Privacy Policy

Information on how we process your personal data

1. Introduction

This Privacy Policy (the “Policy”) describes how Echandia Marine AB, reg. no. 556939-0320, at the address Karlbergs strand 4, 171 73 Solna, Sweden (“Echandia”, “we”, “us” or “our”), processes your personal data when you visit and use our website or come into contact with us because of our business and services – usually because you represent a corporate customer, supplier or a partner of ours.

We are responsible for the processing of your personal data as described in the Policy in the capacity of data controller. If you would like to know more about our processing of your personal data, you are welcome to contact us, e.g. via the address above or via our email address: privacy@echandia.se.

It is important to us that you feel comfortable with how we process your personal data, and we therefore ask you to read through this Policy, which we may update from time to time. If we make changes to the Policy, the new version will apply from the time it is published on our website. At the top of the page, you can see when the Policy was last changed.

2. How we collect your personal data

The personal data we process relating to you is mainly collected from you when you visit and use our website or when we come into contact with you – e.g. via email, telephone or personal meetings, conferences, conventions or similar occasions. We may also collect or receive your personal data from a third party, usually from the company you represent.

3.   How we process your personal data

3.1 Introduction

We only process your personal data to the extent permitted in accordance with applicable data protection legislation. This means inter alia that we need to have a legal basis for the purposes for our processing your personal data, which in our context generally means one of the following legal bases.

Performance of a contract – the processing is necessary in order for us to provide you with our services or otherwise perform a contract between us (this applies if you conduct your business in a sole proprietorship), or to take steps at your request prior to entering into a contract.

If you are acting on behalf of someone else, e.g. in the capacity of representative of a company (which usually is the case), our processing is carried out with reference to our legitimate interest balanced against your interests or fundamental rights or freedoms, where our legitimate interest is to conclude and perform the contract with the company you represent.

Performance of legal obligations – the processing is necessary in order to fulfil our legal obligations according to law or other statutes that we are subject to, or if we are subject to orders or decisions by courts or authorities, which require us to process your personal data.

Legitimate interests – the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, provided that they are not overridden by your interests or fundamental rights or freedoms (in which case the processing would not be allowed).

Consent – the processing is carried out with your prior consent, where we inter alia are responsible for clearly informing you of what processing you consent to and your right to withdraw your consent in relation to our continued processing.

Below, we explain more about the categories of personal data we process, for what purposes we process them and what legal bases we rely on when processing your personal data, including for how long we store your personal data.

3.2 To administer, maintain and improve our website

Purposes of the processing Collect statistical data and analyse the web traffic on our website as well as other technical information generated when visiting our website, in order to maintain and improve its functionality, the user experience, and in order to discover and handle errors, breaches and incidents. To do this we use third party analytics services.

Categories of personal data The personal data we process consist of: IP-address Other technical information generated through visits on our website, such as the type of technical device that you have used, web browser, visited pages as well as the time of the visits (browser information, time zone at the place from which you visited our website, other web traffic information).

Legal basis: Legitimate interest, where our legitimate interest is to collect information to maintain and improve the functionality, content, and security of our website. Collection of information by use of cookies [and similar technologies] is carried out based on your consent, unless they are strictly necessary in order for you to be able to use our website in an appropriate manner. For more information on how we use cookies [and similar technologies], please see our cookie policy.

Storage period: We collect and store information on how visitors interact with our website for no longer than one (1) year. In most cases, the collected personal data is however converted to aggregated data (anonymized data) before the said time period, in connection with us producing statistical data.

3.3 To create, maintain and develop potential business relationships

Purposes of the processing Contact and communication with you for the purposes of creating, maintaining and developing our business relationship with you or the company you represent. This includes, among other things, communication via email regarding our business, services and current activities (see Section 3.7 below).

Categories of personal data The personal data we process consist of: First and last name Contact details such as email address, telephone number, location and business address Professional title and information regarding the company you represent Information that you otherwise provide us in our communications with you.

Legal basis: Legitimate interests, where our legitimate interest is to create and thereafter maintain and develop a business relationship with you or the company you represent.

Storage period: We store your personal data for a period of one (1) year after the data was collected. If a business relationship is established between us and you or the company you represent during this time, we will however continue to process your personal data in accordance with Section 3.4-3.8 below.

3.4 To administer and develop existing business relationships

Purposes of the processing Contact and communication with you in your capacity as a representative of one of our existing customers, partners, suppliers or other business contacts, in order to maintain and develop our business relationship with you or the company you represent. This includes, among other things, regular administration and communication regarding our customer, partner and supplier agreements and communication via email about our business, services and our current activities (se Sections 3.5 and 3.7 below).

Categories of personal data The personal data we process consist of: First and last name Contact details such as email address, telephone number, location and business address Professional title and information regarding the company you represent Information that you otherwise provide to us in our communication with you.

Legal basis: Legitimate interest, where our legitimate interest is to maintain and develop our business relationship with you or the company you represent.

Storage period: We process and store your personal data for as long as we have a business relationship with you or the company you represent, but no longer than two (2) years after the last time we were in contact in our business relationship.

We may however need to store your personal data for a longer time for other purposes, e.g. if we need to take measures in order to establish, exercise or defend legal claims. We may also need to store your personal data for a longer time in order to fulfil our legal obligations, e.g. relating to book keeping according to the Swedish Accounting Act (see further Section 3.8 below).

3.5 To administer the conclusion and performance of contracts

Purposes of the processing Administration and communication in order to conclude or perform a contract between us and you or the company you represent. This includes, among other things, invoicing and regular handling, following up and documentation of contract related matters.

Categories of personal data The personal data we process consist of: First and last name Contact details such as email address, telephone number, location and business address Professional title and information regarding the company you represent Information that you provide to us in contract related matters with you or the company you represent, e.g. questions and feedback on contracted services.

Legal basis: The processing is necessary to conclude and perform a contract with you or the company that you represent. If you are acting on behalf of someone else e.g. in the capacity of representative of a customer, partner or supplier to us, our processing is carried out based on our legitimate interests, where our legitimate interest is to conclude as well as perform the agreement with the company you represent.

Storage period: We process and store your personal data for as long as we have a business relationship with you or the company you represent, but no longer than two (2) after the last time we were in contact in our business relationship. However, a longer retention period may be required if this is stipulated in the agreement between us and the company you represent.

We may also need to store your personal data for a longer time for other purposes, e.g. if we need to take measures in order to establish, exercise or defend legal claims. We may also need to store your personal data for a longer time in order to fulfil our legal obligations, e.g. relating to book keeping according to the Swedish Accounting Act (see further Section 3.8 below).

3.6 To communicate with you for other purposes

Purposes of the processing Contact and communication with you when you when you contact us for other reasons than described above, and administration of your communication.

Categories of personal data The personal data we process consist of: First and last name Contact details such as email address, telephone number, location and business address Information that you otherwise provide us in our communications with you.

Legal basis: Legitimate interests, where our legitimate interest is to be able to communicate with you when you have initiated the contact.

Storage period: We store your personal data for a period of one (1) year after the data was collected.

We may however need to store your personal data for a longer time for other purposes, e.g. if we need to take measures in order to establish, exercise or defend legal claims. We may also need to store your personal data for a longer time in order to fulfil our legal obligations, (see further Section 3.8 below).

3.7 Newsletters and other marketing messages

Purposes of the processing To administer and send marketing messages via email or otherwise, including newsletter, for the purposes of providing information about our business, services and current activities.

Categories of personal data The personal data we process consist of: Email address First and last name

Legal basis: We only send marketing messages via email to you if the content is relevant in relation to you and the company you represent. Our marketing is then based on our legitimate interests, where our legitimate interest is to be able to market ourselves and our services. When you sign up for our newsletter we base our processing on our legitimate interest of managing such newsletters to you in accordance with your wishes.

Storage period: We process and store your personal data to send marketing messages via email to you as long as you have not opted out from receiving further messages. Such opt-out can be done at any time by using the link for opt-out provided in our messages.

3.8 To fulfil legal obligations or to establish, exercise or defend legal claims

We may process your personal data in order to fulfil our legal obligations according to law or other statutes that we are subject to, or if we are subject to orders or decisions by courts or authorities, which require us to process your personal data.

We may also process your personal data so that you, or the company you represent, we ourselves, our any relevant third party can establish, exercise or defend its legal claims, e.g. in connection with an ongoing dispute.

4. Security measures

We have taken measures to ensure that your personal data is handled in a safe way. For example, access to systems where personal data is stored is limited to our employees and service providers who require it in the course of their duties. Such parties are informed of the importance of maintaining security and confidentiality in relation to the personal data we process. We maintain appropriate safeguards and security standards to protect your personal data against unauthorized access, disclosure or misuse. We also monitor our systems to discover vulnerabilities. We will store all your personal information on our safe (password and firewall protected) servers.

5. How we share your personal data

Access to your personal data is limited to persons who require such access for the purposes described in Section 3 above. Your personal data may therefore be shared with the following categories of third party recipients:

• Companies within our group: We may share your personal data with other companies within our group. If we share your personal data with other companies within our group, we will ensure that the personal data continues to be processed in line with this Policy.
• Service providers: We use third party service providers to manage parts of our business operations. We may share personal data with such third parties in order for them to supply us with services, e.g. IT services or other administrative functions or provide services as sub-contractors in connection with our own services. When we use such service providers, we enter into data processing agreements and take other suitable measures to ensure that your personal data is processed in line with this Policy.
• Our partners: We may from time to time cooperate with external parties in order to improve our services and business. Such parties either process your personal data as data controllers according to their own terms and policies for handling personal data, or as our data processors according to our instructions. In the latter case, we enter into data processing agreements and take other suitable measures to ensure that your personal data is processed in line with this Policy.
• Sale or transfer of business or assets: We may share your personal data with a buyer/investor, prospective buyer/investor or legal representatives in the event of a sale, assignment or other transfer of all or parts of our shares, assets or operations. Should such transfer occur, we will take actions in order to ensure that the receiving party processes your personal data in accordance with this Policy. The purpose of such sharing or processing of your personal data is to allow a (potential) buyer/investor to carry out an assessment of us as a company and, where necessary, take actions and make preparations in the event a sale, assignment or other transfer should occur, where such sharing or processing of your personal data is carried out with reference to the legitimate interests of allowing such assessment, actions and preparations by the (potential) buyer/investor.
• Advisors, representatives and insurance companies: We may share your personal data with our advisors, representatives or insurance companies when this is necessary in order to fulfil our legal obligations or to establish, exercise or defend legal claims e.g. if the company you represent are involved in an insurance claim.
• Public authorities: We may share your personal data with public authorities such as the Swedish Police or the Swedish Tax Agency when we are required to do so by e.g. applicable law or other legal statutes or orders or decisions by courts or authorities in order to fulfil the legal obligation specified therein.

6. Where we process your personal data

We strive to always process your personal data within the EU or EEA where our servers are located. However, we may transfer your personal data to service providers who, either themselves or by their sub-contractors, are located or have business activities in a country outside the EU or EEA. In such cases, we are responsible for ensuring that the transfer is made in accordance with applicable data protection legislation before it occurs, e.g. by ensuring that the country in which the recipient is located ensures an adequate level of data protection according to the European Commission, or by ensuring appropriate safeguards based on the use of standard contractual clauses that the European Commission has adopted and other appropriate measures to safeguard your rights and freedoms.

You may access a list of the countries that the European Commission has decided provide an adequate level of data protection at http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm.

You may access the European Commission’s standard contractual clauses at http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010D0087.

7. Your rights

You have rights in relation to us and our processing of your personal data. Below, you will find information about your rights and how you can exercise them.

Please note that your rights apply to the extent that follows from applicable data protection legislation and that there may be exceptions to the rights where applicable. We also ask you to note that we may need more information from you in order to e.g. confirm your identity before proceeding with your request to exercise your rights.

To exercise your rights or request information about them we ask that you contact us, which is most easily done via email: privacy@echandia.se.

7.1 Right of access

You have the right to obtain a confirmation as to whether or not we process your personal data. If that is the case, you also have the right to receive copies of the personal data concerning you that we process as well as additional information about the processing, such as for what purposes the processing occurs, relevant categories of personal data and the recipients of such personal data.

7.2 Right to rectification

You have the right to, without undue delay, have incorrect personal data about you rectified. You may also have the right to have incomplete personal data completed.

7.3 Right to erasure

You have the right to obtain that we erase your personal data without undue delay in the following circumstances:

• The personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• Our processing is based on your consent and you withdraw your consent to the relevant processing;
• You object to processing that we carry out based on a legitimate interest, and your objection overrides our or another party’s legitimate interest of the processing;
• The processed personal data is unlawfully processed;
• The processed personal data has to be erased for our compliance with one or more legal obligations.

7.4 Right to restriction

You have the right to request that we restrict the processing of your personal data in the following circumstances:

• You contest the accuracy of the personal data during a period enabling us to verify the accuracy of such data;
• The processing is unlawful and you oppose erasure of the personal data and request restriction instead;
• The personal data is no longer needed for the purposes of the processing, but is necessary for you for the establishment, exercise or defense of legal claims;
• You have objected to the processing of the personal data which we carry out based on a legitimate interest, pending the verification whether your objection overrides our or another party’s legitimate interest to continue with the processing.

7.5 Right to object

You have a right to object to our processing of your personal data when it is based on our or another party’s legitimate interest. If you object, we must demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms in order to be allowed to continue with our processing.

7.6 Right to data portability

If our processing of your personal data is based on the performance of a contract with you or your consent, you have the right to receive the personal data you have provided us relating to you in an electronic format. You also have the right to have the personal data transferred from us directly to another data controller, where technically feasible.

We ask you to observe that this right to so called data portability does not cover personal data which we process manually.

7.7 Right to withdraw consent

If our processing of your personal data is based on your consent, you always have the right to withdraw your consent at any time. A withdrawal of your consent does not affect the lawfulness of the processing that took place based on the consent before your withdrawal.

8. Complaints with the supervisory authority

In Sweden, the Swedish Authority for Privacy Protection (Sw. Integritetsskyddsmyndigheten) is the authority responsible for supervising the application of current data protection legislation. If you believe that we process your personal data in a wrongful manner, we encourage you to contact us at privacy@echandia.se so that we can review your concerns. However, you may file a complaint with the Swedish Authority for Privacy Protection at any time.