Privacy policy for CuraTime AB

This Privacy Policy was updated on 2023-06-17.

Table of contents

  1. Background
  2. Definitions
  3. When do we Process your Personal Data?
  4. Data controller
  5. Why do we Process your Personal Data?
  6. What Personal Data is Processed and on what legal basis?
  7. Social platforms
  8. How long are your personal data stored?
  9. Your rights
  10. Consent to the Processing of Personal Data
  11. To whom do we transfer your Personal Data?
  12. How do we protect your Personal Data?
  13. Supervision and enforcement
  14. Third party conditions
  15. Amendment of the Personal Data Policy
  16. How do you get in touch with us?

Background

We care about your privacy and this policy (“Personal data policy“) has been designed to make you aware that CuraTime AB (“CuraTime“, “we“, “us“) processes your personal data in a lawful, appropriate and secure manner when you or the company or organization you represent request or purchase our services, visit our website or otherwise interact with us.

The Privacy Policy describes when, how and why we collect, use, disclose and store personal data and your rights under the provisions of the EU General Data Protection Regulation (“GDPR”)(EU) 2016/679 and its implementing and supplementary regulations on data protection (the “Data Protection Rules“).

Definitions

In this Personal Data Policy, the term “personal data” refers to information that can be attributed to an identified or identifiable natural person, for example name, address, social security number, email address, telephone number and IP address (“Personal Data“).

In this Privacy Policy we describe how we process your Personal Data. For example, the term “processing” means that we record, store, compile, transfer, erase and otherwise use your Personal Data in the manner described in this Privacy Policy (“Processing“).

When do we Process your Personal Data?

The Personal Data Policy is applicable in the following cases where Processing of Personal Data is involved in our activities:

  1. When CuraTime provides services to you or the company or organization you represent or work on behalf of;
  2. when sending out information, marketing or invitations to events;
  3. your participation in trainings, workshops, seminars and events held or organized by us or in cooperation with third parties;
  4. in connection with quality work, statistics, market and customer analysis and business development;
  5. in connection with visits to our website
    curatime.se
     (the “Website“) or via social platforms; and
  6. for inquiries or other contact with us by email or phone.

Data controller

CuraTime AB, org. no. 556932-6092, with address Merkuriusvägen 13, 352 64 Växjö is the data controller and is responsible for the Processing of Personal Data that takes place in accordance with this Personal Data Policy.

Why do we Process your Personal Data?

CuraTime processes Personal Data relating to representatives and other contact persons of our customers, our partners and suppliers, and representatives and other contact persons of potential customers. We only collect and Process Personal Data for specific purposes. This means that Personal Data is Processed in order to:

  1. provide services and otherwise perform the contract entered into with you personally, with the company or organization you represent or the company or organization you are working on behalf of;
  2. provide seminars, workshops and other events;
  3. enable general customer care (quality work, statistics, market and customer analysis, business and methodology development) and customer service, e.g. when you contact us by email, phone, social platforms or via the Website;
  4. inform and promote our business, including through the publication of customer references and other material on the Website, presentations at events or through brochures;
  5. provide information on events and news and target marketing via mail, email, phone or social platforms regarding our activities and services;
  6. preventing fraud and performing risk management; and
  7. comply with applicable legislation.

The Personal Data we collect about you depends, among other things, on (i) how you came into contact with us; and (ii) which of our services we provide to you or the company or organization you represent.

When you are asked to provide Personal Data to us, you can choose not to do so. In case you choose not to provide information necessary to access a particular service, we may not be able to provide our services and you will be informed accordingly.

What Personal Data is Processed and on what legal basis?

The Personal Data listed below is Processed by us for the purposes set out in section 5 above:

  1. First and last name;
  2. phone number;
  3. e-mail address;
  4. job title and place of work
  5. customer references;
  6. IP address and other information about how you interact with our Website; and
  7. correspondence with you.

The processing of Personal Data is necessary for CuraTime to provide its services. Where you are acting as a representative or contact person of a company or organization that is a customer, potential customer, supplier or other business partner of ours, we Process your Personal Data on the basis of our legitimate business interest. In this assessment, we have carried out a balance of interests where we have considered, among other things, that the Processing does not involve any sensitive Personal Data and that we have a clear business interest in being able to provide our services to you, the company or organization you work for or on behalf of in an efficient manner.

The processing of Personal Data is also necessary for CuraTime to be able to provide good service and customer care and thus satisfy our legitimate interest in developing the business and communicating with our contacts in an effective manner.

Personal data may also be Processed for other contact with you e.g. when sending out invitations to events, information about seminars, workshops and conferences, when providing offers of benefits or other information that we consider relevant to you or the company or organization you represent. We base this Processing on our legitimate business interest to be able to offer you who have an existing business relationship with us relevant marketing and information. In this assessment, we have carried out a balance of interests where we, among other things, considered that the Processing does not involve any sensitive Personal Data and that we have a clear business interest in being able to inform you about our services in an effective manner.

We may also Process your Personal Data after obtaining your consent, e.g. to this happens when you register for an event, when you declare a dietary preference/allergy, or when you consent to us publishing customer references on our Website or for other marketing purposes. Where we can no longer base the Processing of Personal Data for marketing purposes on our business interest, we may obtain your consent to, for example, send you marketing. We always document whether you have given your consent for us to Process your Personal Data.

Your Personal Data is also Processed, where applicable, in order for CuraTime to comply with legal obligations under applicable law, judgments or decisions of public authorities. Such requirements may, for example, relate to requirements arising from the Accounting Act (1999:1078).

How long are your personal data stored?

Your Personal Data is retained only for as long as it is necessary to retain it in order to fulfill the purposes for which the Personal Data was collected in accordance with this Privacy Policy. We Process your Personal Data as long as we have a business relationship with you, your employer or the company or organization you represent or work on behalf of.

If you have given your consent to the Processing of your Personal Data, we Process the Personal Data for that specific purpose until you withdraw your consent. You can do this by contacting us.

To enable CuraTime to fulfill its legal obligations under applicable law or to protect our legal interest, we may store the Personal Data for a longer period of time than stated above. However, personal data is never kept longer than necessary or required by law for the respective purpose.

Your rights

You have the right to receive information about the Processing of your Personal Data that we carry out. Below is a summary of the rights you can claim by contacting us. You can find our contact details at the end of this Privacy Policy.

Right of access

The main responsibility for the accuracy of the Personal Data we Process lies with CuraTime as data controller. If you notify us that the Personal Data you provided is no longer accurate, we will promptly correct, block or delete such Personal Data.

 

Right to erasure

You have the right to request that we delete 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 have withdrawn your consent and the Processing is based solely on consent as a legal basis;
  3. if the Processing is for direct marketing purposes and you object to the Processing of your Personal Data for this purpose;
  4. if you object to the Processing of Personal Data on the basis of 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 deletion 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 arise from applicable legislation in areas such as accounting. If certain Personal Data cannot be deleted due to applicable legislation, we will inform you of this and ensure that the Personal Data can only be used for the purpose of complying with such legal obligations and not for any other purpose.

Right to restriction

You have the right to request CuraTime to temporarily restrict the Processing of your Personal Data. Such a restriction can be requested in the following cases:

  1. that you believe that the Personal Data we hold about you is inaccurate and that you have requested rectification;
  2. when the Processing carried out on your Personal Data is not compliant with the Data Protection Rules, but you still do not want your Personal Data to be erased but rather restricted; and
  3. where we no longer need your Personal Data for the purposes of our Processing but where we need it to establish, exercise 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. When restricting your Personal Data, we will only store your Personal Data and obtain your consent for further Processing.

Right to data portability

You have the right, where we Process your Personal Data with your consent or to fulfill a contractual obligation with you, to require us to provide all Personal Data that we Process relating to you and that is Processed by automated means, in a machine-readable format. This can be, for example, an Excel file or a CSV file. Furthermore, if technically possible, you have the right to request that we transfer your Personal Data to another controller.

Right to object

You have the right to object to our Processing of your Personal Data if the Processing is based on our legitimate interest. In these cases, we 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 we have legitimate interests in the Processing and these outweigh your interests. We will also always inform you about this.

Consent to the Processing of Personal Data

If you have given consent to the Processing of your Personal Data, you decide if and when you want to withdraw your consent to the Processing of Personal Data to which you have voluntarily consented. You can do that by contaction us, see section 15. below.

To whom do we transfer your Personal Data?

To provide some of our services, we sometimes use various selected third parties. This means that we share some of the Personal Data we have collected about you with them, for example to partners such as IT service providers or printing and distribution providers. In connection with such sharing or transfer of your Personal Data, CuraTime takes technical and organizational measures to ensure that your Personal Data is handled in a safe and secure manner. These selected third parties will only Process your Personal Data in accordance with this Privacy Policy and to fulfill one or more of the purposes set out in this Privacy Policy. In cases where these suppliers are data processors for CuraTime, we are responsible to you that these third parties Process your Personal Data in a correct and lawful manner. In these cases, we also have agreements with the suppliers with instructions for Processing the Personal Data in accordance with the Data Protection Rules.

CuraTime may transfer your Personal Data to countries outside the EU/EEA, if any of our suppliers or partners are located there. In cases where CuraTime transfers Personal Data to a country outside the EU/EEA, CuraTime will take steps to ensure that the Personal Data continues to be protected by taking the necessary steps to lawfully transfer Personal Data to those countries, such as applying the European Commission’s agreed standard contractual clauses, which ensure that appropriate measures are taken to safeguard your rights and freedoms, or by ensuring that the country to which the Personal Data is transferred has an equivalent level of protection for your Personal Data.

For more information on how we ensure the protection of Personal Data transferred outside the EU/EEA, or to obtain a copy of the applicable contractual terms and conditions, please contact us.

We will also disclose your Personal Data if required by law, government or court order or if we, as a company, reasonably believe that disclosure is necessary to protect our rights.

CuraTime will not sell your Personal Data to third parties without your prior consent. However, CuraTime may transfer your Personal Data to a buyer/investor or potential buyer/investor in connection with a restructuring, sale or other transfer of all or part of CuraTime’s shares, assets or our business in general. Upon such transfer of your Personal Data, we will take steps to ensure that the receiving party Processes your Personal Data in a manner consistent with this Privacy Policy. The Personal Data that may be transferred under this paragraph depends on the documentation requested by a buyer/investor or potential buyer/investor. The Personal Data primarily subject to transfer under this paragraph are mainly your name, contact details such as telephone number and email address, and details of your employment such as the department you work in and your title. The purpose of such Processing is to allow a (potential) buyer/investor to conduct a review of CuraTime’s business and, where applicable, to take steps and preparations for a possible purchase or investment, where the transfer of your Personal Data is made with reference to CuraTime’s legitimate interest in enabling the conduct of such review, steps and preparations for an acquisition or restructuring process of CuraTime. If CuraTime ceases to exist, e.g. through a merger, liquidation or bankruptcy, CuraTime will delete your Personal Data as long as we do not need to keep it to comply with legal requirements. If CuraTime’s shares are acquired by a transferee company or if CuraTime is demerged in the context of a reorganization, CuraTime will continue to store and use your Personal Data under the terms of this Privacy Policy, unless you receive other information in connection with the transfer.

How do we protect your Personal Data?

To protect your privacy, detect, prevent and limit the risk of attacks, etc., CuraTime takes a range of technical and organizational information security measures. CuraTime also takes steps to protect your Personal Data from unauthorized access, misuse, disclosure, alteration and destruction. We ensure that access to your Personal Data is granted only to staff who need it for the performance of their duties and that they observe confidentiality.

Supervision and enforcement

If you are unhappy with the way your Personal Data has been Processed or consider that your Personal Data has been Processed in breach of the Data Protection rules, please contact us in the first instance. You also have the possibility to turn to the supervisory authority, currently the Integrity Protection Authority, and file a complaint. The contact details of the Authority can be found at www.imy.se.

CuraTime evaluates this Personal Data Policy annually.

Third party conditions

CuraTime’s services may in some cases be subject to third party terms and conditions. CuraTime is not responsible for the use of your Personal Data by such third parties as they are the sole data controller and responsible for the Processing of your Personal Data. It is therefore important that you consider and read the terms and conditions of third parties. This applies, for example, if there is a link on the Website that links to other websites.

Amendment of the Personal Data Policy

We reserve the right to amend this Privacy Policy when we deem it necessary. Such changes are required in particular in the event of any legislative changes, guidance statements or recommendations from the supervisory authority or other bodies issuing opinions in relation to the Data Protection Rules. Furthermore, this Personal Data Policy will be updated when necessary due to changes in our operations.

If CuraTime makes major changes to this Privacy Policy or changes to the way we Process your Personal Data, you will be informed before the change takes effect.

How do you get in touch with us?

If you have any questions in relation to this Personal Data Policy or the Processing of your Personal Data, wish to make a request in accordance with the Personal Data Policy or if you wish to report a breach of this Personal Data Policy, etc. you are welcome to contact us by e-mail, telephone or letter.

CuraTime AB
Merkuriusvägen 13
352 64 Växjö
E-mail:
anders.nasell@curatime.se
Tel. No: 0708-78 27 59