Last updated: 20190415
TABLE OF CONTENTS
- About this policy
- Collection of information and personal data
- Our use of personal data
- Data retention
- Sharing and disclosing information
AB Leverache (“ABL”, “we”, “us”, “our”), a company incorporated under the laws of Sweden, provides the Inex One Expert Management System (the “EMS”), a software as a service (SaaS) platform for procurement and administration of expert calls and related services. It also provides a website, https://inex.one, hereinafter referred to as the “Site” (collectively, the “Services”).
ABOUT THIS POLICY
A separate agreement governs delivery, access and use of the EMS (the “Agreement”), including the processing of any data and other information that the customer or expert network, including individuals granted access to the EMS by customers or expert networks (“Users”), transfers or makes accessible to ABL through the EMS (“Customer Data” or “Expert Network Data”).
In general, the Customer and/or the Expert Network is the controller of Customer Data and Expert Network Data. ABL is the data processor of Customer Data and Expert Network Data and will only process it in accordance with the data controller’s written instructions, the relevant data processing agreement and applicable law.
In general, ABL is the controller of Other Information (as defined in Section 2 of this policy).
COLLECTION OF INFORMATION AND PERSONAL DATA
We will receive and collect information and personal data from you and from third parties when you are using the Services.
- CUSTOMER DATA AND EXPERT NETWORK DATA
1.1. Customers, Expert Networks or Users may submit Customer Data and Expert Network Data to ABL when using the EMS, and ABL will process such data on behalf of the Customer or the Expert Network.
1.2. The categories of personal data that are submitted may include, but are not limited to:
(a) Any messages, files or other content submitted through the EMS, such as information regarding an expert, relevant expertise and career history, name and LinkedIn profile URL.
- OTHER INFORMATION
In addition to Customer Data and Expert Network Data, ABL collects and/or receives other information, data and personal data (“Other Information”) in a variety of ways during the course of providing the Services.
The different types of Other Information are listed below:
2.1. USER ACCOUNT INFORMATION
2.1.1. ABL may collect and/or receive Other Information when you set up an account or invite a new User to join the EMS.
2.1.2. The categories of personal data that are collected and/or received when setting up an account or inviting a User to the EMS may include:
(a) Name, email address, telephone number, title, and employer (company name).
(b) Additional data if you hold an EMS account relating to a customer (client): location, business unit, and title.
2.2. ADDITIONAL CONTACT INFORMATION
2.2.1. You may choose to share your personal data with us if you contact us. We might also receive Other Information when submitted to the Site if you subscribe to our newsletter, apply for a job, request support, interact with our social media accounts or otherwise communicate with ABL.
2.2.2. The categories of personal data that are collected when you contact us may include, but are not limited to:
(c) Name, email address, telephone number, title, employer, postal address, CV, and images.
2.3. USAGE INFORMATION & COOKIE INFORMATION
2.3.1. When you are using the Services, ABL may collect Other Information to help us develop the Services and improve your user experience.
2.3.2. The categories of personal data that are collected when you use the Services may include, but are not limited to:
(a) Device information: ABL collects information about the device you use to access the Services, including type of device and what operating system is used.
(c) Log data: Our servers will automatically collect information when you access the Services and record it into log files. This log data may include you Internet Protocol (IP) address, browser type and settings, the date and time the Services were used, information about browser configuration and cookie data.
(d) How you use the EMS: We will collect information on how you use the EMS, such as information regarding how often you visit the EMS, which pages you visit on the EMS, links clicked and mouse movements.
(e) Site Analytics: The Site uses Google Analytics as a web statistics tool, however, not to track individual users. For further information on how Google Analytics collects and uses information on our behalf and the right to use such cookies, please refer to the Google Analytics products and services privacy statement.
OUR USE OF PERSONAL DATA
- HOW WE USE INFORMATION
3.1. Customer Data will be used by ABL in accordance with customer’s instructions, and Expert Network Data will be used by ABL in accordance with expert network’s instructions, including any applicable terms in the Agreement. The customer and the expert network are separate and independent controllers of the Customer Data and the Expert Network Data, and ABL is a processor.
3.2. Other Information (as listed in Section 2.) is used in ABL’s legitimate interest to provide Services. More specifically, ABL uses Other Information:
(a) To provide, update, maintain and protect our Services.
(b) To prevent, investigate or address security or technical issues.
(c) To analyze and monitor usage of the Services.
(d) To provide customer support.
(e) To ensure that content is presented in the most effective manner for you and for your device.
(f) To communicate with Users around tech, security and admin related matters
(g) For billing, account management and other administrative matters.
- HOW LONG WE KEEP INFORMATION FOR
4.1. ABL will retain Customer Data in accordance with Customer’s instructions, including any applicable terms in the Agreement, and as required by applicable law.
4.2. ABL will retain Expert Network Data in accordance with Expert Network’s instructions, including any applicable terms in the Agreement, and as required by applicable law.
SHARING AND DISCLOSING INFORMATION
- HOW WE SHARE INFORMATION
5.1. ABL will only share and disclose Customer Data or Expert Network Data in accordance with Customer’s or Expert Network’s instructions, and as required by applicable law.
5.2. Administrator Users and other Customer or Expert Network representatives and personnel may be able to access, modify or restrict access to Other Information, for example by modifying an account details.
5.3. We may engage third party companies or individuals as service providers to support delivery of our Services. Additional information about which subprocessors we use can be found at ABL Subprocessors.
5.4. You may subscribe to notifications of new subprocessors on this site https://inex.one/sub-processor-notification.
5.5. We may disclose necessary personal data to authorities such as the police, tax agencies or other authorities if we are required by law or you have agreed to it. An example of legally required sharing is for the purposes of anti-money laundering and counter-terrorist financing.
- INTERNATIONAL DATA TRANSFER
6.1. ABL may transfer Personal Data to subprocessors in countries located outside the EU/EEA (in a third country).
6.2. When doing so we are committed to protect your data and comply with applicable data protection laws. We deploy one of the following safeguards if ABL transfers Personal Data originating from the EU/EEA area to other countries not deemed adequate under applicable data protection law:
(a) EU-U.S. Privacy Shield Framework
(b) European Union Model Clauses (Standard Contractual Clauses)
Read more about the subprocessors we use to provide our services at ABL Subprocessors.
7.2. If you do not want to accept cookies, you may adjust your web browser settings either to not accept cookies or to indicate when a cookie is used. Please note, by disabling cookies some features in the EMS or on the Site might not work as intended.
7.3. In order to disable cookies, please follow the relevant instructions depending on your browser:
If you use the Internet Explorer browser.
If you use Firefox browser.
If you use the Safari browser.
If you use the Google Chrome browser.
More info: http://www.youronlinechoices.com/
- YOUR RIGHTS
8.1. You have a right to access your personal data. Therefore, you may request a transcript of records if you would like to know and verify your personal data stored and processed by us. The request must be made in writing, including a verification of you, and sent to the address listed in Section 11. “Contact Information”..
8.2. We take all reasonable steps to ensure that your personal data is correct and up-to-date. You have the right to correct inaccurate or incomplete information about yourself. If you believe that your personal data stored by us is incorrect, please notify us and provide us with the correct data.
8.3. You have the right to request the deletion of your personal data insofar as this personal data is no longer necessary for the purpose it was collected (“right to be forgotten”). However, certain legal obligations prevent us from immediately deleting all your data, such as obligations in accounting laws, tax laws and anti-money laundering laws. Data that must be preserved for legal reasons will be blocked from use for any other purposes than meeting such legal requirements.
8.4. You have the right to object to our processing of your personal data. The effect may be that you are no longer able to use the EMS. If you object, we will stop the processing of your personal data.
8.5. You have a right to data portability. In case you want to utilize such right, please contact us by using the information below.
8.6. If you have any inquiries regarding our processing of your personal data, please contact us. If you are displeased with our processing of personal data, you may file a complaint to the Swedish Data Protection Authority (Sw. Datainspektionen), www.datainspektionen.se, the equivalent authority in the EU-member state where you live, or with the relevant authority in your country of residence outside of the EU, if any.
9.1. We are using adequate technical and organizational security measures to ensure that your personal data is not misused, lost, or unlawfully accessed. We only give access to your personal data to those employees who require it to provide our services, including the EMS.
- UPDATES TO THIS POLICY
- CONTACT INFORMATION
11.1. If you have any questions regarding our processing of your personal data, or any question, complaint, or claim, please contact us at:
Address: Östermalmsgatan 26A, 114 26 Stockholm, Sweden