Privacy policy

About Netel Holding AB (publ) and this privacy policy

Netel Holding AB (publ), Reg. No. 559327-6263, c/o Netel Group AB, Fågelviksvägen 9, 145 84 Stockholm (the ”Company” or “we”) takes all necessary measures to make sure that our customer’s and partner’s personal data is processed by us in a lawful, fair and transparent manner.

Processing of your personal data

When you use our various services, we collect your personal data. Consequently, the Company is the data controller of your personal data and processes the data in accordance with this privacy policy. This privacy policy explains and clarifies your rights in relation to the Company regarding the processing of your personal data and how you can exercise those rights.

The Company is committed to protecting your personal data and it is important to the Company that your personal data is being processed in a secure way. We comply with applicable laws and regulations that exist to protect the privacy of individuals, including the General Data Protection Regulation 2016/679 (the “GDPR”), and the Electronic Communications Directive 2002/58/EC, including any changes to, amendments to or replacements to such laws and regulations as well as any Swedish law or regulation that implement or supplement such directives and regulations, such as the Swedish Data Protection Act (Lag (2018:218) med kompletterande bestämmelser till EU:s dataskyddsförordning). We use appropriate technical and organisational measures with respect to the amount and the sensitivity of processed personal data.

It is important that you read and understand this privacy policy before you use any of the Company’s services. You should not use any of our services if you do not approve of this privacy policy.

Some pages on our website contain links to third party websites. These websites have their own privacy policies and the Company is not responsible for their operations or their information policies. Any user who sends information to or through these third-party websites should hence review the privacy policies posted on the respective website before any personal data is transferred to them.

For information on the collection, handling and storage of information obtained through cookies, see the “Cookies” section below.

What personal data do we collect and from where?
If you use our services, you may provide information to us that is considered personal data under applicable data protection laws.

The types of personal data that we collect may, depending on the context, include:

• Contact data: name and contact information including address, mobile number and e-mail address;
• Identity data: personal identity number;
• Billing data: delivery and billing information, payment information and other information that you provide in connection with the purchase or delivery of a product or service;
• Digital information data: your username and password for our services as well as your internet protocol (IP) address and browser information;
• Usage and profile data: different kinds of demographic information, information about preferences and interests based on the use of the Company’s websites and other user-generated information that you actively choose to share through our websites.

We may collect your personal data from the following sources:

• any of Netel Holding AB (publ):s websites, e.g. when you use our websites, order a product, or participate in any of our competitions;
• from third parties in the form of group companies, or companies that the Company engages for the purpose of enriching its customer database, e.g. Bisnode Sverige AB.
• when Netel Holding AB (publ) receives an e-mail from you.

Why do we process your personal data?

If you have ordered a product or subscribed to a service from us, you have entered into an agreement with the Company. As a result, we process your personal data for the purpose of managing your purchase, order or subscription, and in order to deliver the service or product that you have ordered.

In addition to processing your personal data to complete your purchase of products or services, the Company may use your personal data for other purposes, based on other legal grounds, as set out below.

• Performance of a contract: For the handling and administration of purchases, deliveries of products, to make payments as well as to give you access to the Company’s websites and the services provided there, inter alia, customer support.
• Consent: The Company may process personal data to send direct marketing (by regular mail and e-mail), customer surveys, customer support and newsletters.
• Compliance with a legal obligation: We save invoice documentation in accordance with applicable accounting laws and regulations.
• Legitimate interest: In order to be able to provide, carry out and improve our commitments, products and services, it is necessary for us to process personal data to administer and improve our website for statistical purposes and to provide customers with relevant information and marketing, including through profiling by analysing our customers’ buying patterns on the website. Since no sensitive personal data will be processed for this purpose and the processing is limited, the Company has concluded that its legitimate interest to conduct improvements and analysis takes precedence over your privacy interest. You may always object to the processing of personal data for profiling purposes.

In the event that a service that we provide requires your consent, we will always explicitly ask you to give your consent to such a service and to the processing of your personal data in such a case. For example, we will ask for your consent if you would like to subscribe to any of the Company’s newsletters or if you would like to create an account on any of the Company’s websites.

In connection with giving your consent, you will have to confirm that you have read this privacy policy and that you consent to the processing of your personal data as described herein.

Retention of personal data

The Company takes all reasonable steps to ensure that your personal data is processed and stored securely. Your personal data will not be stored longer than permitted by applicable law or longer than necessary to fulfil the above stated purposes. Your personal data will be processed by us during the following time periods.

• Member or customer: If you are a member of the Company’s customer club or if you have registered for any of the Company’s digital services, your personal data is saved until you cancel your membership or unsubscribe from our services, but no later than three years after your last purchase. This does not apply if we need to save your personal data for a longer period of time due to any of the reasons stated below.
• Performance of a contract: Personal data (name, personal identity number, address, telephone number, e-mail, billing and delivery information) which is submitted to the Company in connection with the order of products or services is stored for as long as necessary in order for the Company’s performance of the agreement with you. This includes, inter alia, fulfilling delivery or warranty commitments.
• Legal obligation: The Company saves any documentation that constitutes accounting information in accordance with applicable accounting legislation.
• Consent: In cases where we process your personal data based on your consent, we will only save your personal data for as long as we still have your consent.

Transfer of personal data

Personal data regarding our customers is an important part of the Company’s operations. We only transfer personal data as described below. We always observe great caution when transferring your personal data and your personal data is only transferred in accordance with this privacy policy and after taking appropriate security measures.

• Group companies: Personal data may be shared within the Company’s group.
• Parties outside the Company’s group: Service providers appointed by the Company that provide services connected to this website or its functions, only to the extent it is necessary to provide such services. Further, the Company may transfer personal data to its partners, i.e. companies outside the group of companies that the Company belongs to and which are approved by the Company, for the purpose of giving you access to targeted information and offers about the Company’s products and services.
• Matching with private and public records: The Company may, if necessary to fulfil the purpose of the processing, enrich your personal data with further information through collection of information from other private and public records, for example, Statens personadressregister (SPAR), Bisnode Sverige AB. In this way, your personal data may be enriched and updated.
• Business transactions: If all or part of the Company’s operations is sold or integrated with any other business, operation or company, your personal data may be disclosed to our advisors, potential buyers and their advisors, and be transferred to the new owners of the operation.
• Legal obligations: Your personal data may also be disclosed for the purpose of the Company’s compliance with certain legal obligations and it may be transferred to the Police and other relevant public authorities when permitted and required by law.

The type of transfers mentioned above may only be carried out to companies within the EU or EEA (i.e. all EU member states and Iceland, Norway and Lichtenstein). The Company will not transfer your personal data to any third country.

Your rights and choices

Withdrawal of consent

If we process your personal data based on your consent, e.g. regarding subscription to newsletters, you may withdraw your consent at any time by contacting us at the contact details below. Such withdrawal may be made in whole or in part. If you do not wish to receive marketing and special offers from us you may withdraw your consent by contacting us or, if sent by e-mail, through a link in that e-mail.

If you withdraw your consent with respect to the use or disclosure of your personal data for other purposes stated in this privacy policy, we may no longer be able to continue to give you access to our websites or provide customer service or other services being offered to our users and permitted under this privacy policy.

Information right

You have the right to request information about what personal data concerning you that we are processing and how it is being used by contacting us in writing (see contact details below). You can change your personal details at any time in your account settings online, if you have an account on any of our websites, or by contacting customer service (contact details below).

Right to data portability

You have the right to request that your personal data be transmitted in a machine-readable format if the processing is based on your consent or on an agreement between you and the Company and under the condition that the processing is carried out by automated means.

You have the right to transfer your personal data to another data controller, where technically feasible.

Right to rectification

You are entitled to request correction without undue delay of incorrect, incomplete or ambiguous personal data concerning you by contacting us (see contact details below). For the protection of your privacy and your personal data, we may require that you identify yourself in connection with our assistance.

Right to erasure and right to restriction

In accordance with applicable data protection laws, you also have the right to request that your personal data be erased or that the processing of your personal data be restricted. In certain situations, you also have the right to object to the processing of your personal data.

Right to lodge a complaint with the Swedish Authority for Privacy Protection

You may file a complaint with the Swedish Authority for Privacy Protection (Sw. Integritetsskyddsmyndigheten) if you believe that the Company’s processing of your personal data is not carried out in accordance with applicable laws.

Cookies

The Company uses so-called cookies on our websites. A cookie is a small text file sent from a website to your web browser. The cookie cannot identify you personally, but only the web browser that is installed on your computer and the web browser you use when visiting the webpage. Consequently, different cookies are saved on different computers, should you use different computers when visiting our websites. Cookies do not carry viruses and cannot destroy any other information stored on your computer.

Cookies are usually categorised based on their origin and based on whether they are stored in your web browser or not. Cookies can either be sent to you from the website you visit (i.e. first-party cookie) or from another organisation that delivers services to the current website, such as an analysts and statistical company (i.e. third-party cookies). Cookies can also be divided into session cookies and permanent cookies. A session cookie is sent to your computer so that the webpages can function properly during your visit and is not stored on your computer but is erased when you close your web browser. The function of a session cookie is for example to activate when you return to a previously visited part of the website and thus facilitate your navigation on the website. A permanent cookie, on the other hand, is stored in your web browser and thus allows a web page to recognise your computer’s IP address even if you turn off your computer or log out between visits.

The following types of cookies may be used on the Company’s websites.

• Essential cookies: These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Cookies used

disclaimerAccepted
Functionality Cookie – This allows the website to remember the your preferences related to Disclaimers.

Changes to the privacy policy

Please note that the terms of the privacy policy may be changed or amended. Any new version will be published on the Company’s website. Consequently, you should review these terms on a regular basis to make sure that you are satisfied with the changes. In case of any material changes we will, however, e-mail you, if you have given us your e-mail address, to make you aware of any changes made.

If the changes concern processing of personal data that we carry out based on your consent, we will give you the opportunity to once again give your consent to the processing on the new terms presented.

Contact us

If you have any questions related to this privacy policy, if you suspect that a breach of this privacy policy has occurred, or if you would like to contact us for any reason stated in this privacy policy, please contact us on the contact details provided below.

Netel Holding AB (publ)
c/o Netel Group AB
Att: Netel Group Operational Support
Fågelviksvägen 9
145 84 Stockholm

or: gdpr@netelgroup.com