- Set forth below is a description of how we process your personal data and the table in Appendix A sets out the details hereof. If you wish to receive additional information on the processing of your personal data, you are welcome to contact us at: [firstname.lastname@example.org].
2. personal data we process
- Personal data refers to information which, directly or indirectly, may be associated with a living natural person. We process the following types of personal data [(i) name, (ii) personal identity number, (iii) address, (iv) e-mail address, (v) phone number, (vi) IP address, (vii) payment details, (viii) job title, (ix) correspondence and feedback, (x) user related data, (xi) necessary details of our employees, (xii)
- [We do not process any types of special categories of personal data, unless we in connection with a recruitment or employment procedure have a legal obligation or legitimate interest to do so.]
- We process personal data about persons who:
2.3.1 are customers of Fantasma or enter a business or legal relationship with Fantasma;
2.3.2 are representatives and/or employees of customers, business partners, potential customers or potential business partners of Fantasma;
2.3.3 are employees of Fantasma or applies for jobs at Fantasma;
2.3.4 are otherwise affected by our services;
2.3.5 receives our newsletters, other communication and/or attend our events; and/or
- The personal data that Fantasma processes is either provided by you directly, the company which you represent or by a company which you have engaged and which uses our services. We may also collect personal data from private and public registers, publicly accessible sources as well as from public authorities if necessary.
3. PURPOSE for the processing
- We process personal data for the purposes of:
3.1.1 administrating and performing our services in accordance with agreements with our customers and other business partners;
3.1.2 communicating with you in order to administrating and performing our services and our business;
3.1.3 evaluating and improving our services and systems;
3.1.4 establishing and managing customer and partner relationships;
3.1.5 recruiting staff, including administrating and performing agreements with employees;
3.1.6 sending newsletters, information, offers and marketing of our services;
3.1.7 fulfilling our legal obligations, strive to prevent crime, investigate whether a crime has been committed towards us, and safeguarding our interests in a dispute;
3.1.8 administrating and performing merger, acquisition, reorganization, reconstruction, asset transfer (including our customer database), or similar processes where we (and/or our customer database) are the target; and/or
4. legal basis
- If we process your personal data for any specific purpose which requires your consent under the GDPR, or any other data protection legislation, we will obtain your consent in advance.
- If we process personal data for any specific purpose upon which we have a legitimate interest, we always prior thereto and in each individual case conduct an assessment of interests in order to for example evaluate whether our legitimate interest is overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data in accordance with GDPR. We only process personal data based on our legitimate interest if we make the assessment that our legitimate interest is not overridden by the interests and rights of the relevant data subject.
5. Security MEasures; external parties etc.
- Personal data will always be processed confidentially and protected by appropriate security measures. Fantasma ensures that companies that process and/or manage personal data on our behalf, uses a high level of security measures in order to protect your personal data. However please note that, in relation to any personal data you submit to us online, we cannot guarantee the security of data sent to us in this way. Transmission of data over the internet is at your own risk. You are responsible for keeping any passwords you use to access our platforms safe.
- We may disclose your personal data to external parties with whom we collaborate in order to perform our service and/or conduct our business e.g. [licensors, marketing agencies, e-mail service providers, database- and website service providers, etc.] We may also disclose your personal data when we have a legal obligation to do so, e.g. due to anti-money laundering legislation, tax legislation, court orders or requests from government authorities.
- We may transfer and store personal data in countries outside the EU/EEA in order to perform our services and/or conduct our business. When Fantasma transfers personal data to such countries, we will take reasonable legal, technical and organizational measures to ensure that your personal data is adequately protected, at the same level as it would have been within EU/EES, through the use of relevant safeguards. For the avoidance of doubt, such transfer as referred to herein, if applicable, will only include the type of personal data relevant for the purpose of the processing.
6. storage and deletion of personal data
- Personal data will only be stored for a limited period of time and no longer than necessary in order for us to fulfil the purposes of the processing, or for as long as we are required to store the information according to applicable legislation and relevant guidelines. This will depend on a number of factors, including for example (i) the laws and regulations that we are required to follow, (ii) whether we are in a legal or other type of dispute with each other or a third party, (iii) the type of information that we hold about you, (vi) whether we are asked by you or a regulatory authority to keep your personal data for a valid reason. If processing of your personal data is no longer necessary, it will be erased in accordance with our erasure procedure.
- If we are processing personal data obtained from, for example, publicly available sources for direct marketing purposes with legitimate interest as the legal basis, we will not store such personal data for longer than one (1) month before informing the relevant data subject about such processing. You as a data subject have the right, at any time, to object to such processing of your personal data, after which we shall cease the direct marketing to you as well as the processing of your personal data for that purpose.
- You may unsubscribe from our newsletters or similar communication at any time. In such event we will no longer store or process your personal data for such purposes.
7. your rights as a data subject
- Fantasma is the controller for the processing of your personal data, and as a data subject you have certain rights as regards your personal data. The rights are however not absolute, meaning that there are exceptions to some of the rights where we cannot proceed and fulfill your request.
- As a data subject, you have the following rights:
7.2.1 Right to withdraw your consent – meaning that you have the right to withdraw your consent where Fantasma process your personal data based on consent;
7.2.2 Right to access – meaning that you have the right to request a confirmation of our processing of your personal data, to receive information about the processing, access the personal data in question, and the right to obtain a copy of your personal data;
7.2.3 Right to rectification – meaning that you have the right to have any incorrect personal data about you as a data subject corrected by us;
7.2.4 Right to erasure – meaning that you have the right to have your personal data erased under certain circumstances. This right is limited, and we may be obligated to save your personal data in accordance with applicable law;
7.2.5 Right to object – meaning that you have the right to object to Fantasma’s processing of your personal data under certain circumstances (for example, (i) you may object to processing of your personal data if we base such processing on our legitimate interest and (ii) you have the right at any time to object to Fantasma’s processing of your personal data for direct marketing purposes etc.);
7.2.6 Right to restricted processing – meaning that you have the right to have Fantasma restrict the processing of your personal data, but not delete it; and
7.2.7 Right to data portability – meaning that you may request Fantasma to transfer your personal data to another data controller.
- If you feel that our processing of your personal data does not comply with GDPR, and applicable data protection legislation, you are entitled to lodge a complaint with the Swedish Data Protection Authority (Sw. Datainspektionen).
8. links to third party sites
10. AMENDMENTS and additions