PRIVACY POLICY

It is important for us to safeguard the integrity of you as a current or potential customer, supplier, partner or representative/contact person of such, job seeker or visitor and that you are confident in how your personal data is processed. The following privacy policy describes how we process personal data about you.

About whom do we process personal data?

We process personal data about the following categories:

Customers, i.e. natural persons who are current or potential customers to us or representatives/contact persons of such.
Suppliers, i.e. natural persons who are current or potential suppliers to us or representatives/contact persons of such.
Partners, i.e. natural persons who are current or potential partners to us or representatives/contact persons of such.
Job seekers, i.e. natural persons who are potential employees or consultants.
Visitors, i.e. natural persons who contact us via e-mail or otherwise.

Where does the personal data come from?

We process data that you provide to us, that we collect from you and that we receive from third parties (e.g. publicly accessible sources, authorities, websites and marketing companies).

Purposes and legal basis for processing personal data

Customers, suppliers and partners

We process personal data about you as a current or potential customer, supplier, partner or representative/contact person of such, such as name, social security number, contact information, title, legal domicile and payment information, for the purpose of entering into and performing agreements and marketing. The information is used to, among other things, contact you, manage payments, and handle the issues relating to an agreement with you or the party you represent.

The legal basis for the processing of personal data of you as a current or potential customer, supplier or partner is that it is necessary for the performance of the agreement to which you are party or in order to take steps prior to entering into an agreement or that it is necessary

for our legitimate interests in marketing ourselves. The legal basis for the processing of personal data of you as a representative/contact person of a current or potential customer, supplier or partner of us is that it is necessary for the purposes of our legitimate interest of the performance of an agreement or enter into such or that it is necessary for our legitimate interests in marketing ourselves.

You are not legally obliged to provide us personal data. The provision of personal data is however required in order to enter into an agreement with us.

We may also process personal data about you as a customer, supplier or partner in order to fulfil legal obligations, for example regarding accounting and tax. The legal basis for this processing it that it is necessary for compliance with legal obligations to which we are subject.

Job seekers

We process personal data of job seekers such as name, contact information, personal identity number, job application, certificates, references and other application documentation for the purpose of the recruitment process and to evaluate whether we wish to employ you or hire you as a consultant, as applicable. We receive the data directly from you as the job seeker or from a recruitment agency. The legal basis for this processing is that it is necessary in order to take action at your request as a job seeker before entering into an employment or consultancy agreement and/or that the action is necessary to our legitimate interests in evaluating who we wish to employ. You are not obliged to provide the aforementioned personal data, but if you do not provide it, we may choose not to enter into an employment or consultancy agreement with you.

Visitors

In the event that you contact us we will process personal data about you, such as name, e-mail address, for the purpose of communicating with you or otherwise managing your case. The legal basis for this processing is that it is necessary in order to satisfy both your and our legitimate interests in communicating and managing your case.

When you visit our website we use cookies to ensure that the website works as intended, to review and keep statistics on visits and use of website and to give you as a visitor a good user experience. For more information,

see our cookie policy.

Who is the data controller?

Sealfx AB, Reg. No. 556969-9399, Box 11252, SE-100 61 Stockholm, Sweden is the data controller responsible for the processing of your personal data and that the processing is made in accordance with applicable data protection legislation. Our email address is info@sealfx.com and our telephone number is +46 (0)8 598 431 00.

Recipients of the personal data

We do not sell your personal data to third parties. We may share your personal data with data processors, which are companies that help us with our computer system, administration, marketing or recruiting, etc. These data processors process the personal data on our behalf. Your personal data may also be transferred to and processed by legal advisers, auditors and consultants. In addition, we may share your personal data with authorities if such processing is necessary for compliance with a legal obligation imposed on us. In such cases, the authority becomes the data controller responsible for the processing of your personal data. Other examples when we may share your personal data with third parties is when it is required due to law, dispute, your own request or when it is required to fulfil our legitimate interest. We, as a main rule, remain data controller for the personal data that is transferred while third parties, depending on the circumstances, either become independent data controllers, joint data controllers with us or our processors.

Transfer of personal data to third countries

We do not transfer your personal data outside the EU/EEA.

Storage

We never store personal data longer than necessary for the purposes of the process. We therefore regularly review stored personal data and delete personal data that is no longer needed.

We store personal data about you as a customer, supplier or partner as long as there is an active agreement. After the agreement has been terminated, we store personal data for as long as a legal claim can be made in connection with the agreement or to the extent that it is necessary to save the data in order to comply with legal requirements.

We store personal data of you as a potential customer, supplier or partner for as long as it is needed to manage the case and/or in order for us to defend or enforce our rights, however, for a maximum of three years. If you object to the processing, we will delete your personal data as soon as possible.

Personal data that we process about job seekers is saved for six months after an employment or consultancy process has been completed on condition that all our transactions have been completed and that there is no legal obligation for us to save the data for a longer period of time.

We store personal data of you as a visitor for as long as it is needed to manage your case and/or in order to defend or enforce our rights, however, for a maximum of three years. If you object to the processing, we will delete your personal data as soon as possible.

Swedish Authority for Privacy Protection

The Swedish Authority for Privacy Protection (Sw: Integritetsskyddsmyndigheten, IMY) is the competent supervisory authority responsible for supervision according to data protection legislation. You can contact the Authority for Privacy Protection for general information or if you wish to register a complaint related to the processing of your personal data.

Contact information to the Swedish Authority for Privacy Protection:

Integritetsskyddsmyndigheten

Box 8114

SE-104 20 Stockholm

Sweden

imy@imy.se

+46 (0)8 657 61 00

Changes to this privacy policy

This privacy policy was last updated in November 2022. We may from time to time make changes to the policy, in which case we will notify you about these with updates on our website (www.sealfx.com).

Your rights

As a registered data subject, you have several rights related to the processing of your personal data. If you wish to pursue them, please contact us by e-mail at info@sealfx.com or by telephone on +46 (0)8 598 431 00. Your rights are subject to certain specific conditions under applicable data protection legislation and can be summarized as follows.

As a registered data subject, you have the right to request information concerning which personal data we process and how it is processed. You also have the right to request a copy of the personal data that is processed.

As a registered data subject, you have the right to request that your personal data is rectified without undue delay if it is incorrect. You may also have the right to supplement any incomplete personal data.

As a registered data subject, you have the right to request that your personal data is erased without undue delay. This applies under certain conditions, for example if the personal data is no longer necessary for the purposes for which it is processed, or if you object to our legitimate interest assessment and there are no legitimate grounds for processing that outweigh your interests. You also have the right to request that the processing of your personal data is restricted.

As a registered data subject, you have the right to receive the personal data that you have provided to us and that we have processed in agreement with you. You also have the right to transmit or to have this personal data transmitted to another data controller. The personal data must be provided in a structured, commonly used and machine-readable format.

As a registered data subject, you have the right to object to your personal data being processed on the basis of a legitimate interest assessment. In such cases, we may only process the data if there are legitimate grounds for the processing that outweigh your legitimate interests.