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Paloma's Privacy Policy

This is an English translation of Paloma's Swedish Privacy Policy. If the language versions differ, the Swedish version applies.

Paloma in Sweden AB values the personal integrity of every individual and is committed to processing personal data in a secure, correct and lawful way. Paloma has adopted this Privacy Policy to inform you about how we handle your personal data. If you are going to provide personal data to us at Paloma in any way, we encourage you to read this Privacy Policy first.

Paloma processes different categories of personal data in a number of different contexts.

In most of the processing, Paloma acts as a data processor on behalf of Paloma's customers (the customers are referred to below as the "Users"). This processing mainly takes place when the Users use Paloma's services for event registration and email sending (Paloma and Magnet). Personal data may be processed by Paloma in this way, but it is the Users who are responsible for the processing of the personal data. The Users are data controllers, which means that they have influence over and control of the processing and therefore have the main responsibility for making sure that the personal data is processed in accordance with applicable law.

Paloma also processes some personal data for which we are the data controller. Paloma being the data controller means that we decide how the personal data is processed and have the main responsibility for making sure that it is processed in accordance with applicable law.

This Privacy Policy covers all our processing of personal data, regardless of how the personal data was collected and whether Paloma is the data controller or the data processor. It starts with the personal data for which Paloma is the data controller. Then follows a section on Paloma's processing of personal data as a data processor. The policy ends with a general section.

COOKIES

What are cookies?

A cookie is a small text file that is stored on your computer. There are different types of cookies. A persistent cookie stays on the visitor's computer for a set period of time. A session cookie is stored temporarily in the computer's memory while a visitor is on a website. Session cookies disappear when you close your browser. Cookies can be used, for example, so that users do not have to log in again or choose their language and other settings on every new visit.

Paloma and cookies

When you use Paloma's website, we use cookies so that the website works well for you. If you choose to disable cookies, some functions on our website may stop working, and settings and logins will not be saved. Paloma's website uses a session cookie that contains a session ID. The cookie is used so that the server can keep track of the website's sessions. Paloma's website also stores order data when a visitor creates an account.

PALOMA AS DATA CONTROLLER

Categories of data subjects

Below we describe which categories of personal data are processed for each category of data subjects for which Paloma is the data controller. The categories are: customers, suppliers, job applicants and website visitors.

Paloma processes personal data about its customers. The personal data is mainly collected when a customer creates an account on Paloma's website. The categories of personal data that are collected and processed when an account is created are:

  • identification data in the form of name,
  • contact details in the form of email address and phone number,
  • login details in the form of username and password,
  • information about occupation and employment in the form of workplace, and
  • electronic identification data in the form of IP address and cookies.

Paloma also processes payment information about its customers, including payment history, invoicing and any payment reminders.

Paloma further processes personal data about its suppliers. The categories of personal data that are collected and processed are:

  • identification data in the form of name,
  • contact details in the form of postal address, email address and phone number,
  • information about occupation and employment in the form of workplace, and
  • payment information including payment history and previous invoices.

Personal data is also processed when you apply for a job at Paloma. The categories of personal data that are collected and processed in connection with this are:

  • identification data such as name, title and personal identity number,
  • contact details such as address, phone number and email address,
  • financial information such as salary and salary expectations,
  • personal information such as age and date of birth, and
  • CV with completed education, grades and references.

Paloma also processes some personal data about you when you visit Paloma's website. The categories of personal data processed are then:

  • electronic identification data in the form of IP address and cookies.

Personal data may be supplemented, collected and checked using public and other registers such as the Swedish population register, credit reference agencies, company registers etc.

Use of personal data

Paloma only processes personal data for which we have a legal basis – and a specific purpose – for processing.

The purpose of the processing is to fulfil obligations within Paloma's business towards customers, suppliers and job applicants. For example, Paloma has obligations towards its customers to deliver Paloma's services.

The legal basis for processing the personal data of customers and suppliers is the performance of the agreements that Paloma has entered into with the customers and suppliers.

If you apply for a job at Paloma, we will process your personal data in connection with the recruitment in order to find a suitable candidate. The legal basis for this is Paloma's legitimate interest. If we intend to keep your application documents for later recruitments, we will ask for your consent to do so.

If you visit our website, your IP address and cookies are processed so that Paloma can keep statistics on the visit. A cookie is a small text file that is sent from our web server and saved by your browser. We use as few cookies as possible on our website while maintaining a good service. There are two kinds of cookies, "regular" cookies and session cookies. Session cookies disappear when you close your browser and are therefore not saved, while regular cookies are saved on your computer for a longer time. We use cookies to count the number of users and the amount of traffic on our website. By understanding how the website is used, we can develop and improve it. As a user, you can turn off the saving of cookies on your computer in your browser settings. For more information, visit the website of the Swedish Post and Telecom Authority (www.pts.se). Paloma's legal basis for saving personal data about its website visitors is Paloma's legitimate interest.

Personal data may also be processed for marketing on the basis of Paloma's legitimate interest in communicating with customers who use Paloma's services, or with other people who may want to use Paloma's services in the future. Personal data may also be processed for invitations to events and to develop the business. It may also be necessary for Paloma to process personal data to fulfil Paloma's legal obligations.

Consent

In some cases, the processing of personal data may be based on consent given for a specific purpose. If you have given your consent to a certain processing of personal data, you are free to withdraw it by contacting us. Even if the consent is withdrawn, Paloma has the right to process the data that is necessary to continue processing on the basis of other legal grounds, such as to perform an ongoing agreement between you and Paloma.

Recipients of the personal data

Paloma may disclose personal data for which Paloma is the data controller to the data subject and to third parties when this is necessary or beneficial for Paloma. Third parties are companies with which Paloma has a business relationship or a data processing agreement, and public authorities.

Some of these recipients are independent data controllers, but most of the recipients are Paloma's data processors. If your personal data is shared with a company that is an independent data controller, that company's or authority's privacy policy and handling of personal data applies.

When Paloma shares personal data with our data processors (for example, providers of IT services), it is only for purposes that are compatible with the purposes for which we collected the information. Paloma has written agreements with our data processors, and we regularly check our data processors to make sure that they can provide sufficient guarantees regarding the security and confidentiality of personal data and that they follow our restrictions and requirements regarding the transfer of personal data to third parties outside the EEA.

In some cases, personal data may be disclosed to a party located outside the European Economic Area (EEA), and the personal data may therefore be processed outside the EEA. Paloma only shares personal data with companies in third countries that have an adequate level of protection, or with companies that are considered to achieve an adequate level of protection through approved methods.

Security measures

Paloma has taken appropriate technical, administrative and organisational security measures to make sure that personal data is only processed by authorised staff and to prevent personal data breaches.

Storage period

Your personal data is kept for as long as necessary to fulfil the purposes of the processing. Personal data relating to customer agreements, for example, is kept for as long as the customer agreement is active and for 12 months afterwards. Personal data processed for purposes other than the performance of customer agreements is kept according to an established deletion routine. Paloma also continuously deletes personal data when it is no longer relevant and/or when the purpose of the processing has ended.

Data controller

Paloma is the data controller for the processing described above. This means responsibility for the processing of personal data that takes place. Paloma can be contacted at info@paloma.se.

PALOMA AS DATA PROCESSOR

Paloma also processes personal data on behalf of the Users. The processing then takes place in accordance with the Users' instructions and applicable law. Paloma has entered into data processing agreements with the Users in which Paloma guarantees to take appropriate technical and organisational measures to make sure that the rights of the data subjects are protected during this processing. When the relationship between Paloma and the Users ends, the personal data will be deleted or returned in accordance with the data processing agreement between Paloma and the Users. The Users have the right to carry out regular checks to make sure that Paloma meets its commitments regarding the security and confidentiality of personal data.

Below is information about the processing of personal data that may take place when the Users process personal data within Paloma's services.

Categories of personal data

Paloma mainly provides two types of services. When personal data is processed through Paloma's service Paloma (newsletter sending), the following categories of personal data are typically processed:

  • identification data such as name and personal identity number,
  • contact details such as address, phone number and email address, and
  • some information about occupation and employment such as employer, title or workplace.

When personal data is processed through Paloma's service Magnet (registration pages and ticket sales), mainly the following categories of personal data may be processed.

  • identification data such as name and personal identity number,
  • contact details such as address, phone number and email address,
  • electronic identification data such as IP addresses and cookies,
  • some health data, mainly information about allergies or disabilities, for example, and
  • some information about occupation and employment such as employer, title or workplace

Paloma's services are built so that the Users can freely add information themselves, which may sometimes include personal data. Other categories of personal data may therefore occur in specific email sendings or on specific registration pages.

The personal data is often collected from the data subject, or by using public and other registers such as the Swedish population register, credit reference agencies, company registers etc.

Use of personal data

In the data processing agreement, Paloma's Users have undertaken to only process personal data for which they have a legal basis – and a specific purpose – for processing.

Paloma does not have full insight into the Users' purposes for processing personal data. Typical purposes for processing personal data when using the newsletter service (Paloma) are marketing and advertising and sharing news. Typical purposes for processing personal data when using the event service (Magnet) are managing registrations for events, courses and seminars, for example.

The Users may have a number of legal bases for their processing. They may collect consent, have a contractual relationship with the data subject or have a legitimate interest in the processing. The personal data may also be processed so that the Users can fulfil their legal obligations.

If the processing of personal data is based on consent given for a specific purpose, you are free to withdraw your consent by contacting the User. Paloma can refer you to the right User if needed. Even if the consent is withdrawn, the User has the right to process the data that is necessary to continue processing on the basis of other legal grounds, such as to perform an ongoing agreement between you and the User.

Storage period

Paloma's services are built so that the Users can freely add and remove information themselves. It is the Users who delete personal data when the purpose of the processing has been fulfilled. When a User terminates the agreement with Paloma, a termination date is set. After this date, the User no longer has access to the account. 60 days after this date, the data on the account itself, including personal data, is deleted (address lists, surveys etc.).

The reason the data is kept for 60 days is that Users are sometimes not aware of who uses the account, and suddenly another person who uses an account may no longer have access. It is then important that Paloma can restore the account with all its data for some time after the termination.

Recipients of personal data

Paloma does not have full insight into the Users' processing of personal data beyond the processing that Paloma carries out. The User may disclose personal data to other third parties when this is necessary or beneficial for the User. The Users may also share the data with data processors other than Paloma where this is necessary or beneficial for them to carry out their assignments. The User could also disclose personal data to a party located outside the EEA.

YOUR RIGHTS AS A DATA SUBJECT

You have the right to request information about which personal data we process. You can also request that your personal data is deleted or corrected, or that the processing is restricted. You further have the right to request that your data is not processed for direct marketing purposes. You also have the right to receive your data in a machine-readable format (or, where technically possible, to have the data transferred to a third party that you choose).

A request for information, deletion, correction or restriction should be sent to the data controller. So contact Paloma if Paloma is the data controller for your personal data, and the User concerned if the User is the data controller for your personal data. However, Paloma will forward any such request to the User who is the data controller if the request is sent to Paloma.

If you are dissatisfied with the processing of your personal data, you can file a complaint with the supervisory authority, which in Sweden is the Swedish Data Protection Authority (www.datainspektionen.se).

ADDITIONS AND CHANGES

Paloma may make additions and changes to this policy. An updated policy will then be published on our website. We then encourage everyone to read the updated policy carefully.

CONTACT INFORMATION

If you have any questions or comments about the Privacy Policy or the processing of personal data in general, or if you need help finding out who to contact, you can contact Paloma at info@paloma.se.