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6/29/2018

Personal Data Policy

This policy applies to the processing of personal data that Volito AB (”Volito” or ”we”) collects about you that can stem, for example, from our website (www.volito.se), post, email, text messages, telephone, other contacts with us, from our group companies, third parties and from generally available information.

We safeguard your personal integrity. This policy regulates how we collect, use and protect information about you and how you can exercise your rights. Please contact us if you have any questions or viewpoints regarding this personal data policy.

When stating “with reference to law”, we refer in this policy to the General Data Protection Regulation, (GDPR) and other applicable Swedish data protection legislation.

 

1. Personal data
“Personal data” is defined as information that is about you and can identify you. In this personal data policy the terms ”personal data” and ”information about you” are used synonymously and interchangeably.

You can use our website in most instances without giving us any information other than technical data. Otherwise, the personal data we process about you in most cases comes from you, or someone in your organisation, in connection with us being able to answer questions, meet a request from you, send out financial information, such as the annual report, and send out information on events. If you represent one of our business areas/group companies/portfolio companies or a stakeholder or business partner of ours, the data can come from someone in your organisation or from you.

The personal data about you may include:

 

Personal and contact information– such as your name, address, email address and telephone number and also, when it is clearly justified in view of the purpose of the processing or the importance of reliable identification, your personal identity number.

Financial informationinformation such as invoice details etc.

Technical dataabout your unit or internet connection – e.g. IP address, cookies and geographical location.

User-generated information– content you have registered or submitted, for example via email or by telephone.

Information from other sources– such as generally available information or information from our business areas/group companies/portfolio companies, stakeholders or business partners.

 

2. Purpose and legal basis
For our processing of your personal data to be legal, there is a condition that there is a legal basis for it, i.e. that it is necessary in order to fulfil an agreement with you or a legal obligation that rests with us, that processing is carried out after a balancing of interests or that you have given your consent for specific processing. Below are examples of the purposes for which we process your personal data and the legal fees basis on which it is carried out.

Volito processes your personal data for various purposes. Volito mainly processes your data for the following purposes and with the support of the stated legal basis:

One of our principal reasons for collecting personal data is to fulfil our obligations to our business areas/group companies/portfolio companies, stakeholders and business partners, as well as to send out financial information and the annual report, for accounting and invoicing purposes, and otherwise for ensuring that legal requirements are met (e.g. the Annual Accounts Act).

 

Legal basis: Fulfilment of agreements or legal obligations, or if you are a representative, employee or otherwise represent an organisation that has entered into an agreement with us – legitimate interest. Volito’s legitimate interest in the personal data processing in question is to be able to fulfil the mentioned agreement obligations or legal obligations.

 

We may use personal data in order to – via post, email, text messages or by telephone – send out financial information, such as the annual report, provide information on forthcoming events, as well as for the distribution of other marketing and information on our services that we, our business areas/group companies/portfolio companies, stakeholders and business partners offer and which we think may be interest to you or your organisation.

 

Legal basis: Legitimate interest. Volito’s legitimate interest in the personal data processing in question is to be able to give you/your organisation relevant information and customised offers.

 

3. Information about cookies
We use cookies on our website and in our email communications. For more information on how we use cookies and suchlike, see our cookies information at www.volito.se.

 

4. Transfer of personal data
We process your personal data with great prudence and your information is only used by us and selected third parties.

 

Third parties, including group companies, that we engage to help us run our operations (including, for example, IT and travel and for sending out the annual report) have in most cases only authorisation to use your personal data on our behalf and for the particular tasks they are to execute according to our instructions. They thus act as a data processor for us. They have an obligation to keep your personal data confidential and secure. In certain cases they act as independent data controllers.

We may also in certain circumstances disclose personal data, e.g. when we have reason to believe that data is necessary to identify, contact or pursue a claim regarding someone we have a claim against or has breached the website, or has in some other way encroached on or infringed our, or other’s, rights or property.

Processing of your personal data in accordance with this personal data policy can require transfer of your personal data to a destination outside Sweden. The transfer of personal data to countries outside the EU/EES is only carried out to the extent that it is allowable according to the law and also requires, for example, that the country in question has an agreement with the EU/EES, that the country is considered to have adequate data protection legislation, or that we have entered into an agreement with the third party in question regarding their obligation to apply clauses approved by the EU Commission concerning protection of personal integrity. You will find a list of approved third countries and standard clauses on the EU Commission’s website, and information about transfer of data to third countries on the Swedish Data Protection Authority’s website.

 

5. Your rights
In accordance with the law, you have the right to request information about personal datawe have about you after you have identified yourself and clearly stated what information you wish to review.Such a request is to be in writing, signed by you, and sent to the address given under point 11. Furthermore, we may request further information to ensure that the information is disclosed to the right person. We will, as soon as possible and within one month, meet your request. In cases where we cannot meet your request, we will inform you of this and state why.

If you consider that information about you is incorrect or incomplete, you have, within the limitations prescribed by law, the right to contact us with a request to make a correction. We will correct or update the information about you as soon as it is reasonably possible.

You also have, to the extent prescribed by law, the right to request that information about you is removed, or to request that we limit the processing of your personal data, or to retract any consent that has been given. You also have, to the extent prescribed by law, the right to transfer (data portability) the personal data you submitted to us.

Note that there may be a requirement to retain necessary personal data in connection with deletion, retraction of consent or data portability in order to fulfil our obligations in accordance with a law or agreement. It may also be permitted for us in accordance with the law to retain certain personal data in order to meet our business needs.

You have the right to raise objections against such processing of your personal data that we carry out with support of balancing of interests. We must then, after you have specified the processing you object to, show that there are interests that carry more weight. You also have the right at any time to raise an objection to processing of your personal data that is carried out for direct marketing.

 

6. Duration of storage
Your personal data is saved for only as long as it is necessary for the purposes associated with this personal data policy or for as long as required by a law or agreement.Personal data is destroyed or anonymized when it is no longer relevant for the purpose for which it was collected or is no longer needed in accordance with a law or agreement.

 

7. Data security
We process personal data in accordance with currently applicable laws on personal data processing. Personal data is stored in operational environments that use security measures to prevent unauthorised access. Reasonable standards for protection of personal data are followed. The measures are taken with an aim to prevent unauthorised or illegal processing of information about you and unintentional loss, destruction of, or damage to, this data.

Should a personal data incident be discovered, it will, to the extent prescribed by law, be reported to the Swedish Data Protection Authority and to you.

 

8. Links to other websites
Please note that this website may contain links to other websites. In cases where you follow such a link, this can entail that you visit other websites that have other rules for integrity protection than those stated in this personal data policy.

 

9. Amendments to the personal data policy
We may update this personal data policy. If substantial changes are made to this personal data policy, we will inform you by placing a clear message on the website or by other appropriate means. We urge you to read through this personal data policy in order to keep yourself informed about how we process your personal data.

 

10. Complaints
If you consider that processing of your personal data has been carried out in an incorrect way, we request that you report it to us immediately. You also have the option to make a complaint to the Swedish Data Protection Authority regarding our personal data processing.

 

11. Contact
Volito AB, 556457-4639, is the data controller for the processing of your personal data according to the above, unless otherwise stated, in connection with the collection of your data. If you have any questions about the policy or our personal data processing, please contact us using the information below. 

 

Email: [email protected]

Address: Skeppsbron 3, 211 20 Malmö

Telephone: +46 40 660 30 00