Privacy policy
1. GENERAL
1.1. This privacy policy (the “Privacy Policy”) always applies, unless otherwise agreed in writing, in regard to processing, performed by Econans AB, reg.no 559113-0553, (“Econans”), of Personal Data relating to a natural person (a “Data Subject”). The Privacy Policy applies to all websites, services, and online applications that are owned, controlled or hosted by Econans (together the “Services”).
1.2. “Personal Data” means any information relating to an identified or identifiable natural person, whereupon an identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data or online identifiers, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
1.3. Econans may either process Personal Data on its own behalf, as data controller, or as data processor on the behalf of one of the customers of Econans’ Services (each a “Data Controller”), in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the Processing of Personal Data and on the free movement of such data (GDPR). All processing of Personal Data on behalf of a Data Controller is made in accordance with a data processing agreement between Econans and such Data Controller, as well as in accordance with any instructions given by such Data Controller. For any questions regarding such processing, or the Data Subjects rights in relation to such processing, the Data Subject is primarily referred to review the privacy policy of such Data Controller or contact the Data Controller directly.
1.4. This Privacy Policy serves to assure the Data Subject that Econans processes the Data Subject's Personal Data in accordance with applicable privacy laws and regulations. Below follows a description of how Econans processes the Data Subject's Personal Data. Information is also given regarding the Data Subject’s rights, and how the Data Subject can get in contact with Econans in case the Data Subject has any questions or wants to exercise his or her rights.
1.5. Should Econans have to change this Privacy Policy, the Data Subject will be informed through announcements on Econans’ website or via email. The Data Subject is encouraged to revisit the Privacy Policy from time to time to stay updated on Econans’ processing of Personal Data.
2. COLLECTION OF PERSONAL DATA
2.1. The Services may be used to collect various data such as, but not limited to, browser data and settings (language, browser version, browser type, header referrer, page data), device information (pixel ratio, mobile detection), browser plugins (blocked third party cookies, user agent, version, local storage), performance information (load time, collect time, pixel load time, domain lookup time, connect time).
2.2. When signing up for the Services, or visiting a website that uses the Services, the Data Subject may be asked to provide contact information, such as the Data Subject’s name, e-mail, company affiliation, company address, home address, phone number or other information about the Data Subject or its employer.
2.3. Information regarding transactions, both free and paid, that the Data Subject activate through the Services may be collected by Econans. Payment information can include information about payment method, credit card numbers and purchase information.
2.4. Econans may collect information that can be linked to a computer and the Data Subject’s visits to domains or services, such as IP-address, geographical position, browser type, URL, time stamps and pages that have been visited, domain name, ISP, what files have been seen on the domain (HTML-pages, images, etc.), operation system, click-stream data, time stamps and referring web pages.
2.5. Econans may also collect information about the Data Subject from third party sources, such as Facebook, LinkedIn, Twitter or Google, or public information about the Data Subject that can be obtained through other third party suppliers.
3. PURPOSE AND LEGAL BASIS FOR THE PROCESSING
3.1. The purpose of processing the Personal Data is to enable Econans to offer the Services in full, provide information about the Services and market the Services. Econans also processes the Personal Data to:
a)improve the Data Subjects experience of online content through personalization of websites and applications;
b)send information to the Data Subject with content Econans believe may be relevant for the Data Subject, by mail, e-mail or by other ways of marketing;
c)market the Services and share marketing and information in accordance with the Data Subject’s preferences;
d)provide other companies with aggregated or statistical information, but only in forms that does not allow for the Data Subject to be identified as an individual;
e)send information to the Data Subject about changes to Econans’ terms of service, this Privacy Policy, Econans’ cookie policy, or other legal documents;
f)meet legal requirements from government authorities, local or national, or other parties authorized to make such demands;
g)prevent or obstruct security- and tech problems;
h)respond to the Data Subject’s support questions and issues; and
i)fulfill the obligations to the Data Subject.
3.2. Econans may use geographical information in order to manage and improve the Services. Econans may also use geographical information alone or in combination with other personal Data in order to provide a personalized experience of the Services.
3.3. Econans may publish customer reviews and comments in Econans’ digital channels and marketing materials (website, applications, social media, sales documents, etc.) that may contain Personal Data.
3.4. Payment data will only be processed in order to investigate the Data Subject’s financial status and charge the Data Subject for the Services. The payment information may be processed by third party payment providers for no other purposes than processing the Data Subject’s payments on Econans’ behalf.
3.5. The collection and processing of the Data Subject's Personal Data is conducted solely with the Data Subject's consent or on the premise of an existing agreement or legal obligation, e.g. when Econans must save the data according to accounting rules. Exceptions are made for cases where a prior consent is not possible for practical reasons, the processing of the data is permitted by law, and Econans has a legitimate interest in processing the Personal Data, e.g. for marketing, follow-up of the Services, or for exercising or defending Econans against legal claims, according to a so called balance of interests.
3.6. When processing Personal Data on behalf of a Data Controller, the Data Controller is responsible shall ensure that appropriate legal basis for the processing are obtained in accordance with the data processing agreement between Econans and the Data Controller.
4. COOKIES
4.1. Econans may use cookies and similar technologies to analyze and administrate the Services. Econans may also track user behavior through cookies in the Services and enrich them with information from third parties. Additional information regarding cookies can be found in Econans’ cookie policy found here.
5. SENSITIVE PERSONAL DATA AND PERSONAL DATA ABOUT MINORS
5.1. Sensitive Personal Data refers to data which reveals a Data Subject’s ethnic origin, political opinions, religious beliefs or membership of the trade union, as well as Personal Data relating to health or sex life.
5.2. Econans does not collect or store any sensitive Personal Data or Personal Data regarding minors (i.e. Data Subjects under the age of 18). Econans further disallows Data Controllers from uploading sensitive Personal Data or Personal Data regarding minors to the Services, and undertakes to investigate and remedy any unsanctioned processing of sensitive Personal Data or Personal Data regarding minors within the Services.
6. STORING OF PERSONAL DATA
6.1. The Data Subject's Personal Data is stored in Econans’ own database, but may also be stored locally on device that the Data Subject uses to access the Services. The database is stored on an external server provided by Econans’ Personal Data processor in the EU/EEA, specifically at [ange server host och plats].
6.2. The Data Subject's Personal Data will not be stored for any longer than necessary, with regards to the purpose of the processing and taking into account Econans’ eventual legal obligations regarding to accounting regulations etc. If certain Registration Data is not provided, Econans’ legal obligations cannot be fulfilled and Econans can therefore be forced to deny the Data Subject access to the Services.
6.3. Econans regularly deletes all Personal Data which is no longer needed with regards to the purpose of the processing, in accordance with the relevant laws and regulations in force at any time.
7. SHARING OF PERSONAL DATA TO THIRD PARTIES
7.1. Without the Data Subject's explicit permission, Econans will not share the Data Subject's Personal Data with any third party in any other way than what follows from this Privacy Policy, unless Econans is obliged to do so following the applicable regulations or unless the Personal Data is shared in connection with an ongoing legal-, administrative- or recovery procedure in which the Data Subject and Econans are both parties.
7.2. Econans uses subcontractors for services in connection with Econans’ Services (“Data Processors”). These Data Processors may handle Personal Data and may need some access to Personal Data collected through the Services. Econans may also need to use the Data Processor’s to store Personal Data. Econans will always limit such Data Processors’ access to Personal Data to the minimal amount needed for Econans to still be able to offer the Services. Econans also requires all Data Processors s to (i) protect the Data Subject's Personal Data in accordance with this Privacy Policy and (ii) not use or disclose the Data Subject's Personal Data for any purpose other than to provide the agreed upon services to Econans, enabling Econans to offer the Services. These Data Processors may only process the Data Subject's Personal Data in accordance with Econans’ instructions and may not use the Data Subject's Personal Data for any other purpose. The following Data Processors might be involved in the processing of Personal Data: [t.ex. Microsoft Azure, Amazon Web Services, Google Cloud Web etc.].
7.3. Econans may share Personal Data and information with additional Data Processors based on a request from the Data Subject as part of a service or add-on product.
7.4. Econans may also share information with additional Data Processors for the following purposes: analytics, support, data enrichment or marketing.
7.5. Should Econans, or the assets Econans control, be acquired by another company, e.g. through a merger, acquisition, bankruptcy or similar event, such company will also acquire access to all information that Econans gathered through the Services. In such case, the Data Subject will be notified of this, through e-mail or a clear notification in the Services.
7.6. Econans reserves the right to disclose Personal Data if required by law or if Econans reasonably believe that disclosure is necessary to protect Econans’ rights, protect the safety of the Data Subject or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
8. TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES
Econans will not transfer Personal Data to third countries (i.e. countries outside the EU/EEA). Should Econans need to do so in the future, inter alia due to Econans choosing a digital service provider based in a third country, Econans will only transfer Personal Data if the third country has an adequate level of protection according to applicable privacy laws and regulations.
9. THE RIGHT TO REQUEST INFORMATION
9.1. The Data Subject has a right to request and obtain, free of charge, information regarding what Personal Data (if any) that is being processed by Econans, a so-called register extract. The Data Subject also has the right have any incorrect Personal Data corrected. If the Data Subject wishes to know if Econans processes any Personal Data about the Data Subject, he or she can send a written and signed request to Econans in accordance with section 17 below. In the request, the Data Subject needs to indicate specifically what kind of information the Data Subject is interested in receiving (unless the Data Subject is interested in receiving information about all Personal Data). That way, Econans can provide the Data Subject with information that is relevant. If the Data Subject repeatedly sends requests for an extract from the register, Econans may charge a fee or, in some cases, in accordance with statutory law, refuse to comply with the request.
9.2. The extract from the register will be sent to the Data Subject within 30 days from the time Econans received the request. If the extract is extensive and Econans needs more time or if Econans for some reason cannot comply with the Data Subject’s request, Econans will without undue delay notify the Data Subject thereof.
10. THE RIGHT TO RECTIFICATION
10.1. In order to fulfill its obligations to always have accurate and relevant Personal Data, Econans systematically works with its registers and updates Personal Data where necessary. If the Data Subject notices that the Personal Data Econans processes is incorrect or if Econans lacks important Personal Data, the Data Subject has the right to have their Personal Data corrected. Econans normally performs simple data corrections without consideration but in some cases Econans may need to consider the Data Subject's request. Econans will not approve the Data Subject's request if it is impossible or requires an unreasonable amount of work. Upon a request by the Data Subject, Econans will inform the Data Subject about whom the correction has been submitted to.
10.2. In the event that the Data Subject's Personal Data is changed at the Data Subject's request, Econans will inform any subcontractors and partners that processes the Personal Data about the change.
11. THE RIGHT TO ERASURE
11.1. The Data Subject has the right to request that Econans erases the Data Subject's Personal Data when:
a) they are no longer needed for the purposes for which they have been collected and for which they are being processed;
b) Econans processes Personal Data under the Data Subject's consent and the Data Subject withdraws said consent;
c) Econans processes Personal Data for direct marketing and the Data Subject opposes the continued processing for this purpose;
d) Econans processes Personal Data on the legal basis of a balance of interests and there are no legitimate interests that weigh heavier than the Data Subject's interest;
e) Econans does not process Personal Data in accordance with applicable rules;
f) It is required that Personal Data is erased in order to fulfill a legal obligation; or
g) there is another relevant legal basis for the Data Subjects request to erase the Personal Data.
11.2. Econans has the right to refrain from erasing the Data Subject's Personal Data if Econans needs to retain these in order to fulfill a legal obligation or to be able to make legal claims against the Data Subject or in defense against legal claims from the Data Subject.
11.3. When Econans receives the Data Subject’s request regarding erasure, Econans will conduct an assessment in order to evaluate if there are reasons to erase the Data Subject’s Personal Data. The Data Subject will then be informed about Econans’ assessment. If the Data Subject’s Personal Data are erased at the Data Subject’s request, Econans will inform potential suppliers and third-party partners to which Personal Data has been transferred that the Personal Data has been erased. However, Econans will not do this if it is impossible or requires an extensive amount of work.
12. THE RIGHT TO RESTRICTION OF PROCESSING
12.1. The Data Subject has the right to request the restriction of Econans’ processing of the Data Subject's Personal Data when:
a) the Data Subject has disputed the accuracy of the Personal Data, during the time Econans has the opportunity to check whether the Personal Data are correct;
b) the processing is illegal, and the Data Subject opposes that the Personal Data is deleted and instead requests a limitation of its processing;
c) Econans no longer needs the Personal Data for the purposes of the processing, but the Data Subject needs the Personal Data to be able to determine, enforce or defend legal claims; or
d) the Data Subject has objected to processing in accordance with this Privacy Policy, when awaiting information of the legitimacy of whether Econans’ interests weigh heavier in relation to the interests of the Data Subject.
12.2. Restriction of processing implies that the Personal Data will be marked, so that they in the future may only be processed for certain limited purposes.
13. DELETION OF PERSONAL DATA
13.1. The Personal Data will not be retained for any longer than is necessary with regard to the purposes of the processing, and Econans will otherwise delete Personal Data in the manner that follows from applicable legislation, where an examination is made on a case-by-case basis when different types of Personal Data should be culled.
13.2. If the Data Subject requests that the Data Subject’s Personal Data shall be deleted, Econans will delete or de-identify the Personal Data no later than 30 days from the reception of the request. This is provided that the Personal Data is not required to be saved in the future in order for Econans to fulfill its legal obligations or to be able to exercise its legal claims.
14. THE RIGHT TO WITHDRAW CONSENT AND OBJECT TO PROCESSING
14.1. The Data Subject has the right to object to Econans’ processing of the Data Subject's Personal Data which Econans conducts with the support of so-called balancing of interests according to law. If the Data Subject wishes to exercise this right, the Data Subject needs to specify in writing which processing the Data Subject objects to. In the event of such an objection, Econans may only continue to process the Data Subject’s Personal Data if Econans can show that there are compelling and entitling reasons for why the Personal Data must be processed, and provided such reasons weigh heavier than the Data Subject's interests.
14.2. If the Data Subject's Personal Data is processed for direct marketing, the Data Subject always has the right to object to the processing at any time.
15. THE RIGHT TO DATA PORTABILITY
If the Data Subject has provided his or her Personal Data to Econans, the Data Subject may, in some cases, be entitled to extract his or her Personal Data in order to, for example, move them to another company. In order for the Data Subject to be able to use his or her right to so called data portability, the Data Subject's request must relate to Personal Data that the Data Subject himself/herself has provided to Econans and which Econans processes with the consent of the Data Subject or to fulfill an agreement with the Data Subject. The right to data portability does not apply when Econans’ processing of the Data Subject's Personal Data is based on a balance of interests or a legal obligation for Econans. The right to data portability does not apply when data portability is technically difficult to implement.
16. THE RIGHT TO COMPLAIN
In the event that the Data Subject has complaints or objections in connection with Econans’ Processing of the Data Subject's Personal Data, Econans kindly asks the Data Subject to initially contact Econans, so that Econans can help the Data Subject in the best way possible. However, the Data Subject always has the right to submit his or her complaints directly to the relevant Data Protection Authority, e.g. Datainspektionen in Sweden.
17. SECURITY
Econans undertakes all appropriate technical and organizational security measures, that are required in accordance with applicable regulatory frameworks governing the processing of Personal Data, to ensure a high level of security appropriate to the risks and to protect the Personal Data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to processed Personal Data, such as storing the Personal Data on servers in protected environments, protected from unauthorized access.
18. CONTACT INFORMATION
18.1. The Data Subject may contact Econans, to enquire about Econans’ Processing of Personal Data or exercise the Data Subjects rights under this Privacy Policy, by e-mail to hello@econans.se or by written letter to Econans AB, Kyrkogatan 20-22, 411 15 Gothenburg, Sweden, Att: DPO. Econans undertakes to respond to any enquiry or request within reasonable time and in accordance with at all time relevant legislation.