sell, share, or trade any personal information about our users of any kind to third parties without your permission.

By connecting your personal Facebook account to our app, you get the opportunity to share content, such as timeline records and inboxes from our app directly to Facebook. The information we access in this connection is the information that Facebook considers to be “publicly available information” or “public account information” ( This information is used to show your name and image in the app and is not used for anything else.

We send push notifications to the users who have actively accepted this in the app. Our users can turn off the push-notice feature at any time and the app will work just as well anyway.

Our site uses cookies. These are only used to store completely anonymous domain-internal data that we use to optimize our website and make it better.

It is only allowed to create an account per person and device at Bower. Individuals who abuse this and create multiple accounts risk being suspended from the platform. Individuals who use their counterfeit accounts or otherwise abuse their accounts may be suspended from the platform and legal action can be taken against the person.


Information we collect about you:

When using any of our services, we may collect the following information, depending on what service you are using:

  • Person and contact information – Name, Date of birth, Social security number, E-mail address, Cell phone number, etc.

  • Information about goods/services– details about the goods/services you have a deposit.

  • Historical information – your collected deposit amount and used vouchers, as well as cash donated, redeemed, and transferred.

  • Information about how to interact with Bower – how to use our services, including page response time, download error, how you reached and left the service, and delivery notifier when we contact you.

  • Device information – such as IP address, language settings, browser settings, time zone, operating system, platform, and screen resolution.

  • Geographical information – your geographical location

What do we do with your information? 

Bower handles personal data for the following purposes and with the following legal grounds ( for completion of the agreement, following the law and other legitimate interests):

    • Delivering Bower's user experience.

    • Confirm your identity and verify your personal and contact information.

    • To administer your payment and customer relationship, for example, to fulfill our obligations to you and to provide you with information, offers, and services that you request from us.

    • To send information to you in electronic format (not marketing).

    • To determine which payment methods and other services we can offer you, for example through internal and/or external credit assessments.

    • For internal troubleshooting, data analysis, testing, research, and statistical purposes. To ensure that content is presented effectively to you and your device.

    • To prevent abuse of Bower's services as part of our efforts to keep the services safe and secure.

    • To carry out risk analysis, prevent fraud, and carry out risk management.

    • To improve our services and general business development, including improving credit risk models with the aim of minimizing fraud, developing new products and features, and exploring new business opportunities.

    • In order to comply with applicable legislation, such as anti-money laundering and accounting laws and capital adequacy regulations


Offers and benefits

In order to offer you offers and benefits (if you become Bower users) like discounts, special events, products, sales promotions, store offers, samples, gifts, etc., we’ll look at your past events. This may, for example, be the number of deposits, and/or your use of Bower's services. The purpose of this is to administer Bower's offer and benefits program and analyze your deposit so that we can customize and provide you with relevant offers.

The information will form the basis for Bower's marketing and customer analysis, business and method development, and statistics. Within the offer and benefits program, Bower and Bower's partners can join Bower's, and use this information via postal services, SMS, e-mail, social media, and other digital channels to communicate with you and provide you with offers. Bower and its business partners will not use any direct marketing channel for this purpose (eg email or SMS) if you opted out of marketing (or if you have not chosen this if required by law in your country).

User Portal. If you use Bower's web and mobile app, additional data will be processed to provide the services offered in the user portal.

• Custom items and ads: You will see personalized custom items and ads based on your previous deposit.

• Custom Bower overview: An overview can be displayed where you can see the status of your Bower deposit and view your deposit history, as well as access refunds, pay and extend payment time.

• Your affiliated bank accounts: You not only get an overview of Bower's payments to you, but the user portal also gives you the benefit of connecting external bank accounts. If you sign up for this service, we will process information about your external bank account, such as account number, bank, and previous deposits on the account. It is important to us that you feel safe. We retrieve your banking information from your Internet bank over an established and secure connection. All data transmitted is encrypted and secured in accordance with the current security standard. Bower guarantees that your bank details are used only for the purpose of making your deposit payment. We process your personal data with the utmost care in accordance with GDPR and have taken security measures to ensure the safe handling of your personal data.

• Customer Service: When you contact our customer service through the user portal, we handle the information you provide.

Communicate with you. Bower may also use your data to communicate relevant information about used or similar services and to perform customer satisfaction surveys regarding our services (for example, after you have been in contact with Bower's customer service) via email, SMS, phone, or other channels.

Who can we share your information with? We take all reasonable contractual, legal, technical, and organizational measures to ensure that your information is processed safely and with an adequate level of protection when transferred to or shared with selected third parties.

Suppliers and subcontractors. Bower may share your personal information with suppliers and/or subcontractors for the performance of our contractual obligations to you and for other purposes as set forth in this Data Protection Policy. Before we involve suppliers or subcontractors, we make sure they meet our high data protection standards.

Agencies. Bower may provide the necessary information to authorities such as the Police, the Tax Agency, or other authorities if we are required by law to do so or if you have agreed to do so. An example of a legal obligation to provide information is for measures against money laundering and terrorist financing

Where do we store your personal information? We always strive to process your data within the EU / EEA. However, the data may in some situations be transferred to, and processed in, non-EU / EEA countries by a company within the Bower Group or by another supplier or subcontractor. As Bower is determined to always protect your data, Bower will take all reasonable contractual, legal, technical, and organizational measures to ensure that your data is handled securely and with an adequate level of protection comparable to and at the same level as the protection offered within EU / EEA.

How long do we save your personal information? We save your information as long as it is necessary to perform our contractual obligations to you and as long as required by statutory storage times or necessary under other legitimate interests. When we save your data for purposes other than our contractual commitments, for example, to meet requirements for money laundering, accounting, and regulatory capital requirements, we only save the data as long as it is allowed to meet our legitimate interests and/or statutory for the respective purpose.


Your right to access, rectification, deletion and to lodge a complaint

• Right to access your data. You can request a copy of your information if you want to know what information we have about you.

• Right to rectification. You are entitled to correct incorrect or incomplete information about yourself.

• Right to be deleted. You are entitled to request the deletion of your personal data when the data is no longer necessary for the purpose for which it was collected. However, there may be legal obligations that prevent Bower from immediately deleting parts of your data. These obligations derive from accounting and tax legislation, banking and money laundering legislation, but also from consumer law. What we do then is block the data that we are required to save from being used.

• Right to file a complaint. You are entitled to file a complaint with a regulatory authority. You have the option to opt out of certain specific functions. We will always respect your choice.

Bower has a data protection agent and a team of data protection specialists. Because we take data protection very seriously, we also have a customer service team dealing with data protection issues, which you access via Please visit for more information about Bower.


Thank you for reading our Privacy Policy. We hope you enjoy Bower!


Privacy Policy Manager:

Sugi Group AB

Birger Jarlsgatan 57C, 113 56 Stockholm