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Cinis Fertilizer AB (“Cinis”, “we” or “us”) value your trust. It is important that you have confidence in our processing of your personal data. Therefore, we want you to be aware of how and why we collect and process your data and that we comply with applicable data protection legislation, including the European General Data Protection Regulation (the “GDPR”).
1. WHAT IS THE PURPOSE OF THIS DOCUMENT?
Cinis is the data controller for the processing of personal data described in this policy. If you have any inquiries regarding the processing of your personal data, please contact us at email@example.com
2. What Personal Data about you do we collect?
Personal data means any information that may be used to identify you directly or indirectly or otherwise adheres to you as a person (“Personal Data”). Personal Data can include, among other things, your name, contact information and email address (including professional ones) and technical information such as IP-address or online identifiers. We gather the following categories of personal data:
a) Personal information: name and contact details (email, phone number or other contact information that you provide);
b) Recruitment information: copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process, previous employment background, education history, professional qualifications, spoken language(s) and other relevant skills, certifications, certification expiration dates, information necessary to complete a background check;
c) Professional information: your name, the name of your employer, your position and work assignments with your employer and your professional contact information (work email and work phone number);
d) Technical information: information about how you use our website (such as duration of stay on a certain page and links clicked), your IP-address, operating system and web-browser; and
e) Communication content: information that you provide to use, including the reason for your communication and other information that is disclosed by you in the course of our communication.
The Personal Data we gather and process differs depending on if you: (i) are employed by one of our customers, suppliers or partners, (ii) simply visit our website, (iii) seek employment with us, or (iv) contact us for support or general questions. Therefore, the information below will be separated into four categories: Partner Employees, Website Visitors, Applicant Employees and General Communications.
2.1 As a Partner Employee we collect the following Personal Data about you:
Professional information and Communication content.
2.2 As an Applicant Employee we collect the following Personal Data about you:
Personal information, Recruitment information and Professional information.
2.3 As a Website Visitor we collect the following Personal Data about you:
Technical information when you visit and use our websites.
2.4 When you communicate with us, we collect the following Personal Data about you:
Communication content as well as Personal information and Professional information if disclosed as part of the communication and depending on how you contact us. For example, if you contact us by way of phone, we will store your phone number as well.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
The personal data is collected directly from you, generated by you through your use of our website or disclosed to us by your employer.
Recruitment information may also be collected through recruitment agencies, former employers, credit reference agencies or other background check agencies when we use such third parties in our recruitment process.
4. WHY WE PROCESS YOUR PERSONAL DATA AND OUR LEGAL BASES
To process Personal Data, we must have a legitimate purpose and a legal basis for our processing. The purposes for which we will process your Personal Data and the legal basis we rely on are listed below.
4.1 As a Partner Employee we process Personal Data about you in order to:
Market our products and services to your employer, negotiate business deals with your employer or otherwise to contact your employer within the scope of our and your employer's business operations. These processing operations are based on our and your employer's legitimate interest to conduct our businesses and to maintain contact during ongoing business relationships.
We also retain documents containing your Personal Data in order to be compliant with legal requirements such as tax law, record-keeping and reporting obligations. Such retention of information is done based on the legal obligations which we must follow as a company.
We will also retain documents containing your Personal Data for the establishment, exercise or defence of legal claims. Such retention of information is done in our or your employer’s legitimate interest to process legal claims.
4.2 As an Applicant Employee we process Personal Data about you in order to:
Making a decision about your recruitment or appointment, determining the terms on which you work for us and to perform background checks.
Storage of your Personal Data during the recruitment process and the use of the Personal Data to evaluate and contact applicants and (potentially) to enter into a contract regarding your engagement with us is based on our legitimate interest to efficiently operate our business and to employ personnel as well as our legal obligations as an employer.
After the recruitment process your Personal Data may be stored with us and retained by us for future recruitment processes if you consent to such storage.
4.3 As a Website Visitor we process Personal Data about you in order to:
Such information is aggregated and anonymized. This is done in accordance with our legitimate interest to maintain functioning websites and to understand how website visitors use our websites.
4.4 When you communicate with us, we process Personal Data about you in order to:
Respond to your communication, solve any support issues that you may have and to provide you with marketing information and newsletters if you have elected to opt-in to such. We also analyse the reasons for why you contacted us by using aggregate data and statistics to further improve our website, products and services as well as our support functions.
In the context of support issues, such processing is done based on our legitimate interest to fulfil our contractual obligations towards your employer as a customer of ours, or our legitimate interest to receive support.
In the context of general communications, such processing is done based on our and your legitimate interest to communicate with each other.
Finally, in the context of marketing, such processing is done based on our legitimate interest to market our products, services and business.
4.5 Overlapping purposes and purpose limitation
Some of the above purposes will overlap and there may be several legal bases for processing which justify our use of your personal data, depending on the processing activity taking place.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose and that purpose is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
5. FOR HOW LONG DO WE STORE YOUR PERSONAL DATA?
We will store your personal data for as long as it is necessary. In general, this means that personal data will be stored for as long as the information is needed for the purpose for which it was collected or if it is needed to fulfil another purpose that does not conflict with the purpose for which it was first collected.
Personal data contained in documents that are retained as a part of book-keeping (such as signed contracts, order confirmations, bills or receipts) will be kept for a period of seven years in accordance with the Swedish accounting act.
Personal data contained in documents that are retained in order to establish, exercise or defend legal claims (contract negotiation materials, guarantees, bills, agreements and receipts) will be kept for a period of seven years.
Recruitment information and Personal information collected and used during a recruitment process will be retained for the duration of the recruitment process and for six months thereafter, unless you have consented to our storage of your personal data for use in future recruitment processes.
When you contact us, Personal Data for communication purposes are kept for the duration of the relevant issue and until recalled.
Personal Data relating to our newsletters and your subscription of our newsletter will be retained for as long as you have opted-in to take part of our newsletters. When you elect to opt-out of the newsletters, we will erase the related personal data within six months. Aggregated data that does not contained Personal Data regarding the reason you choose to opt-out will be retained.
Technical information that is gathered from the website is aggregated within 90 days. Aggregated technical information does not contain personal data, meaning that no specific individual can be identified.
We will delete the information that is no longer needed but may retain certain personal data to meet legal requirements. For example, if you are an employee of one of our partners and you were involved in contract negotiations, information relevant to the business relationship will be stored for the duration of the relationship and a period of 12 months after. If you unsubscribe from taking part in direct marketing or information, information related to this purpose will be deleted immediately.
6. DATA SHARING
We share your data with the following third parties, government authorities, suppliers and service providers. We require third parties to respect the security of your data and to treat it in accordance with the law.
Why might you share my personal data with third parties?
We will share your personal data with third parties where required by law, where it is necessary to administer the working relationship with you or your employer or where we have another legitimate interest in doing so.
Which third-party service providers process my personal data?
“Third parties” includes third-party service providers and partners, professional advisors, and entities within the Group, as set out below:
a) Professional advisors: accountants, auditors, lawyers, insurers, bankers, and other outside professional advisors;
b) Service providers and partners: companies that provide products and services to us such as customer relationship management systems, document storage systems, email communication and marketing systems, and IT systems suppliers and support or other service providers or partners with which we may enter into a contract; and
c) Public and governmental authorities: entities that regulate or have jurisdiction over our business such as regulatory authorities, law enforcement and public bodies (for example with Skatteverket regarding tax matters).
How secure is my information with third-party service providers?
All our professional advisors, third-party service providers and partners are required to take appropriate security measures to protect your personal data in line with our policies, as are any parties to corporate transactions. We only permit them to process your personal data for specified purposes and as appropriate, in accordance with our instructions.
What about other third parties?
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may share your personal data with a regulator or to otherwise comply with the law.
Transferring information outside the EU
We share some information you provide to us with our partners and processors that are located in the United States. As such, information collected and controlled by Cinis is transferred to, stored in, or processed by entities and partners in the United States for the purposes described within this policy.
To transfer personal data to the United States, we rely on the standard contractual clauses for international transfers implemented by the European Commission on 4 June 2021. However, we will not transfer any personal data to the United States if we cannot guarantee an equivalent level of protection and that your personal data is treated by those third parties in a way that is consistent with and respects the GDPR.
This means that we take measures for any personal data transferred to the United States to ensure that the transfer is in accordance with applicable data protection legislation and to ensure that your personal data is adequately protected. In particular, we ensure that appropriate contractual, technical and organizational measures are implemented.
7. WHAT RIGHTS DO YOU HAVE?
Below you will find a description of your rights regarding the processing of your personal data. If you wish to exercise any of these rights, you are welcome to contact us by using the contact details set out in section 9 below.
7.1 The right to obtain a copy and to rectification
You have the right to obtain a copy of your personal data undergoing processing by us without cost. If you consider any personal data about you, collected by us, to be incorrect, you have the right to rectification. We will rectify all personal data that is incorrect with the exception of personal data only processed for archiving purposes.
7.2 Right to erasure
Your personal data will not be saved for a longer period than specified in section 5 and we will erase all other personal data in compliance with applicable laws and regulations. You have the right to demand erasure of incorrect personal data and processing of personal data that is no longer necessary. Such a demand of erasure may also regard personal data being processed due to legitimate interests.
7.3 Right to object
You have the right to object to processing made based on our legitimate interests. Such objection means that we may not process your personal data further. Our processing based on legitimate interest is specified above in sections 2 and 4.
7.4 The right to restriction of processing
You have the right to obtain restriction of processing when one of the following circumstances is applicable:
- if you contest the accuracy of the personal data;
- if the processing is unlawful and you request restriction instead of deletion of the personal data;
- if the personal data is no longer needed for the purposes of the processing, but you require the personal data for the establishment, exercise or defense of legal claims; or
- if you have objected to processing based on legitimate interest.
7.5 Right to data portability
You have the right to receive the personal data that you have provided to us in a structured, commonly used and machine-readable format. This applies to processing based on your consent or due to a contract.
7.6 Right to withdrawal of consent
In the event that you have given your consent to processing, you have the right to withdraw that consent. When you withdraw your consent the processing that the consent refers to will cease and those collected personal data will be erased given that the personal data is not needed for any other purpose giving us the right to process your personal data.
7.7 The exercise of your rights
If you wish to invoke any of your rights specified above, you may contact us as described below in section 9.
Cinis will process your request according to this section 7 without undue delay. If we decide to not grant your request in full or in part, we will notify you about this as well as the reason for the decision.
8. SUPERVISORY AUTHORITY
If you are unsatisfied with our processing of your personal data or a decision in reference to section 7.7 above, you always have the right to make a complaint with the Swedish Authority for Privacy Protection (Swedish: Integritetsskyddsmyndigheten) or your national data protection authority.
9. HOW TO CONTACT US
Please e-mail us at firstname.lastname@example.org or regular mail with “Attention: Privacy” to the address provided below if you have any inquiries regarding our processing of your personal data.
The data controller for the processing described herein is Cinis Fertilizer AB, registered organizational number 559154-0322, Bytaregatan 4D, SE-222 21 Lund, Sweden.