1.1 Personal Data is any and all information that can, directly or indirectly, be used to identify or contact an individual. For example, information such as your name, your postal address or your phone number can be used as such identifiers. In other cases, you may be identified indirectly through information that is, for example, related to a family member. Some Personal Data is regarded to be sensitive and is Processed with extra care. Such Personal Data can be information about your health, political opinions or religious beliefs.
1.2 Processing means any operation or set of operations that we perform regarding the Personal Data that we are storing about you. Processing may be collecting, transferring, storing or analyzing such data.
1.3 Controller is the person or legal entity that determines the purposes and means for the Processing of your Personal Data. When Anocca acts as Controller, we are responsible for protecting and Processing your Personal Data correctly in accordance with applicable law.
1.4 Third Party means an individual, legal entity or public authority that is not part of Anocca and that we have no collaboration with.
2 HOW DO WE COLLECT PERSONAL DATA?
2.1 We may collect Personal Data when you contact us, visit our website, apply for employment within our organisation and is part of the recruitment process, or when we are fulfilling an assignment or service provided by you or a company that you represent.
2.2 In some cases, we may collect Personal Data from different companies or public authorities. This can be the case if you are applying for a job and we choose to contact a reference you have provided us or if we need to verify any of the Personal Data that you have provided us with. Such collecting of Personal Data from different companies or public authorities is conducted in accordance with applicable law.
2.3 Furthermore, we may collect Personal Data regarding other individuals than yourself if you should provide us with such Personal Data. For example, this may be the situation when you give us the contact details to a relative or an emergency contact.
3 WHICH PERSONAL DATA DO WE COLLECT?
3.1 We strive to not collect more Personal Data than needed in order for us to fulfil the purposes for which the Personal Data is necessary. We also make sure that Personal Data is collected in accordance with applicable law. For example, we may collect the Personal Data that is listed below (the list is not exhaustive) when you contact us or apply for employment. We may also collect Personal Data when we are interacting with a customer, sponsor or a supplier. The Personal Data is collected in order for us to reply to a question or a request or to fulfil an obligation and may be the following:
a) contact details such as your name, postal address, e-mail address, phone number and photos,
b) contact details such as names, e-mail address and phone numbers to your family, friends or references,
c) title and workplace,
d) social security number, national ID-number or other official identification numbers,
e) citizenship and possible status for a work permit,
f) information about references and any Personal Data that may be provided from such references, and
g) any other Personal Data that you may provide us with regarding your marital status, your family, health or hobbies.
4 WHY DO WE PROCESS YOUR PERSONAL DATA?
We use your Personal Data to provide our services, to fulfil our agreements and to fulfil our legal obligations in accordance with applicable laws such as, but not limited to, the Book-keeping Act (1999:1078). More specifically your Personal Data may be Processed in order for us to:
a) fulfil our legal obligations as an employer, fulfil our obligations as party in an agreement with our employees or other companies and fulfil our obligation to provide our services correctly. This means that Personal Data could be Processed in order to administrate salaries, insurances or disciplinary actions,
b) maintain and manage the relationships we have with our customers and suppliers,
c) communicate with you if you have questions, a request or if there is a subject we need to communicate with you regarding your relationship with us as a company,
d) protect our services and your Personal Data from fraud or other illegal activities,
e) evaluate your qualifications and suitability for a position that you have applied for within our organisation.
4.2 We collect and may use your contact details in order to send you messages regarding changes in our general terms or our policies. Since this information is vital in order for you to use our services, and for us to keep providing them, you cannot refuse to accept these messages unless you wish for us to stop Processing your Personal Data.
4.3 Personal Data may also be collected when you are visiting our website or using our services. This Personal Data is and can be used for the following purposes:
a) information such as your IP-address or information about certain settings that are unique for the device you are using when you visit our webpage or register for a service that we offer, in order to register you for that service,
b) information derived from cookies that can be used to gather information about when or how you are using a service in order for us to offer and provide you with more personalized services,
c) information about how you use our website or services that can be used to create, develop or deliver our services, as well as protect you from loss of data and fraud, and
d) information for data analysis and statistics that can be used to improve our services and improve our communications.
5 HOW DO WE PROTECT YOUR PERSONAL DATA?
We protect your Personal Data by communicating our guidelines and policies on integrity, security and protection to all our employees and to our whole organisation. We also maintain and take the technical and organisational measures that we find appropriate in order to protect your Personal Data and comply with applicable law.
6 DO WE DISCLOSE YOUR PERSONAL DATA TO ANY THIRD PARTIES?
6.2 Your information is not transferred or shared with any Third Party for their marketing or business purposes without your consent.
6.3 We may share your Personal Data with business partners such as our:
a) parent companies or group companies,
b) collaborators, or
c) suppliers that provide services to us or provide services on our behalf. For example, services and programs used for emails, invoices, databases, analysing data and time registration within the organisation. The suppliers we use are solely entitled to Process your Personal Data in order to provide us with their offered service and support, and we enter into agreements with each supplier that stipulates that they may only Process your Personal Data in accordance with our given instructions.
6.4 A person, legal entity or company that is Processing Personal Data on our behalf is called a “Processor”. In some cases, Anocca acts as a Processor when we are Processing your Personal Data and not as a Controller. In these cases, we may not be able to provide you with your Personal Data directly at your request. Instead, we will first need to inform the Controller who originally collected your Personal Data that you have requested such access. When we are acting as a Processor you should therefore turn directly to the Controller in order to gain access to your Personal Data.
6.5 In some cases, Anocca may be forced to disclose your Personal Data to a public authority or a public court in order to comply with a governmental decision or a legal obligation. This may be the case in a legal proceeding, when it is necessary to disclose such information in regard to national security, when it is necessary to prevent physical harm or economic failure, or when there are ongoing investigations regarding fraud, illegal services or financial crimes.
6.6 We reserve the right to transfer your Personal Data to any relevant Third Parties in case of a reconstruction, merger, liquidation or sale of our organization.
7 INTERNATIONAL DATA TRANSFER
7.1 We do not transfer your Personal Data outside the EU or the European Economic Area (EEA) unless you have given your consent to the transfer, or there is sufficient protection in accordance with applicable law to make such a transfer. “The Privacy Shield Framework” provide such a mechanism to protect any Personal Data that may be transferred and stored in the US, as the companies connected to the Privacy Shield Framework shall comply with a level of data protection security that is approved by the EU. This is applicable in relation to any Personal Data that may be transferred and stored by our service provider Google.
8 YOUR LEGAL RIGHTS AND YOUR RIGHT TO ACCESS
8.1 You have certain legal rights regarding the Personal Data that we Process about you. These legal rights are listed below.
a) right to access – you have a right to know which Personal Data we are Processing about you, why we are Processing the data and for how long we will be storing it. In order to receive information about the Personal Data that we are Processing about you, you may contact us with a request of access. We have the right to decline a request that is harmful to another person’s personal integrity, is persistent or is in conflict with applicable law.
b) right to rectification – if any of the Personal Data that we store about you is inaccurate or incomplete, you can contact us and ask for it to be rectified or completed without undue delay.
c) right to withdraw consent – you have a right to withdraw a consent that you have given to us that allows us to Process your Personal Data for a specific purpose. If you withdraw your consent, we will stop Processing your Personal Data for that purpose. However, your right to withdraw your consent does not affect our right to Process the Personal Data that we have collected before your withdrawal if such Personal Data is necessary in order for us to fulfil a given specific purpose or a legal obligation.
d) right to object – if you believe that we are Processing your Personal Data wrongfully, you have a right to object to such Processing. You may object to a Processing that is legally based on a, for us, legitimate interest. If you object, we will make an assessment on whether we have the right to continue to Process your Personal Data or not. If you have given your consent to the Processing of your Personal Data, kindly observe that you cannot object to such Processing. Instead you need to withdraw your consent as stated above.
e) right to restriction – you have a right to request that we shall restrict the Processing of your Personal Data if you find that your data, or our Processing of it, is wrongful pursuant to applicable law. If we receive such a request, we will restrict our Processing to merely storing your Personal Data until we have made an assessment of our right to Process your Personal Data. If we wish to Process your Personal Data in any other way than storing it before the assessment is completed, we will need your consent for such Processing.
f) right to deletion – you have a right to request that we shall cease all Processing of your Personal Data and delete it from our systems. Unless we have a legal right to continually Process your Personal Data in order to fulfil a legal obligation or a legitimate interest, we will fulfil your request. Any Personal Data that we are allowed to continue to Process in accordance with applicable law, we will delete when the legal obligation or legitimate interest has been fulfilled.
g) right to data portability – you have a right to demand that we transfer your Personal Data to another Controller. We can help you with the transfer if your Personal Data is stored digitally and the transfer is technically possible. If we cannot make the transfer, you will nevertheless receive a copy of your Personal Data that you then can transfer on your own.
9 STORING OF YOUR PERSONAL DATA
9.1 We take reasonable steps to ensure that your Personal Data is not stored for longer periods of time than necessary in order to fulfil the purpose for which it is was collected or in order to fulfil our obligations in accordance with applicable law.
9.2 If the time that we will store your Personal Data can be explicitly stated when your data is collected, or if there are circumstances that will shorten or prolong the time described in section 9.1, you will receive additional information about this when your Personal Data is collected.
10 COOKIES AND OTHER TECHNOLOGIES THAT COLLECT INFORMATION
10.2 On our website we use the following cookies:
a) Session cookies – cookies that exchange information between your computer and a server in order to communicate what settings you use on the website. These cookies are not saved on your computer, instead they are deleted when you close your browser.
b) Statistical cookies – keeps statistics of how many visitors our website has received and how different pages has been visited on our website. These cookies only gather statistical data and not any Personal Data about you.
11 CONTACT DETAILS
11.2 If you feel like we cannot answer your questions or if you are not satisfied with how we are Processing your Personal Data, you may always file a complaint to the Swedish Data Protection Agency (sw. Datainspektionen).