At AAK AB (publ.) we are committed to protecting and respecting your personal data and privacy, and therefore we always work to protect your personal data in an appropriate manner with adherence to the EU General Data Protection Regulation and other applicable laws relating to the protection of personal data and privacy in accordance with this Privacy Policy.
You will find information below relating to what type of personal data we collect about you and how we process such data. In addition, we describe your personal data rights as an individual.
AAK AB (publ.), (company registration no. 556669-2850), with its principal address Pulpetgatan 20, SE-215 37 Malmö, Sweden, is regarded as the controller for the personal data we process as described in this Privacy Policy This means that AAK decides the purpose and the means for the described processing of your personal data. We are committed to protecting your personal information.
AAK AB works to ensure that we continuously handle your personal data in an open, accurate and legal manner. You can contact us at privacy@aak.com if you have any questions relating to how AAK process your personal data.
The type of information we collect or process
The personal data (such as your presence, name, title and contact details) that AAK collect and process is that which you have provided to us, or our partners, in connection with your relationship with AAK. Personal data may also occasionally be collected from publicly available sources, such as company websites, business publications, trade fairs and similar including information that you have provided voluntarily or filled in on one of our websites. If you become part of a video recording in connection with your participation in our capital market days, we will inform you of the recordings being made and, in such case, provide information about how and when it is used and your rights connected in this regard.
When you request to receive newsletters, marketing and promotional material, general information or desire to connect with us online, depending upon the type of contact you request we may collect the following personally identifiable information about you: contact details (email address, mailing address, telephone number, professional title or role), company name and language preferences. If you attend an event organized by AAK, we might ask for your special dietary requests.
Job applicants
AAK also collects personal data which you voluntarily submit when applying for a job: name, contact details, CV/resume and cover letter. We may also collect personal data via applications from a LinkedIn account and we may supplement such information from other public sources such as search engines, registers and social media.
How we handle personal data and the legal basis we use
Personal data is processed in order for us to conduct our business operations and to maintain the relationship with our business contacts working with or for our partners, customers and suppliers. Personal data is also processed for direct marketing purposes, to send out press releases, financial reports, invitations to seminars and similar events and to follow up on leads or information provided by you.
When connecting with us by general contact requests, by registration as a recipient of our subscription services or by downloading or requesting marketing material from us, you will be asked to give your consent to our processing of your personal data for this purpose. Your consent can be withdrawn at any time by contacting privacy@aak.com.
When connecting with us for business purposes, e.g. to attend an event organized by AAK, to develop our business relationship with you as a representative for our partners, customers and suppliers or to develop joint business interests, or if we process your personal data for additional sales, we process your personal data based on our legitimate interest or consent. When basing the processing of your personal data on our legitimate interest, we have undertaken a legitimate interest assessment, where the needs, expectations, rights and freedoms of all parties have been considered. Before relying on legitimate interest, we have made sure that our interests are compelling enough and will not cause any unwarranted harm. We have a strong interest in being able to conduct and maintain our business with you and the company or organization that you represent.
We might use your information for marketing and market research, such as if we think one of our products, services, or offers, or those of our third-party partners may interest you and the entity you represent. We or our partners may contact you by e-mail, SMS, on the telephone, post or through other means of communication approved by you. This processing is based on our legitimate interest in marketing our business, services and products. All of our marketing communications will include the option to unsubscribe from us contacting you again.
Job applicants
If you apply for a job on our online portal, we rely on our legitimate interest to process your application and the personal data you submit, and your consent to retain and store your application data and to contact you for future job opportunities if you decide that is something you want after a job application procedure has been concluded.
Third parties and transfer of your personal data
We will not share your personal data with third parties except in the following circumstances:
(i) if we have obtained your consent to do so,
(ii) in order to comply with legal obligations or defend against legal claims,
(iii) we engage a partner who performs services on our behalf including a sales partner, or
(iv) it is otherwise permitted by law.
We might share your personal data with:
(i) other legal entities or suppliers we work with that provide certain services to AAK (including IT systems providers and distributors of our products),
(ii) other subsidiaries within the AAK AB Group, and/or
(iii) any other entity where we are obligated by law, a decision from a public authority or judgment from a court of law to share your personal data with.
We generally process your personal data only within the EU/EEA. If personal data will be transferred outside of the EU/EEA, such transfers will be in accordance with the EU General Data Protection Regulation and other applicable regulations and require the receiving entity to have adequate levels of data protection and safeguards in place. We aim to only transfer and process personal data in countries where an adequacy decision has been made or, if the transfer of personal data is to the USA, to companies certified under the EU-US Data Privacy Framework. This means that the legislative framework in the third country provides the same level of legal protection as a country within the EU/EEA. To learn more about countries with adequacy decision, please see the website of the Swedish Authority for Privacy Protection There may be occasions where we need to process personal data outside of such countries. In these instances, we have undertaken a privacy impact assessment and transfer impact assessment to identify appropriate additional measures to implement, prior to establishing data processing agreements including approved standard contractual clauses. In the event that the contractual and organizational measures are still inadequate, we will seek your consent to undertake the proposed processing.
How long we retain your personal data
We retain your personal data in accordance with our obligations under applicable law. We only retain data for as long as it is relevant to initiate, maintain or administer our business relationship with you or, the company or organization that you represent.
If your organization is a customer of or a vendor to AAK, we process the personal data to administer our business relationship and for direct marketing during the contract period and for twelve months thereafter. If your organization is not a customer of/vendor to AAK but we have connected for business in another way, e.g. at a conference, we process your personal data for up to three years thereafter if no other contact is had.
If we process your personal data due to your participation in an event organized by AAK, we will delete your personal data for that purpose one month after the event has concluded, unless we are obligated by law to retain records of your personal data for a longer period of time.
You may at any time unsubscribe from services you have requested from us, including our subscription services and/or receiving marketing material, as well as further contacts from AAK and its partners, and withdraw your consent. If you unsubscribe, your personal details will no longer be saved for this purpose.
Job applicants
Personal data processed for recruitment purposes will be processed and retained until the recruitment for the position is closed plus an additional period of up to six months after, or as long as is necessary or permitted from a legal perspective based on our legitimate interest in handling your application. Data retained for future job opportunities is subject to your consent and retained up to 3 years for this purpose. You may at any time withdraw your consent for this purpose, in which case we will delete the personal data in question.
Your rights related to our collection and processing of your personal data
You have a number of rights provided to you by applicable personal data legislation and regulations. These are as follows:
· Right to access: You have the right to ask us for copies of your personal data that we process about you. Through this copy, you will be able to understand which of your personal data we have and process. The right to access is applicable when a record contains information where an individual can be identified, and the information is about them. This means that records that are accessible to you will have the personal data about other people redacted where appropriate, in order to protect their right to privacy. Your personal data will be redacted if someone else requests access to a record containing your personal data. Legislation provides other exemptions that may be applicable such as records where legal privilege needs to be observed or there is an obligation of confidentiality in specific circumstances.
· Right to information: You have the right to be informed of how we process your personal data. This Privacy Policy is an initial means of informing you about the processing of your personal data. Additional methods of keeping you informed include via FAQs and directed information when signing up for e.g. an event and updated information when needed. If you have any questions regarding how we process your personal data, you can contact us by writing to privacy@aak.com.
· Right to rectification: If you believe that the personal data we currently hold or process about you is incorrect or inadequate, you are entitled to request your data to be corrected or supplemented. Any request to rectify your personal data will also be transferred and actioned by any processor with whom your personal data has been shared. This process is managed by us and will not require any additional action from you for your right to be exercised in full.
· Right to erasure: Under certain circumstances you may also have the right to request that your personal data is deleted. AAK will erase your personal data after such a request if the information is no longer necessary to fulfill the purpose of processing the information or if you retract your consent. AAK is obliged to keep some personal data due to legal obligations despite a request for erasure. As such, AAK may not be able to delete every record that is processed about you. This will be explained where relevant. Any request to be forgotten will also be managed by AAK with any processor that is processing your personal data on our behalf.
· Right to restriction of processing: You have the right to ask us to restrict the processing of your personal data in certain circumstances such as if they are not relevant to fulfill our legal obligations.
· Right to object to processing: You have the right to object to having your personal data processed. The right can be invoked when the legal basis is our legitimate interest in processing your information, including profiling, e.g. when AAK process your personal data for marketing or for a job application. If an objection is made, AAK must show a compelling legitimate interest to continue processing personal data for that specific purpose.
· Right to data portability: Under certain conditions, you have the right to ask that we transfer the information you gave us to another organization, or to you. This enables you to transfer it in a machine-readable format to another recipient. The right to data portability applies to personal data that is processed based on your consent (for instance direct marketing efforts) or to perform a contract. It applies only to such personal data that you have provided AAK with yourself.
· Right to withdraw consent: You have the right to withdraw your consent where this is the lawful basis established for the processing of your personal data, i.e. when collected for certain marketing activities.
Please note, that these rights are not absolute, and we may have a right to deny your request where we have a compelling interest to do so.
Before responding to a request, we have a legitimate interest in ensuring the authenticity of your request and identity. If we require further information to verify your identity, we will inform you after the request has been made.
Your personal data will not be subject to automated decision-making.
If you are of the opinion or suspect that we may have processed your personal data in violation of the EU General Data Protection Regulation or any other applicable data protection regulations, please raise your concerns with us. You may also file a complaint with the Swedish Authority for Privacy Protection, Integritetsskyddsmyndigheten (IMY), who is the relevant supervising authority. You may contact IMY at imy@imy.se. Further instructions can be found on the Swedish Authority for Privacy Protection’s website, www.imy.se.
In the event this isn’t your local data protection authority, you can contact your local data protection authority who will advise as to how best to proceed. In some instances, such as within the EEA, you can file a report/complaint with your local data protection authority and will not have any additional need to communicate with the Swedish IMY.
Please note that there is always a risk of disclosing personal data, regardless if it is disclosed personally, by telephone or over the internet, and that no technology system can be completely protected from intrusion. However, AAK always makes every effort to take appropriate technical and organizational measures to prevent and minimize the risks of unauthorized access or use or corruption of your personal data.
Additional matters
This information is subject to regular review and AAK reserves the right to revise the contents of this information at any time. If any significant changes are made that may affect the processing of your personal data we will inform you of the change.
If any part of this Privacy Policy is inconsistent with applicable law, or is not applicable in a particular case, or for some reason cannot be fulfilled, the other parts of the Privacy Policy remain in effect and will not be affected in any way.
Contact us
If you have any questions, concerns or comments about the contents of the Privacy Policy or the information provided here, or if you want to invoke any of your rights as described above, you are welcome to contact us at privacy@aak.com.
