This Privacy Notice (the "Privacy Notice") explains how your personal data is collected and processed by SEWN Technology Solutions AB 559197-5411 ("SEWN", "we" or "us") when you register for and use our digital marketplace and the thereto related services (the "Marketplace"). This Privacy Notice describes how we collect and process your personal data within the Marketplace.
Who is responsible for the collection and use of your personal data?
SEWN is the responsible party for collecting and processing of your personal data (data controller). Our contact details are: Postal address: BOX 2003, SE- 663 11 Hammarö, Sweden.
1. How we process your personal data
We process your personal data in connection with your application for membership, your registration for a Marketplace account, when you access the Marketplace or contact us, and upon the termination of your membership and Marketplace-account. We collect your personal data directly from you as well as from external sources. The personal data that we process are described in detail below in Section Processing of your personal data". The personal data that we process are
2. What are my rights in relation to my personal data?
We process your personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation) (GDPR"). According to the GDPR
2.1 Information: You have the right to obtain concise, transparent, intelligible and easily accessible information about how we use your personal data and your rights related thereto. This is in part why we are providing you with the information in this Privacy Notice.
2.2 Access to personal data: You have the right to access your personal data, for example to confirm our use in accordance with law.
2.3 Rectification: You are entitled to have your personal data rectified if they are inaccurate or incomplete.
2.4 Erasure: You have a â€˜right to be forgottenâ€™. This means in short that you, subject to certain conditions, can request the deletion or removal of your personal data where the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, where you have withdrawn your consent or where we have no compelling legitimate grounds for the processing which override your interests, rights and freedoms in relation to your personal data.
2.5 Restriction of processing: You have, subject to certain conditions, a right to block or prevent further use of your personal data. When processing is restricted, we can still store your personal data, but our use of your personal data will be restricted.
2.6 Data portability: Subject to certain conditions, and insofar it does not affect the rights and freedom of other data subjects, you have the right to digitally obtain personal data that relate to yourself and have such personal data transferred to another data controller. The right can for example be used when you have provided us with personal data for the purpose of performing a contract with you and facilitates for you to move, copy or transfer your personal data easily between our IT systems or to external data controllers, without affecting its usability.
2.7 Objections to processing: Where the processing is based on our legitimate interest, you have the right to object to such processing unless we have a compelling and legitimate reason to continue processing your personal data. You may at all times object to the processing of your personal data for direct marketing purposes.
2.8 Complaints: You have the right to lodge a complaint about the way we handle or process your personal data with the Swedish Data Protection Authority (DPA"). Such complaint is lodged by way of completing a form that is available at the DPAâ€™s website and that is sent by email to firstname.lastname@example.org or by mail to Integritetsskyddsmyndigheten
2.9 Automated-decision making: As a main rule, you have the right not to be subject to a decision that is based solely on automated processing (including profiling) and that produces legal (or similarly significant) effects to you. Please see further information below.
3. How can I exercise my privacy rights?
SEWN is the responsible party for collecting and processing of your personal data (data controller) and we ask you to send all requests regarding exercising your privacy rights to SEWN. If needed, we will then contact the appropriate responsible persons within our organizations or other companies with whom we might share your personal data, in order to manage your requests, questions and complaints. You contact us through our data protection contact person email@example.com: You may also contact us on the following address: BOX 2003, SE- 663 11 Hammarö, Sweden.
Your requests will be answered as soon as reasonably practicable and always in accordance with the applicable time periods set out in the GDPR. When you contact us, we may ask for further information necessary for us to verify your identity. The purpose of such request for additional information is to ensure that we do not provide you with information on other data subjects than yourself, which would be a violation of the GDPR. Please note that even though you have requested the erasure of your personal data, there may still be a need to retain certain personal data if required or authorized by law.
4. Changes to this Privacy Notice
This Privacy Notice will be updated from time to time. Our application and web portal will always display the current version, and by ticking the tick-box, we will be assured that you have taken part of the most recent version. If you have any questions regarding any changes to this Privacy Notice, please contact us as set out in Section How can I exercise my privacy rights?" above.
5. Processing of your personal data
This section explains how, why and by whom your personal data is collected and used when you register with and use the Marketplace.
Step 1 - Application for membership
The Registration Data is collected in order for us to approve your application for a membership with us. The processing is legitimate as it is necessary to conduct preparatory measures for the purpose of entering into the services agreement regarding the Marketplace. The data will be retained until the agreement is terminated and during such longer period of time that may be necessary in order to establish, exercise or defend any legal claims.
Step 2 - Creating and activating your Marketplace account
Once your membership application has been approved, you must create a Marketplace account to use the Marketplace. To do this, you will need to login to the Marketplace, using your Registration Data, and provide the following additional personal data:
- your personal identification number and/or date of birth (depending on in which country you reside);
- your home address or place of business depending on whether or not you access the Marketplace in your capacity of a private person or as an employee of a customer of SEWN;
- registration of debit/credit card or other payment related information for payments of membership fee and variable purchases as applicable.
The personal data above constitutes your â€œAccount Informationâ€. When you have provided your Account Information you will initiate our assessment process to receive a Marketplace account. Your Account Information is used in this step with the purpose to create your account for us to assess the prerequisites of entering into a Marketplace contract. The processing is legitimate since it is necessary in order for you to be able to enter into a Marketplace contract with us. The data will be retained until the agreement is terminated and during such longer period of time that may be necessary in order to establish, exercise or defend any legal claims, or comply with legal obligations.
We may also conduct a credit assessment where we provide information to a Swedish or other nationality credit reference agency in order for that reference agency to assess your fulfilment of our creditworthiness requirements. The assessment merely generates a â€œyesâ€ or â€œnoâ€. We process data on your creditworthiness in order to determine your payment ability. The processing is legitimate since we have a legitimate interest of payment obligations being fulfilled. The data will be retained until the agreement is terminated and during such longer period of time that may be necessary in order to establish, exercise or defend any legal claims or comply with legal obligations such as replying to requests from authorities.
Step 3 - Using the Marketplace
We use your Registration Data and Account Information so that you can make purchases, enter into agreements with other participants, communicate with them and otherwise use and access the Marketplace. Your Registration Data and Account Information is used in the following ways:
- Administration of how you use the services (such as feedback, reviews, searches, discussions, enquiries and communications) and
- Administration of purchases, subscriptions and transactions.
The information above constitutes your â€œUser Informationâ€. The User Information is used to manage your use of the Marketplace and to ensure that it is conducted according to contract. The processing is legitimate since it is necessary in order to perform the contract you enter into with us. The data will be retained until the agreement is terminated and during such longer period of time that may be necessary in order to establish, exercise or defend any legal claims.
Step 4 - Support
Through the Marketplace we provide you support. In order to communicate with you in an efficient way, we use your Registration Data, Account and User Information. For example, we may need to know your purchase history to help you with current purchases etc. We also need to be able to contact you to follow up on enquiries. The processing is legitimate since the processing is necessary for our legitimate interests of ensuring that you may use the Marketplace in a satisfactory way. The data is retained as long as a matter is open, and regarding certain data, at the longest until you or we terminate the contract.
Step 5 - Terminating your membership
You may terminate your membership with us by contacting us, and your membership will then terminate the following turn of the month or if you have subscribed to a fixed term upon the expiry of said term. In some cases, we may have the right to immediately terminate your contract with us. We use your Account Data in order to terminate your membership as described above. The processing is legitimate since it is necessary in order to perform the membership agreement. If we terminate the Marketplace agreement, we will retain your personal data during a period of 90 days or during such longer period of time that may be necessary in order to establish, exercise or defend any legal claims.
Step 6: Our communicating with you
We use your Registration Data, Account and User Information to communicate with you for the following purposes:
- to keep you updated (through mail or so called push messages) on your use of the Marketplace, e.g. notification of reviews, articles, direct messages etc.;
- to respond to any queries you may have relating to our use of your personal data accurately and promptly;
- to make changes you have requested to your Account Data;
- to survey you on your user experience of the Marketplace;
- to ask you if you approve of processing of your personal data for marketing purposes; and
- to support our sales and marketing activities.
For direct marketing (e.g. by telephone, email and text messages) where such marketing are invitations to attend events, offers and recommendations or requests to participate in marketing surveys, we will only use your personal data where you have given your express consent for each type of marketing communication. You can give or withdraw your consent at any time by contacting us. When you have provided a valid consent, the processing is legitimate on the basis of such consent and during such time from which your consent is registered by us until you withdraw it.
Step 7: Using your personal data for other purposes
We use your Account and User Information in order to:
- improve the performance of the Marketplace and our services and in order to develop new ones;
- conduct research and development, carry out data analysis and create user group profiles from aggregated data to enhance and improve the Marketplace and to develop new services and solutions; and
- secure, maintain and support its networks, systems and applications.
The abovementioned personal data are only processed to a limited extent and during the period required to transform such personal data into aggregated data. The legal basis we rely on to process your Account and User Information for the abovementioned purposes and for the limited processing period is the legitimate interest to be able to provide the customer collective with relevant services and to develop products and services.
We may also use your Account and User Information if necessary in connection with a dispute in which we are or may become involved either directly with you or with a third party. The purpose of the processing is to solve such dispute and the processing is legitimate since it is necessary for our or a third partyâ€™s legitimate interest of solving a dispute.
We also process your personal data in order to comply with legal obligations to which we are subject. We may, for example, share financial information in accordance with the Swedish Bookkeeping Act (1999:1978). The processing for such purposes is legitimate since it is made in order to comply with a legal obligation. The data is retained as long as is required by law, which in terms of bookkeeping, in relation to us, is 7 years.
6. Sharing your personal data
Within the framework of your use of the Marketplace we share your personal data with others in the following ways:
- Where required in order to comply with legal obligations, legal proceedings or decisions by a public authority we will share your personal data with public authorities (for example law enforcement authorities such as the Swedish Enforcement Authority and supervisory authorities such as the Swedish Tax Office) and courts.
- If we will become involved in a dispute, we may share your personal data with other parties, or a third party such as a collection agency.
- We use external service providers in connection with the development, marketing and provision of the Marketplace. These service providers may, in certain cases, obtain access to your personal data when providing services to us. For example, we use external service providers to support and maintain the IT systems, platforms and applications that it uses to provide the Marketplace. All our service providers are bound by strict obligations regarding confidentiality and data security in accordance with GDPR. In such cases where our service providers process personal data about you, on our behalf, we enter into data processing agreements which fulfils the requirements of GDPR with such parties.
7. During what period of time do we retain your personal data?
As a main rule, we will only retain your personal data for as long as it is needed to provide the Marketplace to you and cater the purpose for which we collected the personal data.
After your Marketplace membership is terminated your Registration Data, Account and User Information will, as a main rule, be retained during such time needed in order to terminate all dealings with you and solve potential debts or other obligations. Your personal data will thereafter be removed permanently, if there is not any legal obligation for us to retain the personal data during a longer time, or if we otherwise need the data in connection with any disputes or legal claims. With the purpose to give you the possibility to reactive your membership with us, your account with its data will be retained for a period of 90 days after the termination of the membership. If you wish to terminate the membership immediately, you may contact our customer service. Then, we will delete your Marketplace account.
Please note that we process certain aggregated data coming from your personal data, but which has been anonymized in such a way that the information no longer constitutes personal data regarding you. GDPR is not applicable in relation to such anonymized aggregated data and we may retain such data during other time periods than what is otherwise stated in this Privacy Notice.
8. Will my personal data be transferred to other countries?
Your personal data may be stored and processed by us as well as third-party service providers in multiple countries, including countries other than your country of residence. Your personal data may, for example, be transferred to the United Kingdom and/or the United States.
Your personal data will thus be transferred to countries located outside of the European Economic Area (â€œEEAâ€). Such transfer will only occur where there are an adequate level of protection in the relevant country, or if appropriate safeguards in place, such as Binding Corporate Rules, or Standard Contractual Clauses, in order to protect your integrity and ensure that the processing of your personal data is made in a way corresponding to the requirements of GDPR. We will always take necessary safeguards, including technical safeguards in order to ensure that your personal data is processed in accordance with the requirements of GDPR.
We ask you to note that the information that we process in order for the provision of the services to be provided may be subject to the Clarifying Lawful Overseas Use of Data Act (H.R. HR 4943) in USA or similar such legislation. According to such legislation certain competent authorities may require a data controller to disclose personal data to the authority in question. You acknowledge that in such case, SEWN may not refuse to disclose personal data we may only inform you about such disclosure if permitted by the authority. By using the Marketplace, you acknowledge this risk and accept that we may have to share your personal data with foreign authorities depending on where the data is processed.
9. Keeping your personal data accurate and up to date
It is important that the personal data that we hold about you is always accurate, complete and up to date. There is the possibility to rectify some of your personal data directly through the Marketplace. In some cases, you may need to, due to technical reasons, contact our customer service in order to rectify personal data.