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INTEGRITY POLICY – CUSTOMER

1. Information on processing of your Personal Data

The aim of this integrity policy is to provide information on the way AddPro AB (‘we’) process(es) your Personal Data in conjunction with your registration as a contact for one of our customers or potential customers.

We respect your integrity and protect the Personal Data on you that we process. All processing of Personal Data takes place in accordance with the European Union’s General Data Protection Regulation (GDPR). The following is a description of the way we collect, process and share your Personal Data.

2. What Personal Data will be processed

  • We collect and process the following Personal Data on you (your ‘Personal Data’): contact details (e.g. name, company address, email address and phone number);Position within the company (e.g. CEO, CFO, buying manager, IT manager);
  • Data related to your position within the company (e.g. agreement number, customer number, buying history and related documentation)

We will mainly collect Personal Data directly from you. In certain instances we may also collect contact details from generally accessible sources or registers, e.g. publicly accessible company websites. Where appropriate we may also collect your data from collaborating partners and from other companies controlled by AddPro AB.

3. For what purposes do we process your Personal Data?

We process your Personal Data for the following purposes:

  1. In order to enter into, set up, implement and administrate agreements with customers you represent
  2. In order to act in accordance with and discharge our obligations pursuant to applicable legislation within the field of bookkeeping;
  3. In order to email you newsletters and information;
  4. To facilitate provision of offers, and so as to offer and deal with renewals of licences and agreements with customers you represent

Provision of your Personal Data is necessary in order to enter into, set up, implement and administrate agreements with customers you represent. If you do not provide us with your Personal Data we will be unable to discharge our obligations in accordance with previously cited agreements.

Provision of your Personal Data is also necessary in order to be able to send newsletters and provide offers, and so as to offer and deal with renewals of licences and agreements for customers you represent. If you do not provide us with your Personal Data we will be unable to provide you with newsletters and offers of various kinds.

4. What is the legal basis for the processing of your Personal Data?

The processing of your Personal Data for purposes [1] in Section 1 above is based on its being necessary so we can discharge our obligations in accordance with the agreements in relation to our customers. The processing of your Personal Data for purposes [2] in Section 3.1 above is based on its being necessary so we can act in accordance with the applicable legislation, e.g. the Swedish Bookkeeping Act (SFS 1999:1078).

The processing of your Personal Data for purposes [3] to [4] in Section 1 above is based on our justified interest. The processing of your Personal Data for these purposes is based on our justified interest in marketing our services or products via newsletters and through provision of offers related to our services or products. The Personal Data that is processed is of a simple nature, and in many instances it is to be found in generally accessible sources. Furthermore, the processing is of a simple nature, and does not involve any major violation of personal integrity. Based on this, we have weighed up the interests involved, and as a result we consider that our justified interest takes precedence over your interest in your Personal Data not being processed for this purpose. You always have the right to object to this assessment. You can read more about your rights below.

5. Who has access to your Personal Data?

We have undertaken appropriate technical and organisational security measures to protect your Personal Data against loss, unauthorised access, etc. The number of persons who have access to your Personal Data is restricted. Only persons at AddPro who need to process your Personal Data in accordance with the purposes cited above have access to the Personal Data

We may share your Personal Data with other companies under the control of AddPro AB in order to deal with joint undertakings related to one of the four original objectives in Section 3.1.

We may also share your Personal Data with suppliers and collaborating partners who carry out services on our behalf, e.g. advertising agencies hired by AddPro, subcontractors involved in the management of customer invoices and related financial accounts and bookkeeping, shipping agents and distributors, and suppliers of third-party IT services and document storage for which we have a current appropriate personal data processing agreement (or similar protection).

Your Personal Data may also be shared with a tax authority or other authority if we in good faith assess that the law or another regulation requires us to pass on this data (e.g. because of a request from a tax authority or in conjunction with a pending legal dispute). Your Personal Data may be shared with a country outside the EU/EEA, e.g. the USA. Any transfer will be based on a weighing-up of interests, and will be necessary to facilitate provision of newsletters. When your Personal Data is shared with countries outside the EU/EES we use standard agreement clauses that have been approved by the European Commission in order to ensure a satisfactory level of protection for your Personal Data. The standard agreement clauses are available via the following link: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

6. For how long will we save your Personal Data?

Your Personal Data will only be saved for as long as is necessary on the basis of the purpose for which it was collected and for as long as is permissible or is required in accordance with local legislation. This means that your Personal Data will be saved for as long as we have agreements or obligations related to you or the organisation you represent, and for as long as is permissible or is required in accordance with local legislation.

For the Personal Data collected on the basis of a weighing-up of interests, we will save your contact details for one year if you (or the organisation you are representing, where appropriate) have not got in touch, insofar as our processing does not subsequently switch to another legal basis (i.e. your company becoming a customer of ours, with you acting as a representative of the customer).

7. What are your rights?

AddPro AB, Corp. Reg. No. 556990-8485, with the address Arenagatan 8 B, SE-215 33 Malmö, is the data controller for the processing of your Personal Data. This means that we are responsible for your Personal Data being processed correctly and in accordance with the applicable legislation. You have the right to know what Personal Data about you we are processing, and can request a copy of the Personal Data being processed. You have the right to request rectification of incorrect or incomplete Personal Data, and in certain instances you can request that we delete your Personal Data. If you have given specific consent to specific processing of personal data, you always have the right to withdraw your consent. You can do so using the contact details stated in Section 7.1. You also have the right to object to certain processing of your Personal Data and to request that the processing of your Personal Data be restricted. Please note that restriction or deletion of your Personal Data may result in our being unable to discharge our obligations in accordance with previously cited agreements. You also have the right to receive your Personal Data in a structured, generally used and machine-readable format and to transfer it to another data controller.

If you have any questions about the way we process your Personal Data or wish to assert your rights in accordance with [7.2], please feel free to contact us using the following form: https://www.addpro.se/Personal Data-forfragan

If you wish to report a personal-data incident, please feel free to contact us using the following form:
https:/www.addpro.se/Personal Data-incident

If you have any objections or complaints regarding the way we process your Personal Data you have the right to contact or submit a complaint to the Swedish Data Inspection Authority.

8. Changes

In the event of any changes with regard to the processing of your Personal Data we will inform you of this by publishing an updated version of this integrity policy at https://www.addpro.se/Personal Data/informationsgivning