PRIVACY POLICY

Renew Group Sweden AB, org. nr. 556603-2602, Produktvägen 3, 435 33 Mölnlycke (”Renew”) is responsible for processing of personal data. Renew processes personal data in accordance with applicable legislation, including the General Data Protection Regulation.

The terms “we, ours, our and us” below refer to Renew.

1DATA CONTROLLER

Renew is responsible for the processing of personal data that you submit to us or that we collect about you.

You can contact us in the following ways:

by writing a letter to or by visiting us at Produktvägen 3, 435 33 Mölnlycke.

2WHAT PERSONAL DATA DO WE PROCESS?

When you interact with us in your role as a representative or contact person for the organization you work for via telephone, e-mail, letter or otherwise, we process the personal data that you submit to us or that we collect about you. Personal data that you submit to us and that we process may be e.g. name, address, telephone number, e-mail address, correspondence with you, your title and information about the organization you represent. If you act as a sole trader (Sw. enskild näringsidkare) we may also process data about purchases and sales, customer number and organization number, which is identical to your personal number.

We may receive e-mail and other correspondence that contain personal data about third parties and we will therefore process such personal data. If required, Renew will inform you as a third party about the processing.

We process different data to produce statistics in order to follow up and develop our business. However, we do not process personal data about you as a business contact for this purpose.

3WHY DO WE PROCESS YOUR PERSONAL DATA AND WHAT LEGAL BASIS DO WE HAVE FOR THE PROCESSING?

Contracts between you or your organization and Renew

If you act as a sole trader or represent an organization that we have a business relationship with, we will process the personal data that you have submitted to us within and for this relationship. We will process your name, telephone number, e-mail address, title, correspondence with you, information about the organization that you represent, customer number and organization number. For this purpose, we may process your personal data in connection with inter alia offers, deliveries, payments, sponsorships, quality- and supplier controls as well as claims or complaints. The legal basis for our processing of personal data about you who act as a sole trader is that it is necessary for the performance of the contract with you or to take steps before entering our contract. The legal basis for our processing of personal data about you who represent an organization that we have a business relationship with is that it is necessary for the purposes of legitimate interests pursued by Renew to maintain and perform our commitments in the business relationship. This means that our interest of processing your personal data as a representative overrides your interest in protecting your personal privacy. If you do not submit your personal data, we will not be able to have a business relationship with your organization or perform our commitments to the organization you represent.

Marketing

Renew will process your name, e-mail address and information about the organization you represent for marketing of us and our business to you or your organization. The legal basis for our processing of your personal data is that it is necessary for the purposes of Renew’s legitimate interests to market Renew’s products and services that we believe you or your organization may be interested in. Our interest of processing your personal data for marketing purposes overrides your potential interest in protecting your personal privacy, considering the potential benefits that these offers may bring you or your organization.

Accounting and other legal obligations

Renew will process information about financial transactions between Renew and you or your organization for accounting purposes. We will also process information to fulfil other legal obligations, such as, where applicable, to carry out necessary control of suppliers. For these purposes, we may process personal data such as name, address, telephone number, personal number, correspondence, e-mail address and information about the organization you represent. The legal basis for our processing of your personal data is that it is necessary for our fulfilment of our legal obligations under the applicable legislation in the respective situations.

4TO WHOM DO WE TRANSFER YOUR PERSONAL DATA AND WHERE IS YOUR PERSONAL DATA PROCESSED GEOGRAPHICALLY?

In addition to the processing performed by Renew, your personal data may also be processed by others. We will transfer your personal data to consultants that we engage, such as accountants and lawyers. We will also transfer your personal data to our business partners and suppliers, who process personal data on our behalf as data processors. We have agreements in place with our data processors which ensure that they process your personal data in accordance with this policy and our instructions.

Renew may also disclose your personal data in order to permit a merger, an acquisition or a sale of all or parts of Renew’s assets.

We may also disclose your personal data to authorities that require that we disclose such personal data.

Your personal data will, as a main rule, be disclosed to entities only within the EU and EEA. In case your personal data is transferred to an entity outside EU/EEA, Renew will take all necessary measures to ensure that your personal data continues to be protected, and we will also take all necessary steps to ensure that a transfer outside of the EU/EEA is made in accordance with what is set forth in law.

5FOR HOW LONG WILL WE PROCESS YOUR PERSONAL DATA FOR THE DIFFERENT PURPOSES?

We only process personal data for as long as necessary to fulfil the purposes for which they were collected. Personal data may be stored in several locations for different purposes. This means that personal data which has been deleted from one system may continue to be processed and stored in another location/system for a different purpose.

We will process your personal data for as long as necessary to fulfil our contract with you or your organization.

We will process your personal data for marketing purposes for as long as we have an agreement with you or your organization and up to one year thereafter.

Personal data that Renew processes for accounting purposes will, in accordance with applicable accounting legislation, be stored for seven years after the transaction. Personal data that Renew processes to fulfil other legal obligations will be stored for as long as necessary under the relevant legislation.

Your personal data may be stored for a longer time than stated above, if it is required to comply with legal obligations or an authority’s decision.

6YOUR LEGAL RIGHTS

6.1Withdrawal of consent

You may at any time withdraw consent that you have given to Renew and which relates to such processing of personal data that is based on your consent. You withdraw your consent by contacting us using the contact information in section 1 and stating for which purposes that you wish to withdraw your consent. You are aware that you have the right to request the erasure of personal data in connection with a withdrawal of consent.

6.2Right to rectification and access to records of processing activities

Renew will take measures in accordance with applicable legislation to keep your personal data correct, complete and updated. You have the right to rectify incomplete or incorrect personal data. You also have the right to request access to records of the processing activities regarding your personal data.

6.3Right to object to processing

If your personal data is processed with a balance of interest as legal basis, and you believe that your right to integrity overrides Renew’s legitimate interest to process your personal data, considering your specific circumstances, you have the right to object to the processing by contacting us via the contact information in section 1 above. If you object to the processing we must demonstrate compelling legitimate grounds to continue processing the personal data. You always have the right to object to processing of your personal data that is conducted for direct marketing purposes.

6.4Right to erasure

Under certain circumstances, such as when you have withdrawn your consent and there is no other legal basis for the processing of your personal data, you have the right to request the erasure of your personal data.

6.5Right to restriction of processing

Under certain circumstances you have the right to restrict the processing of your personal data to storage only, e.g. while we investigate if you have a right to erasure.

6.6Right of access

You have a right to obtain a confirmation from Renew that your personal data is processed by us and, in such a case, gain access to the personal data along with the following information:

  • the purposes for the processing;
  • the categories of personal data that are processed;
  • the recipients of personal data (in particular if they are located outside of the EU/EEA);
  • the time during which the personal data is processed;
  • information about the rights that are stated in this policy;
  • information about the source from which the personal data has been collected; and
  • the existence of automated decision-making, including profiling.

In addition, you have the right to, on request, obtain a copy of your personal data in a commonly used electronic form.

6.7Right to data portability

You have a right to receive the personal data that we process about you and that you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller where this is technically possible.

6.8Complaints to the supervisory authority

You are welcome to contact us with questions or complaints that concern the processing of your personal data. You always have the right to file complaints regarding the processing of your personal data to:

Datainspektionen / Integritetsskyddsmyndigheten (the authority will change names to Integritetsskyddsmyndigheten during 2018)

Box 8114

104 20 Stockholm

datainspektionen@datainspektionen.se