PRIVACY POLICY

Information about processing of personal data

We at Winningtemp AB(”Winningtemp”, “we”, ”our” and ”us”) care about your privacy and want you to feel safe when we process your personal data.

In this privacy notice we want to inform you who interact with us in different situations, e.g.as a representative of our current or potential customer, supplier or partner.This privacy notice also applies to you who visit our website or communicate with us on social media.

With this text we provide information on how and why we process your personal data. We also describe your rights, the legal basis for processing and the storage period for which we keep your personal data.

In short: Why do we process your personal data?

When we refer to “your organisation” in this privacy policy, we refer to your employer or the organisation that you represent. We will only process data about you in your professional role, which for example means that we will only send marketing to your organisation and not to you in your capacity as a private individual.

From where do we collect your personal data?

We collect your personal data directly from you, for example when you contact us. We may also collect your personal data from your organisation, e.g. if one of your colleagues state you as the organisation’s representative.We will also collect your personal data from other sources in the following situations:

-      If you represent a potential customer, supplier or partner (i.e. a business lead), we may collect your personal data from the internet or a third-party service.

-      If you use our website, we will  collect information on your browsing of our website to analyse your use of our website.

The personal data you need to provide to us

In general, and with some exemptions, you are not required to provide your personal data to us. You find a description of when you are needed to provide your personal data in the charts below when the so called legal basis is stated to be ”Legal obligation”. If you don’t provide such personal data to us, we at Winningtemp will not be able to administrate our relationship with your organisation or fulfil the agreements with your organisation.

Detailed description on how we process your personal data

The below charts describe in detail why we process your personal data, what personal data we process, when you need to provide the personal data to us and the legal basis for our processing. The legal basis is the basis for processing your personal data according to the GDPR. You will also find information about how long we process your personal data.

Don’t hesitate to contact us if you have any questions regarding our processing of your personal data. Our contact details can be found in the beginning of this privacy notice.

If you interact with us without having a business relationship with us, represent a business lead or visit our social media

If you are in contact with us without having a business relationship with us, e.g. by contacting us through our chat or contact forms on our website or by sending us an e-mail or a message at our social media account, we will process your personal data as we describe in the charts below. We process the personal data which you provide to us and information from your social media account (if you use such account to communicate).

When contacting us through a social media platform, we suggest you also familiarise yourself witht he privacy information of that platform.

To Communicate with you
What processing we perform what personal data we process our legal basis for processing

- Communicate, e.g. via e-mail, our chat or any of our contact forms on our website

- Communicate via social media, e.g. if you make a comment on our site or our wall

- Answer your questions and give you the best service

Information you provide to us, e.g. name and contact information

If you visit our social media accounts (e.g. our Instagram) we also process:

- Information from your profile on the social media in question (user name and any picture you have chosen for your account)

- Other information regarding the matter for which you contact us

Legitimate interest

The personal data will be processed based on our legitimate interest to communicate with you who have contacted us.

Storage period: We will delete your personal data regularly.

• Communication with us via our website or in e-mails will be deleted once a year, if we do not have an ongoing relationship or communication with you. Chat history will however be deleted within [one day].

• Your comments and communication with us on social media can be deleted by you at any time. We will remove posts or comments which are in breach of the rules of the platform or in conflict with legislation as soon as possible.

To enable your organisation to try Winningtemp
What processing we perform what personal data we process our legal basis for processing

- - Enable you to sign up for a free trial with Winningtemp

- To verify that you are not a robot when you sign up by using a service provided by Google

- Contact you if we find that your organisation is a business lead

- Information you provide to us when signing up (name, e-mail, organisation belonging and telephone number)

- When you tick the box “I´m not a robot” we will process technical information to verify that you are not a robot

Legitimate interest

The personal data will be processed based on our legitimate interest to facilitate our free trial with Winningtemp.

Storage period: We will delete your personal data after three (3) months from when the free trial period has ended. If we find that your organisation is a business lead, we will store your personal data for one year.

The chart below describes how we process your personaldata if you subscribe to our newsletters. We gather your personal data directlyfrom you and provide some personal data ourselves by analysing how you use ournewsletters.
To send newsletters
What processing we perform what personal data we process Our legal basis for the processing

- Send information about news, marketing, offers and invitations (“newsletters”) to you who have chosen to subscribe to our newsletters

- E-mail address

- Name

Legitimate interest

Legitimate interest The personal data will be processed based on our legitimate interest to send the newsletters you have stated that you wish to receive.

- Improve and develop our newsletters by analysing how you open them and what you click on in the newsletters

Do you want to read more about this type of analysis? You find a more detailed description of this in our information about cookies.

- Information about how you open our newsletters and what you click on

- IP-address

- E-mail address

Consent

The personal data will be processed based on your consent. You can withdraw such consent at any time.

Storage period: You can choose to unsubscribe or object to receiving newsletters and marketing at any time. If you object to receiving marketing from us, we keep track of this in our “unsubscribe-list” to avoid sending you any further marketing material.

If you visit our website

We analyse how our website is used and show you relevant marketing on social media and other websites you visit based on such analysis. This means that your personal data is processed when you visit our website. To protect your privacy, we have taken measures to avoid identifying you when you visit our website. For instance, we only store an encrypted version of your IP address to reduce the risk of being able to identify you.

When you visit our website, we will gather your personal data from your device and from the companies we cooperate with (see below).Such companies will also use previous information they have about you to show you interesting offers.

When you use our website, we will gather personal data by using cookies. How we do this is described in our text about cookies which you find here.

To analyse how our website is used
What processing we perform what personal data we process Our legal basis for the processing

Analyse how you use our website to improve our website and services. To do this we use the analytic service from Google Analytics

The analytic service means that we place a random ID on your device to distinguish your device from other visitors and to acknowledge patterns in how our website is used. We will however not know who you are

The personal data we gather will be used e.g. to optimize functions and to adapt the websites to suit our visitors

- An encrypted version of your IP address which we at Winningtemp can’t connect to you as an individual

- Information about your device/browser (which area in the country you use our website from and which screen resolution you have)

- Information about your activities on the website

- Other information Google has about you, e.g. information about from which site you found us

Consent

The personal data will be processed based on your consent. You can withdraw such consent at any time.

You can prevent Google Analytics from using your personal data by downloading and installing this browser add on

Storage period: We will store your personal data for a period of 180 days after your visit on our website. Google will continue to store your personal data for their own purposes and Google will inform you separately about such storing. For more information, please visit our cookie policy.

To show you marketing from us that is relevant to your organisation
What processing we perform what personal data we process Our legal basis for the processing

- Market our services by showing you offers we believe you or your organisation are interested in

We show you such marketing on Google (including YouTube), Facebook (including Instagram), Twitter and/or LinkedIn. You see marketing based on information that these companies have about you beforehand (so called profiling*)

- Share information about you with Google (including YouTube), Facebook (including Instagram), Twitter and/or LinkedIn so that these marketing services will have information about which type of visitors that are interested in us

- An encrypted version of your IP address which we at Winningtemp can’t connect to you as an individuall

Thereafter you will see search results and ads based on:

- An analysis of how you use our website

- Information that the marketing services we use have about you from before, e.g. information about from which site you found us

Consent

The personal data will be processed based on your consent. You can withdraw such consent at any time.

The personal data will be processed based on your consent. You can withdraw such consent at any time.

Here you can make choices about the marketing you see from Google and here on Facebook, under the heading “Ad settings”, you can choose which marketing you want to see on Facebook

Storage period: You will see marketing from us on other websites and on social media for a period of 180 days after your visit to our website. Google (including YouTube), Facebook (including Instagram), Twitter and/or LinkedIn will continue to process your personal data and will be independently responsible. Information on how long they store your personal data can be found in their respective privacy information.

*Profiling: We use so called profiling to be able to show you offers that are relevant to you and to provide you with customized marketing.We use profiling because without it, you would instead see offers and information which you are probably not interested in. You have the right to object to profiling as described below under the section explaining your rights.

If you represent our customer

To show you marketing from us that is relevant to your organisation
What processing we perform what personal data we process Our legal basis for the processing

- Negotiate and enter into an agreement with your organisation

- Administrate our relationship with your organisation (e.g. communicate with our customer)

- Information you provide to us, e.g. name, organisational belonging, position in your organisation, telephone number and e-mail address

Legitimate interest

The personal data will be processed based on our legitimate interest to negotiate and enter into an agreement with your organisation and to administrate the agreement.

Storage period: Your personal data will be removed if we conclude that we will not enter into an agreement with your organisation.

If your organisation becomes our customer, we will store your personal data for this purpose as long as your organisation is our customer, however for a shorter period if we receive information that you no longer represent the organisation.

To send newsletters
What processing we perform what personal data we process Our legal basis for the processing

- Send information about news, marketing, offers and invitations (“newsletters”)

- E-mail address

- Name

Legitimate interest

The personal data will be processed based on our legitimate interest to send newsletters to our customer.

- Improve and develop our newsletters by analysing how you open them and what you click on in the newsletters

Do you want to read more about this type of analysis? You find a more detailed description of this in our information about cookies.

- Information about how you open our newsletters and what you click on

- IP-address

- E-mail address

Consent

The personal data will be processed based on your consent. You can withdraw such consent at any time.

Storage period: We will process your personal data as long as your organisation is our customer, however for a shorter period if we receive information that you no longer represent the organisation.

You can choose to unsubscribe or object to receiving newsletters and marketing at any time. If you object to receiving marketing from us, we keep track of this in our “unsubscribe-list” to avoid sending you any further marketing material.

If you represent our supplier or partner

To enter into an agreement with your organisation and administrate our relationship
What processing we perform what personal data we process Our legal basis for the processing

- Negotiate and enter into an agreement with your organisation

- Administrate our relationship with your organisation (e.g. communicate with our supplier or partner)

- Name, organisational belonging, position in your organisation, telephone number and e-mail address

Legitimate interest

The personal data will be processed based on our legitimate interest to negotiate and enter into an agreement with your organisation and to administrate the agreement.

Storage period:Your personal data will be removed if we conclude that we will not enter into an agreement with your organisation.

If your organisation becomes our supplier or partner, we will store your personal data for this purpose as long as the organisation you represent is our supplier or partner, however for a shorter period if we receive information that you no longer represent the organisation.

If you participate in any of our events or webinars

To take photos/videos during an event and publish them on our website and social media
What processing we perform what personal data we process Our legal basis for the processing

- Take photos of you during an event

- Publish your photo on our intranet, our website or on our social media pages to be able to market our events

Your personal data will only be processed for this purpose after you have been given information about our publication of photos and if you have not objected to our processing.

- Your image, either in photos or video material

Legitimate interest

The personal data will be processed based on our legitimate interest to be able to document our events and make use of footage from the event for marketing purposes.

Consent

We will always ensure you give your consent according to Swedish act on Names and Pictures in Advertising if your photo or name is visible in our marketing

Storage period:If we have published a photo or video of you from our event on our intranet or website, the photo or video will stay published for [two years], unless you ask us to remove it before then.

Photos or videos of you that have been published on our social media pages will be published until you ask us to remove them.

If you or your organisation have any questions or queries

We always strive to keep a good relationship with your organisation and answer all questions you or your organisation may have. If you or your organisation have any questions, would want to make a complaint regarding one of our services or if we would have a claim against your organisation, we will process your personal data as described below. We will collect your personal data from you or your organisation or provide the information ourselves.

Note that an ongoing matter may mean that we cannot delete all your personal data after your request.

To handle any questions or complaints
What processing we perform what personal data we process Our legal basis for the processing

- Handle any questions, complaints or claims

- Personal data necessary in case of a claim, complaint or legal process/matter

- Name, organisational belonging, position at your organisation, telephone number, e-mail address, information concerning your organisation’s complaint or claim and other necessary information in relation to the matter

Legitimate interest

The personal data is processed based on our legitimate interest to handle a question, complaint and/or legal dispute in which you are the representative of a customer, supplier or partner

Storage period:We will store your personal data from the time the matter was initiated and for the duration of the potential dispute.

To comply with our bookkeeping and accounting obligations

To handle any questions or complaints
What processing we perform what personal data we process Our legal basis for the processing

- Store information in bookkeeping and accounting

- Name, history regarding payments made and other information that constitutes accounting records

Legal obligation

The processing is necessary to comply with legal obligations to which we are subject, i.e. bookkeeping and accounting legislation.

Storage period:We will store any document constituting bookkeeping material and personal data included therein for seven to eight years according to bookkeeping and accounting legislation. The regulation means that we store bookkeeping material until and including the seventh year after the end of the calendar year for the fiscal year to which the personal data relates.

If you object to receiving marketing from us

We will store information about you who have chosen to object to receiving marketing from us – see the below chart for information about this. We have received the personal data we store from you.

To handle any questions or complaints
What processing we perform What personal data we process Our legal basis for the processing

- If you have stated that you do not wish to receive marketing from us, we will store such information in an “unsubscribe-list” to make sure we do not send any marketing to you

- Name

- E-mail address

Legal obligation

The processing is necessary to comply with legal obligations which we are subject to, i.e. marketing law which require us to not send marketing material to individuals who have objected to receiving such marketing.

We cannot make sure you will not receive marketing from us without processing your personal data for this purpose and you are therefore required to provide your personal data to us.

Storage period:You will be listed in our “unsubscribe-list” until further notice.

Who can gain access to your personal data and why?

Your personal data is initially collected and processed by us and we do not sell your personal data. This means that your personal data will be handled by our employees, but only personnel who need such access to conduct their work.

To conduct our business, we need to work with suppliers and partners who therefore will process your personal data. We are responsible for any sharing of your personal data to such suppliers or partners and to make sure your personal data is safe when shared with third parties as set out below.

We will share your personal data with the following recipients:

  • We will share your personal data with our IT partners who will process these on our behalf and on our instructions to ensure good and secure IT operations. We only share your personal data with our IT partners if it is necessary for them to fulfil their obligations towards us according to the contract that we have with them.
  • We use third parties which on our behalf and on our instructions help us administrate our marketing and therefore will have access to your personal data.
  • If you interact with us on or visit our social media accounts, the social media platform that you use will process personal data about you as a user.
  • In order to store information that we according to bookkeeping and accounting law are required to store, we may use a company that help us archive such information. The information contains personal data but will only be processed on our behalf and on our instructions.
  • When you use our website and consent to us doing so, we will also share your personal data with:
    o  Google, which provides the service to analyse the website; and
    o   The companies which provide the marketing services we use (Google (including YouTube), Facebook (including Instagram), Twitter and/or LinkedIn).
  • If you participate in any of our events, we will share your personal data with:
    o  the photographer that takes your picture and that will process your personal data on our behalf and on our instructions; and
    o   social media platforms if we publish a picture or video in which you appear. These social media platforms are either processing your personal data on our instructions or as controllers in their own right for their processing of your personal data. What role they have in a particular case depends on the specific platform and activity.

If you have any questions regarding how we share yourpersonal data or want to know more about who we share your personal data with, please feel free to contact us.

Where are your personal data processed?

We, as well as our processors, mainly process your personal data within the EU/EEA. In some instances, we will transfer your personal data outside of the EU/EEA, however only to a limited extent. Such transfer will only take place in accordance with applicable data protection legislation.

If you use our website and have consented to us using services from Google, Facebook and LinkedIn your personal data may be considered transferred outside of the EU/EEA. These parties may transfer your personal data to the United States since they are located there.

We have de-identified your personal data as far as possible to avoid your personal data being transferred outside of the EU/EEA. We only transfer your personal data outside of the EU/EEA when we can ensure an adequate level of protection of your personal data. Google, Facebook andLinkedIn rely on Standard Contractual Clauses for the transfer of personal data outside of the EU/EEA. Standard Contractual Clauses are one safe guard to provide a safe transfer of your personal data.

If you want to know more about who we share your personal data with, please feel free to contact us. Our contact information can be found at the beginning of this privacy notice.

What are your rights when we process your personal data?

You have certain rights that you can exercise to affect how we process your personal data. You can read about what those rights are below.

If you want to know more about your rights or if you want to exercise any of your rights, please contact us and we will help you. Our contact information can be found in the beginning of this privacy notice.

Right to withdraw your consent and object to processing

You have a right to withdraw any consent you have given us, partly or completely.

You always have a right to object to our processing of your personal data when the processing is performed for marketing and profiling purposes, such as sending newsletters and customising marketing. You can read more about profiling in the charts above.

You also have a right to object to our processing of your personal data when the processing is based on the legal basis “legitimate interest”. In some instances, we may continue to process your personal data based on our legitimate interest even if you have objected to our processing (e.g. when we need to store your personal data). This can be the case if we can show compelling legitimate reasons for the processing that outweigh your interests, rights and freedoms in us not processing your personal data or if the purpose of the processing is to establish, exercise or defend against a legal claim.

Right to information and access

You have the right to obtain confirmation as to whether we are processing personal data about you or not. If we do process your personal data, you also have a right to obtain a copy of the personal data processed by us as well as information about how we process your personal data.

Right to rectification

You have a right to correct any inaccurate personal data concerning you that we may be processing and to ask us to have incomplete personal data completed.

Right to erasure (“the right to be forgotten”) and restriction of processing

Under certain circumstances, you have a right to request that we delete your personal data. This is the case for example when the personal data is no longer necessary for the purposes for which they were collected or otherwise processed or if you have withdrawn your consent the processing was based on and there is no other legal basis for processing.

Under certain circumstances, you also have a right to request that we restrict our processing of your personal data. That is the case for example when the accuracy of the personal data is contested by you, or the processing is unlawful, and you do not want us to delete your personal data but instead you request that we restrict our use of them.

Right to data portability

Under certain circumstances, you have a right to receive your personal data from us in a structured, commonly used and machine-readable format and, where technically feasible, have your personal data transferred to another organisation (“data portability”). This applies to personal data that you have provided to us in a structured, commonly used and machine-readable format, if our processing of your personal data is carried out by automated means and the legal basis for our processing is based on the performance of a contract or consent.

Legitimate interest assessments when processing personal data based on the legal basis “legitimate interests”

As we state above, for some purposes, we process your personal data based on our “legitimate interest”. By carrying out a legitimate interest assessment concerning our processing of your personal data, we have concluded that our legitimate interest for the processing outweighs your interests or rights which require the protection of your personal data.

If you want more information in relation to our balancing of interests assessments, please do not hesitate to contact us. Our contact information can be found at the beginning of this privacy notice.

Right to lodge a complaint with our Data Protection Officer and/or a supervisory authority

You always have the right to lodge a complaint with our Data Protection Officer at dpo@winningtemp.comwhen you feel that we have not complied with this policy or relevant rules and legislation.

In addition, you have the right to lodge a complaint with a supervisory authority. You may do this in the EU/EEA member state where you live, work or where an infringement of applicable data protection laws is alleged to have occurred. The supervisory authority in Sweden is the SwedishData Protection Authority (Integritetsskyddsmyndigheten).

This privacy notice was adopted by Winningtemp AB on 15/12/2021.

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