Privacy Notice

version 2.2. May 2018

As a company promoting privacy awareness and compliance, we at Privasee have created a Privacy Notice that aims to help you understand what personal data we collect, what we use it for and how you can exercise your rights. Reading a Privacy Notice is important, so we hope you will give it time and attention. Privasee adhere to the following principles in order to protect your personal data:

  • we do not collect more personal data than is necessary;
  • we do not use your personal data for purposes other than those specified;
  • we do not keep your personal data if it is no longer needed.

This Privacy Notice applies to the use of the Privasee website in all available languages, as
well as to the services Privasee offers.

1. Information collection and tracking

This section describes what personal data we collect and process on different occasions,
such as: when you use this website, when you apply for a job, when you contact us, etc.

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1.1. When you visit the website

You can visit our website without giving away a lot of your personal data. In an
effort to limit privacy-intrusive methods, Privasee use only one (1) session cookie in order
to improve the use of our website.

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1.1.1. Cookies

Cookies are small text files that are stored on your computer when you visit some
websites. The Privasee website uses only one session cookie to ensure increased
functionality of our website. The cookie expires as soon as you close the browser. We do
not process website visitor data for any additional purpose, such as to profile those who
access our website. We do not collect information such as your age, gender, interests,
bank details or clickstream.
Legal basis: Legitimate interest.

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1.2. When you contact us

While you can use our website without giving out a lot of your personal information, once
you contact us via the Privasee website, Privasee collects a limited amount of information
about you. If you get in touch with us via email, phone, post or other form of
communication, we may keep records of those correspondences and their content in
order to be able to respond to you or document your complaint. If you wish for your
information to be deleted from our systems, you can contact us at privacyoffice(a)privasee.eu and
read more about your rights below.

Legal basis: Legitimate interest.

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1.3. Recruitment

If you apply for a job with Privasee, we will collect, process and store the information you have sent us for recruitment-related purposes, such as contacting you and performing screening and interviews.

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Recruitment is done through a special page on our website [link]. On this website, we will ask you to fill in your name, email address, phone number, LinkedIn profile link (optional) as well as attach a CV and a cover letter and write us a short message. We process this personal data on the basis of our legitimate interest which is based on filling a position we are currently advertising and thus expanding our team.
Additionally, Privasee may keep your data for a period of time for the purpose of considering you for a different opportunity. If you do not wish for Privasee to keep your information for another opportunity, you may indicate so in the application form.

Legal basis: Legitimate interest.

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1.4. Courses and trainings

If you sign up to take a course or training with Privasee, we will collect, process and store the information necessary for us to deliver the requested service.

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The information we collect on these occasions may include: full name, address, title, contact details, billing information. We offer classroom courses as well as a range of eLearning courses.

Legal basis: Contract.

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1.5. What if you are a client of Privasee?

Privasee is mainly a B2B business, meaning that the majority of our business is based on providing services and/or products to organisations, rather than to individuals. If you are a client of Privasee, please consult the contract you’ve signed with us because it may contain a more detailed set of information on personal data processing. If you have questions, please get in touch with your point of contact at Privasee. Furthermore, when data is processed for the purposes of delivering a training/course, the processing is done on the basis of a performance of a contract.

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2. International transfers

Privasee aim to limit the international transfers of personal data to which it is a custodian. Therefore, international transfers are limited to a minimum necessary to obtain analytics of our website usage and our customer relationship management. We only transfer personal data when there is a basis for such transfers and having due consideration of the risks to the individual that may be connected to such transfers.

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2.1. INTERNATIONAL TRANSFERS TO THE UNITED STATES OF AMERICA
Microsoft Office 365 Privasee use the Microsoft Office 365 suite for external communication and internal use. This entails a transfer of some personal data to the United States of America. Microsoft is a certified EU – U.S. Privacy Shield organization, meaning that the transfers are performed under this legal mechanism for international transfers.

2.2. INTERNATIONAL TRANSFERS TO SWITZERLAND
Tresorit Privasee use Tresorit as an end-to-end encrypted file sharing service between Privasee and its partners and/or customers. Tresorit is a company based in Switzerland, therefore, data may be transferred outside the EU/EEA to Switzerland. This is done on the basis of the EU Adequacy Decision where the EU has recognized Switzerland as providing adequate protection of personal data.

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3. Security measures

We undertake security measures appropriate to the size and nature of our business, all with the aim of keeping your personal data safe and secure.

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We strive to protect our environments and systems to the fullest extent possible. This means that we continuously work on maintaining a high IT standard for our systems so that personal data is kept safe. For example, aside from the technical measures we implement, we also ensure that our staff have been trained in data protection and undergo continuous training. In addition to that, physical security measures are put in place, as well as need-to-know need-to-access basis for our employees thereby limiting the access to personal data only to those who need it in order to fulfil the purposes of processing.

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4. Disclosure to third parties

Personal data shared with us is treated confidentially. Therefore, as a general rule, we do not disclose personal data to third parties, save from circumstances in which we share data with our partners and suppliers. This is common for most businesses today, and we only share your personal data with third parties when necessary and always according to the principles stated in this Privacy Notice.

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This is a list of third parties we partner with:

List of Privasee third party providers

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5. Your rights

According to applicable law, you have a set of rights when it comes to your personal data and its processing by personal data controllers such as Privasee. We summarized them for you so that you can be aware of them and be able to exercise them if you so wish. You have the right to know what we process on you and receive a copy, you have the right to correct or complete as well as delete your personal data or object to processing, subject to certain conditions.

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5.1. Access to Information
Access to Information If you would like to obtain a confirmation of whether Privasee process your personal data, please contact us at privacyoffice(a)privasee.eu. You have the right to access the personal data we process on you to the extent that the access request is done in reasonable intervals and that fulfilling this
request would not adversely infringe on other persons’ rights and freedoms. You are also entitled to obtain a copy of the personal data we process on you. This could mean that we will charge you an administrative fee to be able to meet your request. Please note that we will always go through a verification process to check your identity before you can exercise your rights.

5.2. Information rectification, deletion, and objection to processing
If you believe the information we have on you is incorrect or incomplete, you may request for a correction and completion of that information by contacting us via privacyoffice(a)privasee.eu. When certain conditions are met, you also have the right to erasure (“right to be forgotten”). Feel free to contact us if you believe your situation meets the conditions for erasure: privacyoffice(a)privasee.eu. You may also object to processing done with the purpose of direct marketing. In such a case, you can contact us here: privacyoffice(a)privasee.eu. Please note that we will always go through a verification process to check your identity before you can exercise your rights.

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6. Retention periods

As a general rule, we store personal data of our customers for the duration of our contract with them. We may retain information such as billing or financial information for longer than that in order to comply with applicable laws as well as for the establishment, exercise or defence of legal claims. When it comes to personal data generated by the cookie on our website, this is only retained for the duration of your visit, i.e. the cookie is deleted as soon as you exit the browser you are using for the visit.

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7. When this privacy notice applies

This Privacy Policy is applicable to the use of this website and Privasee’s services towards its customers. Our website contains links to other websites. Once redirected to another website, this Policy is no longer applicable.
This version of the Privacy Policy is effective from May 2018.

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8. Changes to this privacy notice

Privasee reserve the right to make changes and amendments to this Privacy Notice at any time and for any reason. We will always make sure to have our Notice be freely available and easily accessible so that you may be informed of the content of this Privacy Notice by reading it on our website.

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9. Contact in case of questions or complaints

You are always welcome to contact us:

  • Hammarby Kaj 10D, 2nd floor (GOTO 10), 120 30 Stockholm, Sweden
  • www.privasee.eu
  • Phone: +46 (0)8 508-52888 * Email: privacyoffice(a)privasee.eu

In the event of a complaint, you have the right to contact the Swedish Supervisory Authority: Datainspektionen.

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10. To sum up

We only collect a limited amount of information about you that is necessary for improving our services and website. We do not use profiling, we do not sell or in any other way spread your data to third parties save from our partners and suppliers, we do not use your data for purposes other than what we specified.
We also make sure that your data is stored securely. We delete all information deemed no longer necessary. We constantly review our Privacy Notice in order to make it better and protect you more.

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Glossary:

Legitimate interest

Legitimate interest is one of the six legal bases for processing according to the General Data
Protection Regulation (GDPR). Legitimate interest may be used for processing as long as that
interest is not detrimental to you as an individual in the sense that it would infringe on your rights
and freedoms. We use legitimate interest in the following situations:

  • To enhance your experience on our website, only for the duration of your visit to our website.
  • To review your job application sent to us.


Contract

Contractual obligation is one of the six legal bases for processing according to the General Data
Protection Regulation (GDPR). When we use this basis for processing, it means that the processing
is necessary for a contract you have signed with us or as a preparatory step towards signing the
contract.

  • Hammarby Kaj 10D, 2nd fl (GOTO 10), 120 30 Stockholm, Sweden
  • www.privasee.eu
  • Email: info@privasee.eu