Preamble
This Privacy Policy ("the Policy") sets out and formalises the processing of personal data by the Holtab Group, currently consisting of Holtab AB, co. reg. no. 556181-0911, Holtab Service AB, co. reg. no. 559230-5246, and Holtab Fastigheter AB, co. reg. no. 556984-1405 (collectively referred to as "the Holtab Group", individually as "the Company", "Holtab", "we", "us").
The policy also sets out how we proceed to ensure that your personal data is collected, used, stored, protected and otherwise processed in a secure manner, in accordance with the provisions of the General Data Protection Regulation and related implementing and supplementary regulations ("the Data Protection Rules"). Holtab is the data controller for the processing.
The policy also sets out how we proceed to ensure that your personal data is collected, used, stored, protected and otherwise processed in a secure manner, in accordance with the provisions of the General Data Protection Regulation and related implementing and supplementary regulations ("the Data Protection Rules"). Holtab is the data controller for the processing.
Definitions
For the use of this Policy, the term "personal data" refers to information that can be attributed to an identified or identifiable natural person, such as name, address, social security number, date of birth, debit card number, e-mail address and telephone number (hereinafter referred to as "Personal Data").
In this Policy we describe how we process your Personal Data. For example, the term "processing" means that we record, store, send and otherwise use your Personal Data in the manner described in this Policy (hereinafter referred to as "Processing").
In this Policy we describe how we process your Personal Data. For example, the term "processing" means that we record, store, send and otherwise use your Personal Data in the manner described in this Policy (hereinafter referred to as "Processing").
Purpose of the processing of Personal Data
Personal data is processed by Holtab only for the express and specific purposes below and for no other purposes. The overall purpose of the processing is to manage existing, old and new business relationships. This means that Personal Data is mainly processed in the following cases:
(1) To safeguard and develop the service for customers;
(2) In communication with customers and suppliers;
(3) To manage support and service cases;
(4) To manage contracts;
(5) To manage requests;
(6) To manage various customer activities;
(7) For statistical purposes; and
(8) To further develop Holtab's business operations.
(1) To safeguard and develop the service for customers;
(2) In communication with customers and suppliers;
(3) To manage support and service cases;
(4) To manage contracts;
(5) To manage requests;
(6) To manage various customer activities;
(7) For statistical purposes; and
(8) To further develop Holtab's business operations.
Categories of Personal Data we process and legal basis
Holtab processes Personal Data regarding our customers, customers' customers, suppliers, prospective customers and partners.
The Personal Data we may process is:
(1) Name and identification number (social security number including date of birth);
(2) Address;
(3) Telephone number;
(4) E-mail address; and
(5) Customer number.
Personal Data may be provided to us directly from you when you interact with us, by visiting our website www.holtab.se or from third parties.
The processing of Personal Data is necessary to satisfy our legitimate business interest in being able to interact with customers, partners and suppliers and otherwise run and develop our business. We may also process Personal Data with your express consent.
If you choose not to provide Holtab with the Personal Data requested, Holtab may not be able to fulfil its obligations to you or others. Holtab will then advise you of the consequences of this.
Some of the Personal Data that Holtab collects is processed in order to comply with legal obligations as required by laws, judgments or the decisions of government agencies. Such requirements may, for example, relate to product liability and product safety requirements for contract clients, etc., as well as to safeguard Holtab's legal interests in disputes. Processing of Personal Data relating to you may also be required for accounting purposes, for example, under the Accounting Act (1999:1078) and for handling money laundering issues under the Money Laundering Act (2017:630).
(1) Name and identification number (social security number including date of birth);
(2) Address;
(3) Telephone number;
(4) E-mail address; and
(5) Customer number.
Personal Data may be provided to us directly from you when you interact with us, by visiting our website www.holtab.se or from third parties.
The processing of Personal Data is necessary to satisfy our legitimate business interest in being able to interact with customers, partners and suppliers and otherwise run and develop our business. We may also process Personal Data with your express consent.
If you choose not to provide Holtab with the Personal Data requested, Holtab may not be able to fulfil its obligations to you or others. Holtab will then advise you of the consequences of this.
Some of the Personal Data that Holtab collects is processed in order to comply with legal obligations as required by laws, judgments or the decisions of government agencies. Such requirements may, for example, relate to product liability and product safety requirements for contract clients, etc., as well as to safeguard Holtab's legal interests in disputes. Processing of Personal Data relating to you may also be required for accounting purposes, for example, under the Accounting Act (1999:1078) and for handling money laundering issues under the Money Laundering Act (2017:630).
How long is your Personal Data stored?
Personal Data is only stored for as long as there is a need to retain it in order to fulfil the purposes for which the Personal Data was collected under this Policy. Personal Data belonging to customers and suppliers is stored during the contract period and during Holtab's and third party's warranty period. Personal Data about you is never stored for more than two years after the end of your business relationship.
In order to enable Holtab to comply with the legal obligations arising from legislation or to be able to protect our legal interests (in the event of a legal process), we may retain the Personal Data for a longer period of time. However, the Personal Data is never stored for longer than is necessary or set out by law for the respective purpose.
In order to enable Holtab to comply with the legal obligations arising from legislation or to be able to protect our legal interests (in the event of a legal process), we may retain the Personal Data for a longer period of time. However, the Personal Data is never stored for longer than is necessary or set out by law for the respective purpose.
How do we protect your Personal Data?
To protect your privacy, detect, prevent and limit the risk of hacker attacks, etc., Holtab takes a number of technical and organisational information security measures. Holtab also takes steps to protect your Personal Data against unauthorised access, misuse, disclosure, alteration and destruction. Holtab ensures that access to your Personal Data is only given to personnel who need it for the performance of their duties and that they observe confidentiality.
Your rights
You have the right to receive information about the processing of Personal Data we perform. Below is a summary of the rights that you can assert by contacting us. Contact information for us can be found at the end of this Policy.
Right of access
You have the right to request information about the Processing we perform in respect of your Personal Data free of charge. You also have the right to receive a copy of the information we process about you. This request must be submitted in writing to us with clarification of what information you wish to receive. We will respond to your request as soon as possible. If we are unable to comply with your wish to access the information to which your request relates, we will provide grounds for this. The copy of your Personal Data will be sent to your registered address unless otherwise agreed in writing. On receiving a request from you, we may request additional information from you to verify your identity.
Right to rectification
As data controller, Holtab's main responsibility is for the accuracy of the Personal Data we process. If you notify us that the Personal Data you have provided is no longer accurate, we will correct, block or delete such Personal Data as soon as possible.
Right to erasure
You have the right to request that Holtab deletes your Personal Data without undue delay. Personal Data shall be deleted in the following cases:
(1) if the Personal Data is no longer necessary for the purpose for which it was collected;
(2) if you withdraw your consent and consent is the sole legal basis for processing;
(3) if processing is for direct marketing and you object to your Personal Data being processed for this purpose;
(4) if you object to the processing of Personal Data that occurs after a balance of interests and your interest outweighs ours;
(5) if your Personal Data has not been processed in accordance with the Data Protection Rules; or
(6) if erasure is required to comply with a legal obligation.
There may be obligations that prevent us from immediately erasing all of your Personal Data. These obligations are derived from applicable legislation such as accounting. If certain Personal Data cannot be erased due to applicable law, we will ensure that the Personal Data can only be used for the purpose of fulfilling such legal obligations and not for any other purposes.
Right to restriction
You have the right to request that Holtab temporarily restricts the processing of your Personal Data. Such a restriction may be requested in the following cases:
(1) if you believe that the Personal Data we have about you is not correct and that you have requested rectification in connection with this;
(2) when the processing of your Personal Data is not in accordance with the Data Protection Rules but you still do not wish for your Personal Data to be erased but instead wish it to be limited; and
(3) when we no longer need your Personal Data for the purposes of our processing but you need it to be able to establish, enforce or defend a legal claim.
If you have objected to the processing of your Personal Data, the use of the Personal Data may be restricted during the investigation. Upon restriction of your Personal Data, Holtab will only store your Personal Data and, upon further processing, obtain your consent.
Right to data portability
You have the right, in the event that we process your Personal Data by obtaining your consent or to fulfil contractual obligations with you, to request that we provide all Personal Data that we have about you, and that is processed in an automated manner, in a structured and machine-readable format. If technically possible, you also have the right to request that we transfer your Personal Data to another data controller.
Right of objection
You have the right to object to our processing of your Personal Data if the processing is carried out on the basis of Holtab's legitimate business interest. In such cases, Holtab will ask you to specify which processing you object to. If you object to any processing, we will only proceed with the processing of your Personal Data if there are legitimate reasons for the processing that outweigh your interests.
Right to lodge a complaint
You have the right to lodge any complaints regarding the processing of your Personal Data to the national supervisory authority, the Swedish Data Protection Authority. Learn more about how you can do this at www.datainspektionen.se.
Right of access
You have the right to request information about the Processing we perform in respect of your Personal Data free of charge. You also have the right to receive a copy of the information we process about you. This request must be submitted in writing to us with clarification of what information you wish to receive. We will respond to your request as soon as possible. If we are unable to comply with your wish to access the information to which your request relates, we will provide grounds for this. The copy of your Personal Data will be sent to your registered address unless otherwise agreed in writing. On receiving a request from you, we may request additional information from you to verify your identity.
Right to rectification
As data controller, Holtab's main responsibility is for the accuracy of the Personal Data we process. If you notify us that the Personal Data you have provided is no longer accurate, we will correct, block or delete such Personal Data as soon as possible.
Right to erasure
You have the right to request that Holtab deletes your Personal Data without undue delay. Personal Data shall be deleted in the following cases:
(1) if the Personal Data is no longer necessary for the purpose for which it was collected;
(2) if you withdraw your consent and consent is the sole legal basis for processing;
(3) if processing is for direct marketing and you object to your Personal Data being processed for this purpose;
(4) if you object to the processing of Personal Data that occurs after a balance of interests and your interest outweighs ours;
(5) if your Personal Data has not been processed in accordance with the Data Protection Rules; or
(6) if erasure is required to comply with a legal obligation.
There may be obligations that prevent us from immediately erasing all of your Personal Data. These obligations are derived from applicable legislation such as accounting. If certain Personal Data cannot be erased due to applicable law, we will ensure that the Personal Data can only be used for the purpose of fulfilling such legal obligations and not for any other purposes.
Right to restriction
You have the right to request that Holtab temporarily restricts the processing of your Personal Data. Such a restriction may be requested in the following cases:
(1) if you believe that the Personal Data we have about you is not correct and that you have requested rectification in connection with this;
(2) when the processing of your Personal Data is not in accordance with the Data Protection Rules but you still do not wish for your Personal Data to be erased but instead wish it to be limited; and
(3) when we no longer need your Personal Data for the purposes of our processing but you need it to be able to establish, enforce or defend a legal claim.
If you have objected to the processing of your Personal Data, the use of the Personal Data may be restricted during the investigation. Upon restriction of your Personal Data, Holtab will only store your Personal Data and, upon further processing, obtain your consent.
Right to data portability
You have the right, in the event that we process your Personal Data by obtaining your consent or to fulfil contractual obligations with you, to request that we provide all Personal Data that we have about you, and that is processed in an automated manner, in a structured and machine-readable format. If technically possible, you also have the right to request that we transfer your Personal Data to another data controller.
Right of objection
You have the right to object to our processing of your Personal Data if the processing is carried out on the basis of Holtab's legitimate business interest. In such cases, Holtab will ask you to specify which processing you object to. If you object to any processing, we will only proceed with the processing of your Personal Data if there are legitimate reasons for the processing that outweigh your interests.
Right to lodge a complaint
You have the right to lodge any complaints regarding the processing of your Personal Data to the national supervisory authority, the Swedish Data Protection Authority. Learn more about how you can do this at www.datainspektionen.se.
Processing of Personal Data on behalf of Holtab
In order to fulfil our obligations to you and provide certain services, Holtab shares your Personal Data with selected third parties. These may include, for example, partners or group companies. In such sharing or transfer, Holtab takes technical and organisational measures to ensure that Personal Data is handled securely and in accordance with this Privacy Policy.
Before Holtab hires a supplier to deliver a service whereby personal data processed by Holtab is processed by the supplier on behalf of Holtab, Holtab ensures that only suppliers who have the technical and organisational capacity and level required for the task to be performed by the supplier are hired. When Holtab hires data processors, we are fully responsible to you for their processing of your Personal Data. Where necessary, Holtab also ensures that agreements with the suppliers containing instructions on how to perform the processing of the Personal Data are in place.
Before Holtab hires a supplier to deliver a service whereby personal data processed by Holtab is processed by the supplier on behalf of Holtab, Holtab ensures that only suppliers who have the technical and organisational capacity and level required for the task to be performed by the supplier are hired. When Holtab hires data processors, we are fully responsible to you for their processing of your Personal Data. Where necessary, Holtab also ensures that agreements with the suppliers containing instructions on how to perform the processing of the Personal Data are in place.
Amendment of the Privacy Policy
Holtab reserves the right to update or amend this Policy at any time and you should regularly visit this website to view the latest version.
Last updated: 10 February 2020.
How to contact us
If you have any questions regarding this Policy or our processing of your Personal Data, please contact us by e-mail: privacy@holtab.se.