tretton37

Privacy Policy

  1. GENERAL

    1. This privacy policy (”Privacy Policy”), describes how tretton37 Development AB, registration number 556797-9306 with its principal place of business at Klostergatan 2 3tr, 222 22, Lund, Sweden (“tretton37”), collects, uses, discloses, stores and otherwise processes personal data.

    2. We respect your right to privacy, and we are committed to comply with applicable data protection rules and to safeguard your rights. This Privacy Policy describes, amongst other things, which information we collect about you, how your personal data is processed and for what purposes we collect and use the personal data. This Privacy Policy also describes your rights and how you can contact us about the use of your personal data.

    3. tretton37 is the data controller responsible for processing your personal data in accordance with applicable data protection legislation.

    4. Personal data means all types of information which can, directly or indirectly, be used to identify a living physical person (“Personal Data”).

    5. This Privacy Policy is layered and divided into sections based on the categories of data subjects, i.e. the individuals, whose Personal Data is processed by tretton37. Therefore, you only need to read the section that is relevant to you and which refers to the category that you belong to. The final sections 6 - 8 cover general provisions regarding protection of your data, your rights and contact details, and apply to all categories of data subjects.

  2. IF YOU ARE APPLYING FOR A JOB AT TRETTON37 OR IF YOU OTHERWISE ARE IN THE RECRUITMENT PROCESS WITH TRETTON37

    1. General

      This section 2 applies if you are applying for job at tretton37; either for an announced open position or by submitting an unsolicited application or if you otherwise are in a recruitment process with tretton37. Our recruiting processes start as soon as we get in contact with you. Therefore, it’s important for us to have the possibility to process and store your personal data to create the best possible experience during our recruitment process and afterwards. We welcome all applications and are curious about anyone wanting to join our team!

    2. What types of data do we process?

      We will process personal and contact information about you, which have been requested by us or submitted by you in writing or communicated orally. We will not collect any Personal Data about you from any third party, except as required to check your references or if you have referred to your LinkedIn profile, GitHub profile, personal blog or similar. The personal and contact information consists of name, date of birth, address (incl. e-mail address), telephone number, current work position (if applicable), meeting notes, CV (including photo if you have included your photo on the CV), personal letters, grades, certificates, portfolios, email correspondence and any other materials sent to us during the recruitment process. At this stage, we do not require you to submit any sensitive data, such as Personal Data regarding health or trade union membership and should you voluntary submit such data to us, we reserve the right to delete such Personal Data and ask you to resubmit it to us should you proceed in the recruitment process.

    3. Why do we process your data?

      tretton37 processes Personal Data relating to you in order to assess your job application, to determine whether we would like to offer you a position at tretton37 and to stay in contact with you for any offers in the future.

    4. The legal grounds for processing the Personal Data
      1. Application for an announced open position or if you proceed to a job interview The legal basis for processing Personal Data which we receive in relation to a recruitment process regarding an announced open position, or if you proceed to a job interview following an unsolicited application, is that the processing is necessary in order to take steps prior to entering into a (employment) contract with you.

      2. Unsolicited application and Personal Data stored for future recruitment processes The legal basis for processing Personal Data which we receive through an unsolicited application where we currently do not have any open positions to offer, or which we store after a completed recruitment process (regarding a position which has been assigned to another applicant) is the consent given by you to such processing.

    5. For how long do we store your Personal Data?
      1. Your data will be stored for as long as the recruitment process is ongoing and thereafter for a following period of two years, during which tretton37 will retain the Personal Data for the defense of any legal claims.

      2. If our processing of Personal Data is based on your consent, we will retain your Personal Data until you withdraw your consent. However, we will under all circumstances delete your Personal Data if the purpose behind our processing of the data ceases.

    6. How may the data be shared?
      1. Only those of tretton37’s employees and, if applicable, external recruiters who are directly involved in a relevant recruitment process will have access to your Personal Data. Further, certain service providers of tretton37, incl. providers of IT-systems, may be given access to your Personal Data. tretton37 may engage a data processor for processing of Personal Data on behalf of tretton37. tretton37 is responsible for ensuring that the data processor’s processing complies with the legal requirements applicable to the processing.

      2. tretton37 will not sell, trade or lease your Personal Data to third parties.

      3. tretton37 will not transfer your Personal Data to any country outside the EU/EEA, unless we have ensured that such transfer is lawful and subject to appropriate safeguards, such as the Privacy Shield or standard data protection clauses adopted by the Commission.

      4. Personal Data may be disclosed by tretton37 to comply with legal requirements or other requirements from official authorities, in order to safeguard tretton37’s legal interests or to detect, prevent, or draw attention to frauds or other safety or technical problems

  3. IF YOU REPRESENT A COMPANY THAT HAS A CONTRACTUAL RELATIONSHIP WITH TRETTON37 OR OTHERWISE IS IN CONTACT WITH TRETTON37

    1. General

      This section 3 applies if you are an employee of or otherwise represent a company that tretton37 has an ongoing contractual relationship with, or that tretton37 has established contact with for discussing the possibilities of such contractual relationship or for other purpose.

    2. What types of data do we process?

      We collect and process the following Personal Data about you: (i) contact details, i.e. name, e-mail address, phone number, (ii) employment details, i.e. employer, job title, job street address, and (iii) other data that you intentionally share, e.g. information about you that you voluntarily submit to us in free text fields or share in other contexts.

    3. Why do we process your data?

      We process your Personal Data for the following purposes:

      1. to send notifications or messages to you which are related to an agreement between your company and tretton37.

      2. to be able to otherwise execute, maintain and perform our obligations under an agreement with your company

      3. to discuss any future contractual relationship between your company and tretton37

      4. to provide you with information about tretton37’s products, solutions and/or services or to invite you to activities or events.

    4. The legal grounds for processing the Personal Data

      As applicable, the processing referred to under section 3.3 is made on the basis of our legitimate interest to:

      1. uphold, maintain and administrate a contractual relationship that we have with your company;

      2. sustain the partnership with your company and to provide your company with relevant product, solution and service offerings; and

      3. market, promote and demonstrate our business, products, solutions, services, events and similar.

    5. For how long do we store your Personal Data?
      1. If your company has a contractual relationship with us, we will store your Personal Data in our database until the contractual relationship with your company ceases and for a limited time thereafter (not exceeding five years). However, your Personal Data will (if included in the contract text) continue to be processed as a part of the contract text, as long as the contract is retained for the purpose of safeguarding tretton37’s legal interests.

      2. If we have discussions with your company but such discussions do not result in that any contract is concluded, we will delete your Personal Data from our databases when it is no longer needed for the said discussions.

      3. If we have not commenced any discussions with your company but are interested in providing your company with marketing material and other information about our business, products, solutions, events etc., we will process your Personal Data during such time as is necessary (in our reasonable opinion) to promote our business and get you hooked, whereafter we will delete the data (as long as no discussions regarding a future cooperation have been initiated). Further, we will delete your Personal Data processed for direct marketing purposes if you object to processing for such purposes.

    6. How may the data be shared?
      1. tretton37 may share your Personal Data with our trusted subcontractors to the extent necessary for the performance of the contract we have entered into with your company. They may need access to the Personal Data in their assignment for us, but they will not be allowed to use the Personal Data for any other purpose. Further, certain service providers of tretton37, incl. providers of IT-systems, may be given access to your Personal Data. tretton37 may engage a data processor for processing of Personal Data on behalf of tretton37. tretton37 is responsible for ensuring that the data processor’s processing complies with the legal requirements applicable to the processing.

      2. tretton37 will not sell, trade or lease your Personal Data to third parties.

      3. tretton37 will not transfer your Personal Data to any country outside the EU/EEA, unless we have ensured that such transfer is lawful and subject to appropriate safeguards, such as the Privacy Shield or standard data protection clauses adopted by the Commission.

      4. Personal Data may be disclosed by tretton37 to comply with legal requirements or other requirements from official authorities, in order to safeguard tretton37’s legal interests or to detect, prevent, or draw attention to frauds or other safety or technical problems.

  4. IF YOU ARE IN CONTACT WITH TRETTON37 AS A PRIVATE INDIVIDUAL

    1. General

      This section 4 applies if you are in contact with tretton37 as a private individual, regarding our events, conferences or similar.

    2. What types of data do we process?
      1. We process Personal Data of you in the form of name, e-mail address and pictures taken at the events, conferences or similar which you attend.

      2. For some events and conferences, we may offer an “opt-out” badge from being photographed. If you wear one of those badges, we will not process any Personal Data in the form of pictures of you.

    3. Why do we process your data?

      We process your name and e-mail address in order to be able to invite you to and administer your registration for events, conferences or similar arranged by us. Pictures of you is used in order to market and otherwise inform about our business, products, solutions, services, events and similar. Pictures may be published on our website and on our social media accounts.

    4. The legal grounds for processing the Personal Data

      The legal basis for processing your name and e-mail address and pictures of you is our legitimate interest to inform about our business.

    5. For how long do we store your Personal Data?
      1. We will delete your name and e-mail address when the relevant event has taken place.

      2. Pictures of you will be stored and continued to be processed as part of our marketing materials. However, we will under all circumstances delete the pictures of you if our purpose behind the processing of the pictures ceases.

    6. How may the data be shared?
      1. Certain service providers of tretton37, including providers of-IT systems, may be given access to your Personal Data. tretton37 may engage a data processor for processing of Personal Data on behalf of tretton37. tretton37 is responsible for ensuring that the data processor’s processing complies with the legal requirements applicable to the processing.

      2. Since the pictures of you will be used in order to market and otherwise inform about our business, products, solutions, services, events and similar, the pictures may be shared with the receivers of the marketing material or other information.

      3. tretton37 will not sell, trade or lease your Personal Data to third parties.

      4. tretton37 will not transfer your Personal Data to any country outside the EU/EEA, unless we have ensured that such transfer is lawful and subject to appropriate safeguards, such as the Privacy Shield or standard data protection clauses adopted by the Commission.

      5. Personal Data may be disclosed by tretton37 to comply with legal requirements or other requirements from official authorities, in order to safeguard tretton37’s legal interests or to detect, prevent, or draw attention to frauds or other safety or technical problems.

  5. IF YOU SEND E-MAILS TO US

    1. General

      This section 5 applies if you, either as a private individual or as a representative of your company, have sent e-mails to an employee or other representative of tretton37.

    2. What types of data do we process?

      We collect Personal Data in the form of your name, e-mail address and other information which you voluntarily share in e-mails that you send to us.

    3. How do we process Personal Data received in an e-mail?

      Upon our receipt of an e-mail, we will consider whether we have any reason and legal ground pursuant to section 2, 3 or 4 above to store or otherwise continue to process the received Personal Data. If we determine that such reason and legal ground exist, we will continue to process the received Personal Data in accordance with section 2, 3 or 4, as applicable. Otherwise, we will delete the Personal Data received through the e-mail.

  6. PROTECTION OF YOUR PERSONAL DATA

    1. You should always feel secure when you provide your Personal Data to us. We have employed a wide range of security measures to help protect your Personal Data against undue access, modification and deletion.

    2. We protect your Personal Data using commercially reasonable safeguards to prevent loss, misuse, unauthorized access, disclosure, alteration, and destruction. These measures include data encryption, firewalls and multifactor authentication. Therefore, you can rest assure that your Personal Data is in safe hands.

  7. YOUR RIGHTS

    1. Access, Corrections

      You are always entitled to ask us whether we process any of your Personal Data, and if so, access a copy of such Personal Data. Further, you have the right to request that we correct or update your Personal Data if something is wrong or missing.

    2. Deletion, Restriction of use and data portability

      Under certain circumstances (expressed in applicable data protection legislation), you may request that tretton37 restricts the use of your Personal Data or delete your Personal Data. If you have provided us with Personal Data, you also have the right to have your Personal Data resubmitted to you, in a structured and accessible format, for transfer to another user/processor.

    3. Withdrawal of consent

      If tretton37 processes Personal Data based on your consent, you have the right to withdraw the consent at any time through a written notice sent to tretton37.

    4. Requests and Complaints
      1. If you wish to exercise any of the abovementioned rights or if you have any questions regarding Personal Data held by us or this Privacy Policy, please do not hesitate to contact us (for contact information, please see section 8 below).

      2. Should you be dissatisfied with our processing of your Personal Data, please let us know, and we will do our best to meet your complaints. Your integrity is very important to us, and we always strive to protect and secure your Personal Data in the best possible way. Should we nevertheless, in your opinion, fail in this ambition, please note that you are also entitled to lodge a complaint with the Swedish Data Protection Authority (Sw. Datainspektionen), or such other authority as may be determined in the future.

  8. HOW TO CONTACT US

    You can contact us at: tretton37 AB, Klostergatan 2 3tr, 222 22, Lund Sweden, or at our e-mail: gdpr@tretton37.com