When you use our website or when our email communication system communicates with you, we and our information systems will collect, store and otherwise process personal data relating to you through your use of our website and receiving/sending email communication. We analyse also your contact details with other personal information that we observe about you from your interactions with our website, our email communications to you and/or with our services.

Our support organisation also collects and processes personal data about contact persons of suppliers, business partners and other external parties.

In addition, we collect and process personal data in conjunction with registration for our newsletters, seminars, events, interest of our services, to be part of our network, job applications and in connection with other business contacts and marketing of our own business or as a part of a customer assignment.

Normally, there is no obligation to provide us with personal data. However, if we do not receive certain personal data, we might not accept an assignment, co-operation, agreement with us or our customers, provided obligations/rights to us or our customers, accept obligations by us or our customers and similar where we will have a legitimate interest of personal data including but not limited to perform conflict of interest, money laundering checks, safeguard our or our customers interest etcetera.

The personal data we process may consist of contact details (e.g. name, title, work address, telephone number, email address), identification details (e.g. passport details and date of birth /ID number), financial and employment information (employment agreement, income, bank account number, tax details), gender, as well as invoicing information (e.g. account number and tax details), notes and summaries from meetings, information about areas of interest for newsletter/investment/divestment and other mailings, information on registration for participation in seminars or event and, in the case of a seminar or event offering food, special food preferences (which may reveal information about your health or religious beliefs). The personal data may also comprise other information, e.g. course of events or other circumstances, or other information relevant for us in an assignment or for our business. In connection with visits at our offices, we normally register the visitor’s name and employer (or equivalent).

When you visit our website or when our email communication system communicates with you, we may collect and process personal data comprises of IP address, e-mail address, webpages visited, time and duration of visit and cookies (which is a text file that is stored on the computer of anyone visiting a website) and similar data generated by used cookies together with, where relevant, so-called pixeltags, through your use of our website or email communication.

We might process personal data to review Söderlind & Co AB's equal opportunity profile in accordance with applicable legislation to ensure that Söderlind & Co AB does not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. We will not process any special category data except where we are able to do so under applicable legislation or with your explicit consent.

In special circumstances we may process single pieces of data relating to (such personal data is collected only to the limited extent necessary for the purpose):

(i) that the customer, a contact person or beneficial owner of the customer, or someone they are acting for in connection with the assignment have been convicted of crimes, have been involved in several bankruptcies, have had bad publicity relating to business matters, or otherwise can be assumed to be unserious, or single pieces of data relating to that the assignment is, or is suspected to be, part of money laundering or other criminal offence.

(ii) criminal conviction or offences, or sensitive personal data (i.e., information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or concerning health or sexual life) when the assignment, on the basis of its nature, raises such personal data.

This is a non-exhaustive list which is reflective of the varied nature of the personal data processed as part of the services our firm provides.

What is the legal basis for our processing?

In relation to information about customers who are private individuals, the legal basis for processing personal data is performance of the assignment. In relation to customers’ representatives, business partners and consultants, foreign representatives, representatives and counsel of counterparties and other external parties, etc., our processing of personal data is normally based on a balancing of interests. This entails that we consider it necessary to process the personal data for the purposes that concern our customers’ or, where applicable, our legitimate interests and that these outweigh any opposing interests or fundamental rights and freedoms.

The processing of personal data in connection with the conflict of interest and money laundering checks and archiving of documents after an assignment has been concluded are based on our duty to comply with our legal obligations (e.g. under accounting and anti-money laundering legislation), as well as to safeguard our customers’ or own interest and rights and what is required for professional manner customary for our industry. We may have additional grounds for the processing in connection with the various assignments we have accepted.

The legal basis on which we process your personal data in connection with a business transaction such as a merger, restructuring or sale of assets or shares is our legitimate interest to execute the transaction and our business can be continued by a purchaser.

Processing of personal data relating to suppliers or their representatives and other external parties is based on our legitimate interest in administrating the relationship and performing our contractual obligations. In relation to the information registered in connection with visits at our offices the legal basis for our processing is – in addition to the fact that the processing may be covered by the preceding paragraphs – our legitimate interest in managing the visits, and/or our duty to comply with our legal obligations.

When we process personal data in order to maintain business contacts and analyse, develop and marketing our business, processing is based on our legitimate interest in improving our business and for communication.

When we process personal data from our website and email communication systems, such processing is carried out on the basis of your above-mentioned consent, and/or on the basis of our legitimate interest to analyse the use of our website, email communication and marketing as well as to develop it.

Processing of personal data in connection with recruitment is necessary in order to take measures prior to the entry into of an employment agreement or similar. Since we have a legitimate interest in being able to fill positions and market our business, we also process personal data by virtue of a balance of interests.

Who has access to the personal data that we process?

We employ appropriate technical and organizational security measures to protect the personal data we process from loss and to guard against, inter alia, access from unauthorized persons. Transfers of data outside the EU/EEA are made in line with applicable data protection laws and for the purposes specified above. The appropriate safeguards of the transfer may comprise of, for example, that the receiving country ensures an adequate level of protection or be ensured through the use of the EU Commission’s standard contractual clauses.

We will not disclose personal data to any third parties, except where (i) it has been agreed between us and the person whose personal data we process; (ii) it is necessary within the scope of a given assignment to safeguard our customers’ rights and interests; (iii) it is necessary so we can fulfill a statutory obligation, comply with a decision of a public authority or a court of law; (iv) if we engage an external service provider or business partner who performs services on our behalf; (v) we need to safeguard our own rights and interests, (vi) it is necessary for us to provide such information to our insurer or insurance broker, (vii) in the event that we directly or indirectly sell any business, assets and/or shares, in which case we will disclose your personal data to the prospective purchaser of such business, assets or shares and later transfer your personal data to the final purchaser if it may be the case; (viii) it is otherwise permitted by law. The personal data may also be disclosed to courts, arbitral tribunal, public authorities, to our customers and the customers’ counsel and representatives within the scope of the assignment, counterparties and counterparty’s counsel and representatives, banks, auditors, consultants etcetera where such is necessary in order to perform an assignment and does not conflict with the related customer’s instructions.

If you attend our events, seminars, or similar your personal data will be shared through the name tag you will be offered to wear during a seminar or event, and/or through a list of attendees handed out in connection with a seminar or event.

We may also share personal data with third-party service providers to assist us with client insight analytics, such as Google Analytics, or third-party postal or courier providers who assist us in delivering our postal marketing campaigns to you or delivering documents related to a matter.

Please note this list is non-exhaustive and there may be other examples where we need to share personal data with other parties in order to provide our services as effectively as we can.

What rights do you have as a data subject?

You have as a data subject the right to know what personal data we process about you. You have also the right to request that personal data concerning you is rectified if such is inaccurate or incomplete. In accordance with applicable legislation, you are also entitled to request that your personal data is erased, restrict the processing of your personal data, or object to the processing of your personal data. You have further the right to object against our processing of personal data relating to you for direct marketing purposes, and in case of such objection, we will no longer process your personal data for such purposes. In addition, you have the right to withdraw your consent to the processing of personal data at any time. Finally, you have the right to receive personal data provided by you in a machine-readable format and have the data transferred to another party responsible for data processing. Note that the above rights for you may be limited by the professional duty of confidentiality, archiving obligation, not being mandatory by law or otherwise. Restriction of erasure of personal data may mean that we are unable to meet your requirement.

Additions and alterations

We may make changes to this Privacy Notice from time to time to reflect any changes to our use of your personal data to comply with changes in applicable law or regulatory requirements or otherwise. We encourage you to review our Privacy Notice periodically to be informed of how we use your personal data.

Contact information controller

If you have any questions or complaints about how we process your personal data or wish to exercise any of your rights, please contact us by email at mail@soderlind.se or by post to the address in below. If you are dissatisfied with our processing, you can also turn to the Swedish Data Inspection Board or to the supervisory authority in the country where you live or work.

Söderlind & Co AB, Birger Jarlsgatan 41A, 111 45 Stockholm, Sweden