1 GENERAL 1.1 This privacy policy (the "Privacy Policy") applies between Bolmstedt Svanqvist AB, reg.no 559416-6513 ("Bolmstedt Svanqvist AB"), and each individual who provides Bolmstedt Svanqvist AB with their personal data (the "Data Subject").
1.2 In this Privacy Policy, terms such as "personal data," "data controller," "processing," "data processor," "standard contractual clauses," and "supervisory authority" have the meanings ascribed to them in Regulation (EU) 2016/679 of the European Parliament and of the Council (the “GDPR”), unless the circumstances obviously require another interpretation.
1.3 Bolmstedt Svanqvist AB is the personal data controller for the processing of personal data registered with Bolmstedt Svanqvist AB via the website www.strongsales.se or any of its sub-domains or connected webpages (collectively, the "Website"), or which Bolmstedt Svanqvist AB collects directly from a Data Subject or from a third party. Bolmstedt Svanqvist AB may also process personal data on behalf of one of its clients, in which case Bolmstedt Svanqvist AB acts as a data processor, and the client as the data controller.
1.4 This Privacy Policy is intended to ensure that the Data Subject is assured that Bolmstedt Svanqvist AB, in its capacity as a personal data controller, processes personal data in accordance with applicable privacy laws and regulations. Bolmstedt Svanqvist AB, in its capacity as a data processor, shall also strive to adhere to this Privacy Policy when processing personal data on behalf of a data controller; however, such processing is always subject to the instructions given by the data controller.
1.5 Below is a description of how Bolmstedt Svanqvist AB processes the Data Subject's personal data. Information is also provided regarding the Data Subject’s rights and how the Data Subject can get in contact with Bolmstedt Svanqvist AB in case the Data Subject has any questions or wishes to exercise their rights.
1.6 By using the Website or in any other way soliciting Bolmstedt Svanqvist AB's services (collectively referred to as the "Services"), the Data Subject agrees to Bolmstedt Svanqvist AB's processing of the Data Subject's personal data in accordance with this Privacy Policy.
2 CHANGES TO THE PRIVACY POLICY 2.1 Bolmstedt Svanqvist AB may, at its sole discretion, update or make changes to this Privacy Policy at any time. 2.2 In the event of changes to this Privacy Policy, Bolmstedt Svanqvist AB will inform the Data Subject through announcements on the Website.
3 PROCESSING, OBJECTIVES, AND LEGAL BASIS 3.1 The purpose of processing personal data is to enable Bolmstedt Svanqvist AB to offer the Services in full, provide information about the Services, and market the Services. Bolmstedt Svanqvist AB may use personal data for email marketing, facilitating sales, newsletter dispatches, webinar invitations, or re-targeting through advertisement platforms such as LinkedIn, Google, or Facebook, etc.
3.2 The collection and processing of the Data Subject's personal data are conducted solely with the Data Subject's consent or on the basis of an existing agreement or legal obligation, e.g., when Bolmstedt Svanqvist AB must retain data according to accounting rules. Exceptions are made for cases where prior consent is not possible for practical reasons, when the processing of the data is permitted by law, or when Bolmstedt Svanqvist AB has a legitimate interest in processing the personal data, e.g., for marketing, follow-up of the Services, or for exercising or defending Bolmstedt Svanqvist AB against legal claims, in accordance with a so-called balance of interests.
3.3 Any personal data that Bolmstedt Svanqvist AB processes in connection with the registration of the Data Subject’s use of the Services is referred to below as "Registration Data."
3.4 Bolmstedt Svanqvist AB processes the Registration Data to administer the Data Subject's ability to offer and market the Services to the Data Subject. The legal basis for the processing is the Data Subject’s consent and/or Bolmstedt Svanqvist AB's contractual relationship with the Data Subject in accordance with Bolmstedt Svanqvist AB’s general terms and conditions.
3.5 When a Data Subject contacts Bolmstedt Svanqvist AB via Bolmstedt Svanqvist AB's support service, Bolmstedt Svanqvist AB saves the personal data that Bolmstedt Svanqvist AB needs to provide the support service as part of the Services, administer support and complaint cases, and be able to contact the Data Subject. In addition to Registration Data, Bolmstedt Svanqvist AB may process personal data relating to case/ticket numbers. The legal basis for the treatment is Bolmstedt Svanqvist AB's contractual relationship with the Data Subject in accordance with Bolmstedt Svanqvist AB’s general terms and conditions.
3.6 Bolmstedt Svanqvist AB processes the Data Subject’s Registration Data for direct contact with the Data Subject via email, in order to conduct Data Subject surveys or to deliver updated purchase terms, newsletters, etc. The legal basis for the processing is a so-called balance of interests.
3.7 Bolmstedt Svanqvist AB may process the Registration Data to fulfill its legal obligations based on legal requirements, judgments, or decisions by authorities, etc. In such cases, the legal basis for the processing is Bolmstedt Svanqvist AB’s legal obligation.
4 SENSITIVE PERSONAL DATA Bolmstedt Svanqvist AB does not process any sensitive personal data, i.e., data that reveals a Data Subject’s ethnic origin, political opinions, religious beliefs or membership of the trade union, as well as personal data relating to health or sex life.
5 SHARING OF PERSONAL DATA TO THIRD PARTIES
5.1 Without the Data Subject's explicit permission, Bolmstedt Svanqvist AB will not share the Data Subject's personal data with any third party in any other way than what follows from this Privacy Policy, unless Bolmstedt Svanqvist AB is obliged to do so following the applicable regulations or unless the personal data is shared in connection with an ongoing legal, administrative, or recovery procedure in which the Data Subject and Bolmstedt Svanqvist AB are both parties.
5.2 Bolmstedt Svanqvist AB uses subcontractors for services in connection with Bolmstedt Svanqvist AB's Services (so-called data processors). These data processors may process personal data and may need some access to personal data collected in connection with the Services. Bolmstedt Svanqvist AB may also need to use the data processors’ services to store personal data. Bolmstedt Svanqvist AB always ensures that data processors only process the Data Subject's personal data in accordance with Bolmstedt Svanqvist AB's instructions and only for the purpose of providing the agreed-upon services to Bolmstedt Svanqvist AB.
6 STORING OF PERSONAL DATA
6.1 The Data Subject's personal data will not be stored for any longer than necessary, with regards to the purpose of the processing and taking into account Bolmstedt Svanqvist AB’s legal obligations, e.g., regarding accounting regulations, etc.
6.2 Bolmstedt Svanqvist AB regularly deletes all personal data that is no longer needed with regards to the purpose of the processing, in accordance with the relevant laws and regulations in force at any time.
7 TRANSFER OF PERSONAL DATA OUTSIDE THE EU Bolmstedt Svanqvist AB only transfers personal data to data processors in third countries (i.e., countries outside the EU/EEA) if the third country has an adequate level of protection according to applicable privacy laws and regulations and the data processor has agreed to the EU Commission’s standard contractual clauses for data transfers between EU and non-EU countries.
8 THE RIGHT TO REQUEST INFORMATION
8.1 The Data Subject has a right to request and obtain, free of charge, information regarding what personal data (if any) that is being processed by Bolmstedt Svanqvist AB (a so-called register extract). The Data Subject also has the right to have any incorrect personal data corrected. If the Data Subject wishes to know if Bolmstedt Svanqvist AB processes any personal data about the Data Subject, he or she can send a written and signed request to Bolmstedt Svanqvist AB in accordance with section 17 below. In the request, the Data Subject needs to indicate specifically what kind of information the Data Subject is interested in receiving (unless the Data Subject is interested in receiving information about all personal data). That way, Bolmstedt Svanqvist AB can provide the Data Subject with information that is relevant. If the Data Subject repeatedly sends requests for an extract from the register, Bolmstedt Svanqvist AB may charge a fee or, in some cases, in accordance with statutory law, refuse to comply with the request.
8.2 The extract from the register will be sent to the Data Subject within 30 days from the time Bolmstedt Svanqvist AB received the request. If the extract is extensive and Bolmstedt Svanqvist AB needs more time or if Bolmstedt Svanqvist AB for some reason cannot comply with the Data Subject’s request, Bolmstedt Svanqvist AB will, without undue delay, notify the Data Subject thereof.
9 THE RIGHT TO RECTIFICATION
9.1 In order to fulfill its obligations to always have accurate and relevant personal data, Bolmstedt Svanqvist AB systematically works with its registers and updates personal data where necessary. If the Data Subject notices that the personal data Bolmstedt Svanqvist AB processes is incorrect or if Bolmstedt Svanqvist AB lacks important personal data, the Data Subject has the right to have their personal data corrected. Bolmstedt Svanqvist AB normally performs simple data corrections without consideration, but in some cases Bolmstedt Svanqvist AB may need to consider the Data Subject's request. Bolmstedt Svanqvist AB will not approve the Data Subject's request if it is impossible or requires an unreasonable amount of work. Upon a request by the Data Subject, Bolmstedt Svanqvist AB will inform the Data Subject about whom the correction has been submitted to.
9.2 In the event that the Data Subject's personal data is changed at the Data Subject's request, Bolmstedt Svanqvist AB will inform any data processors and partners that process the personal data about the change.
10 THE RIGHT TO ERASURE
10.1 The Data Subject has the right to request that Bolmstedt Svanqvist AB erases the Data Subject's personal data when:
a) they are no longer needed for the purposes for which they have been collected and for which they are being processed;
b) Bolmstedt Svanqvist AB processes personal data under the Data Subject's consent and the Data Subject withdraws said consent;
c) Bolmstedt Svanqvist AB processes personal data for direct marketing and the Data Subject opposes the continued processing for this purpose;
d) Bolmstedt Svanqvist AB processes personal data on the legal basis of a balance of interests and there are no legitimate interests that weigh heavier than the Data Subject's interest;
e) Bolmstedt Svanqvist AB does not process personal data in accordance with applicable rules;
f) It is required that personal data is erased in order to fulfill a legal obligation; or
g) there is another relevant legal basis for the Data Subjects request to erase the personal data.
10.2 Bolmstedt Svanqvist AB has the right to refrain from erasing the Data Subject's personal data if Bolmstedt Svanqvist AB needs to retain such data in order to fulfill a legal obligation or to make/defend against legal claims towards/from the Data Subject.
10.3 When Bolmstedt Svanqvist AB receives the Data Subject’s request regarding erasure, Bolmstedt Svanqvist AB will conduct an assessment in order to evaluate if there are reasons to erase the Data Subject’s personal data. The Data Subject will then be informed about Bolmstedt Svanqvist AB’s assessment. If the Data Subject’s personal data are erased at the Data Subject’s request, Bolmstedt Svanqvist AB will inform potential suppliers and third-party partners to which personal data has been transferred that the personal data has been erased. However, Bolmstedt Svanqvist AB will not do this if it is impossible or requires an extensive amount of work.
11 THE RIGHT TO RESTRICTION OF PROCESSING
11.1 The Data Subject has the right to request the restriction of Bolmstedt Svanqvist AB’s processing of the Data Subject's personal data when:
a) the Data Subject has disputed the accuracy of the personal data, during the time Bolmstedt Svanqvist AB has the opportunity to check whether the personal data are correct;
b) the processing is illegal, and the Data Subject opposes that the personal data is deleted and instead requests a limitation of its processing;
c) Bolmstedt Svanqvist AB no longer needs the personal data for the purposes of the processing, but the Data Subject needs the personal data to be able to determine, enforce, or defend legal claims; or
d) the Data Subject has objected to processing in accordance with section 13 below when awaiting information of the legitimacy of whether Bolmstedt Svanqvist AB’s interests weigh heavier in relation to the interests of the Data Subject.
11.2 Restriction of processing implies that the personal data will be marked, so that they in the future may only be processed for certain limited purposes.
12 DELETION OF PERSONAL DATA
12.1 Bolmstedt Svanqvist AB will not retain personal data for a longer duration than necessary for the purposes of processing, and personal data will be deleted in compliance with applicable legislation, following a case-by-case assessment for the deletion of various types of personal data.
12.2 If a Data Subject requests the deletion of their personal data, Bolmstedt Svanqvist AB will remove or anonymize the personal data within 30 days from the receipt of the request. This will be done unless retaining the personal data is required for Bolmstedt Svanqvist AB to meet its legal obligations or to assert its legal claims in the future.
13 THE RIGHT TO WITHDRAW CONSENT AND OBJECT TO PROCESSING
13.1 Data Subjects have the right to object to the processing of their personal data by Bolmstedt Svanqvist AB when such processing is conducted based on a balancing of interests under the law. To exercise this right, Data Subjects must specify in writing which processing activities they object to. If such an objection is raised, Bolmstedt Svanqvist AB may only continue processing the personal data if compelling and legitimate reasons can be demonstrated, which outweigh the Data Subject's interests.
13.2 If personal data is processed by Bolmstedt Svanqvist AB for direct marketing purposes, Data Subjects always have the right to object to such processing at any time.
14 THE RIGHT TO DATA PORTABILITY
If a Data Subject has provided their personal data to Bolmstedt Svanqvist AB and is entitled to do so, they may, in certain cases, request the extraction of their personal data for purposes such as transferring it to another company. To exercise the right to data portability, the request must pertain to personal data that the Data Subject has provided to Bolmstedt Svanqvist AB with their consent or as part of an agreement. This right does not apply when Bolmstedt Svanqvist AB processes personal data based on a balancing of interests or a legal obligation. Additionally, data portability may not be feasible if technically challenging.
15 THE RIGHT TO COMPLAIN If a Data Subject has complaints or objections related to Bolmstedt Svanqvist AB's processing of their personal data, they are encouraged to initially contact Bolmstedt Svanqvist AB for assistance. However, Data Subjects always retain the right to submit their complaints directly to the relevant data protection authority.
16 SECURITY
Bolmstedt Svanqvist AB implements appropriate technical and organizational security measures as required by applicable regulatory frameworks governing personal data processing. These measures ensure a high level of security, mitigating the risks associated with accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to processed personal data.
17 CONTACT INFORMATION
If a Data Subject wishes to exercise their rights under these terms or has any inquiries regarding this policy or Bolmstedt Svanqvist AB's personal data processing, they should submit a written request via email to anton@strongsales.se.
