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This policy relates to the processing of personal data that Kjell Group AB (publ) (”Kjell Group” or ”we”) collect about you from for example our webbsite (www.kjellgroup.com), mail, e-mail, text messages, phone, in other contacts with us, from our group companies, third parties and from publicly available information.
We care about your privacy. This policy governs how we collect, use and protect information about you and how you can exercise your rights. Please contact us if you have questions or comments regarding this personal data policy.
With reference to law, we refer below to the General Data Protection Regulation (GDPR) (Swe. Dataskyddsförordningen) and other applicable Swedish data protection legislation.
We collect personal contact information such as social security number, name, address, e-mail, telephone number, technical information about your device or internet connection and any other personal data that you among other provide to us yourself, when you visit our website or which is transferred from Euroclear Sweden AB, such as contact information (e.g. name, title, address, telephone number and e-mail address), identification details (e.g. date of birth and social security number), share and voting rights, information about shareholder assistant/ representative/contact person. This information is necessary, among other things, for Kjell Group to be able to contact you and take the measures described in more detail below.
Collection, Purpose and Legal Basis
In order for our processing of your personal data to be legal, it is assumed that there is a legal basis for this, i.e. that it is necessary to fulfill an agreement with you or a legal obligation, or that the processing is done after a balance of interests or after you have given your consent to a specific processing. Below are examples of the purposes for which we process your personal data and on which legal basis, unless otherwise expressly stated in connection with the collection of your personal data.
Collection and Purpose
We may process your personal data in order to handle registrations for and implementation of the Annual General Meeting and to take the measures we are obliged to take within the framework of handling the share register. We may also process your personal data to send financial information about our business, such as interim reports and annual reports, information about upcoming events as well as press releases and other news that we believe may be of interest to you. In addition, we may process your personal data to handle communication with you. We may also process your personal data by publishing names and shareholdings in interim reports, annual reports and on our website.
Our processing of your personal data for handling notifications to and conducting the Annual General Meeting and for handling the share register is based on the legal basis legal obligation.
The legal basis for our personal data processing in the form of press releases and newsletters about us and our business, invitations, possible publication of information about you in the annual report or similar, and for handling the matters that you as a shareholder/contact person at companies that are shareholders, is based on a balance of interests where Kjell Group’s legitimate interest in the said personal data processing is that the processing is necessary in order to be able to provide you with relevant information and adapted offers.
Transfer of Personal Data
We take great care to protect your personal information. Except in cases where you have given your consent, we do not license or sell your personal information to third parties. However, we may transfer to, or share your personal information with, companies within Kjell & Company goup and with selected third parties as follows.
By this we mean outside companies that we assign to help us run our business (such as for IT, mailings, events and administration of the share register). In most cases, service providers and their employees are only allowed to use your personal data on our behalf and for the special assignments they have to perform according to our instructions and act as personal data processor. They are obliged to keep your personal information confidential and secure. In the other cases, they process personal data as an independent data controller or as a joint personal data controller with Kjell Group.
Due to Legal Causes
If Kjell Group or its assets are acquired by or merged with another company, including through bankruptcy, we may share your personal information with any of our successors. We may also disclose your personal data to third parties when required by applicable law, in connection with legal proceedings (such as responding to a request from the competent law enforcement agency, to protect our rights, our privacy, security, property or the public, or to enforce contracts or the terms or conditions of our website).
Transfer to Third Countries
Storage and processing of your personal data may require that your personal data be transferred to and/or stored at a destination outside the EU/EEA. Transfers of data to countries outside the EU/EEA requires that the country in question has an agreement with the EU/ EEA, that the country is considered to have sufficient data protection legislation, or that we have taken sufficient safeguards in accordance with law or other grounds for such transfer by law are applicable.
In accordance with applicable law, we store your personal information only for as long as is necessary to fulfill the purposes for which your personal information was collected or as long as required by law or agreement; for example, information that is processed about your ownership is saved for ownership history according to law for at least ten years.
We process personal data in accordance with the at each time applicable laws on personal data processing. Personal data is stored in operating environments that use security measures to prevent unauthorized access. Reasonable standards for the protection of personal data are complied with. The measures are taken in order to prevent unauthorized or unlawful processing of the data about you and unintentional loss or destruction of, or damage to, this data. Should a personal data breach be detected, it will, as prescribed by law, be reported to the Swedish Authority for Privacy Protection (Swe. Intergritetsskyddsmyndigheten) and also to you.
In accordance with law, you have the right to request information about personal data we have about you after you have identified yourself and clearly stated what information you wish to receive. Such a request must be in writing and signed by hand and sent to the address given below. Furthermore, we may request additional information to ensure that the information is provided to the correct person. We will respond to your request as soon as possible and within a month. In cases where we are unable to fulfill your request, we will notify you and state why.
If you believe that the information about you is incorrect or incomplete, you have the right and limited to what is prescribed by law the right to contact us with a request for correction. We will correct or update the information about you as soon as reasonably possible.
You also have the right prescribed by law to request that the information about you be deleted or request that we restrict the processing of your personal data, and to withdraw any consent. You also have the right prescribed by law to have the personal data you have provided to us transferred (ported).
Please note that we may be required that we retain necessary personal data in connection with deletion, withdrawal of consent or porting in order to fulfill our obligations under law or agreement. We may also be permitted by law to retain certain personal data in order to meet our business needs.
You are entitled to object to such processing of your personal data that we do pursuant to a balance of interests. We must then, after you have specified the processing to which you are objecting, demonstrate that there are overriding interests.
Amendments and Complaints
Amendments/Adjustments of the Policy
If you believe that we are processing your personal data incorrectly, we ask you to notify us as soon as possible. You have the opportunity to contact the Swedish Authority for Privacy Protection (Swe. Intergritetsskyddsmyndigheten) if you have a complaint about our personal data processing.
If you have questions or want to comment on the policy or our personal data processing, please contact us as below.