Data Protection Policy

1. About the Processing of Your Personal Data
This data protection notice serves to inform you that Proflute (below “we”, “us” or “our”) will process personal data relating to you as a representative of your company who is a contact to us.

2. We are the data controller
Your privacy is important to us. Under the EU General Data Protection Regulation 2016/679 and associated and applicable EU legal acts, from time to time (below “EU Data Protection Law”), we are the ‘data controller’ in relation to you.
As the data controller, we determine the means and purposes of collection and use of your personal data and we are obliged to provide the individual whose personal data is being processed (you) with certain information about the processing. This notice serves as such information. This notice is not intended to replace any other separate or more detailed privacy notices or further information that we may provide you.

3. Sources of Personal Data
We will process personal data about you gathered from the following sources:
(1) Personal data that you provide (or have provided) to us, such as name, title, e-mail address and telephone number.
(2) Personal data that arise as a result of you or your company being customer or supplier to us, such as costumer or supplier number and delivery history.

4. Purpose and Legal Basis for the Processing of Your Personal Data
The processing of your personal data is necessary for us in order to pursue our legitimate interests of providing our services to your company and for internal administrative purposes within Proflute. Specifically, your personal data is processed for the following purposes: customer and supplier management, billing, delivery, advertising, information relating to our products, solutions and customer segmentation, which may e.g. lead to customized advertising and invitations.
If you do not provide your personal data we may not be able to properly fulfil our contractual obligations towards your company.

5. How Your Personal Data is Processed
For the above described purposes, your personal data will be collected, processed and transmitted electronically to us and other members of Proflute and our subcontractors inside or outside the EU. Other Proflute entities as well as subcontractors would for certain processing activities be processors to us. Such processing activities include customer and supplier relationship management, IT- services (such as operations and maintenance) and distribution of marketing and information material.
Appropriate technical and organizational measures and safeguards protect your personal data and all data processing operations handled by us. Such measures include traceability and access control and other suitable IT and information security measures in accordance with industry practice, as well as data processing agreements and other arrangements as appropriate ensuring protection of your rights as a data subject and ensuring that your personal data is only used for the purposes for which it is collected, as described above.
We will not disclose or share your personal data with any third party, except for other members of Proflute and our subcontractors. We may however need to disclose your personal data to relevant public authorities, if required by law.

6. Cross-border Data Transfers
Your personal data may be transferred across national borders for the purposes set out herein.
If and when personal data is transferred outside the European Union, we have taken appropriate technical and organizational measures to protect your privacy, including for example EU Standard Contractual Clauses (a copy of which can be obtained from us upon your written request, see contact details below), or other appropriate measures in accordance with EU Data Protection Law.

7. Retention Period
Your personal data will be stored for as long as necessary to meet the purposes described herein. This means that your personal data is generally stored for as long as you are a representative for your company who is a customer or supplier to us, unless otherwise required or permissible under EU Data Protection Law or local law. When your personal data is no longer necessary for us to retain for the purposes of the processing it will be deleted or rendered anonymous in such a manner that the data will no longer identify you.

8. Marketing Choices regarding your personal information
Proflute may send you marketing communications by email about products and services that we feel may be of interest to you. You can ‘opt-out’ of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself or you can update your preferences by using the contact us link.

9. Your Rights

As a data subject you have certain mandatory rights under EU Data Protection Law in regards to our processing of your personal data:
a) Right to access – You have the right to receive written confirmation as to whether or not personal data concerning you is being processed, and, if personal data is processed, access to the personal data.
b) Right to object – You have the right to object to our processing of your personal data, and we are then obliged to re-examine whether our legitimate interests to perform the processing still outweigh your interests and objection. If you object to processing for direct marketing purposes, we will no longer process your personal data for such purposes.
c) Right to rectification and restriction – You have the right to have inaccurate or incomplete personal data corrected and under certain circumstances, you have the right to request restriction of the processing.
d) Right of erasure – Under certain specific circumstances, e.g. your personal data is no longer necessary for the purposes set out herein; you have the right to request that your personal data is erased.
e) Right to lodge a complaint – If you believe that we illegally process your personal data, and if you are an EU citizen, you can lodge a complaint to the Swedish supervision authority, Datainspektionen.

10. When we need to update this policy
We will need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices.
A copy of the latest version of this policy will always be available on this page.

11. Contact Details
If you wish to exercise your mandatory rights under EU Data Protection Law, as set forth above, please send a written and duly signed request to Proflute AB, Box 1150, 164 26 Kista, Sweden.
If you have questions regarding the processing of your personal data under this notice, you can contact us at info@proflute.se