Novedo Holding AB (publ)
3. The personal data processed
3.1 Novedo processes the following categories of personal data:
- The personal data we receive in connection with the acquisition and management of companies (“Acquisition Data”), such as name, national identification number/social security number, title, contact details, billing details and other business-related information we receive from our partners. The information that is provided may also be supplemented with data that we obtain from other sources, such as your company’s public website, public databases or purchased marketing databases, for example.
- Contact information, such as name, e-mail address, telephone number, title or role, address and postal code, company name.
- Recruitment information, such as CV or résumé, motivation letter and other information that may arise in the context of recruitment or commencement of consultancy.
4. Purposes and legal grounds for the processing
4.1. Novedo processes personal data as described above, for the following purposes and based on the following legal grounds:
- To acquire and manage companies. The personal data processed in this context is Acquisition Data. The processing is necessary for Novedo’s legitimate interest to acquire and manage companies. Information that is obtained from other sources, such as your company’s public website, public databases or purchased marketing databases will only be processed where Novedo has a legitimate interest to do so and where such interest overrides your interests and rights.
- To administer our relationship with partners, suppliers and other stakeholders. The personal data processed in this context is contact information and any other information that you may share with us. This processing is necessary for Novedo’s legitimate interest to administer our relationships with partners, suppliers and other stakeholders and keep in contact.
- To promote our business and to reach out to potential suppliers, partners and other stakeholders. The personal data processed in this context is primarily contact information. The processing is necessary for our legitimate interest to market and promote our business.
- To recruit personnel and initiate consultancies. The personal data processed in this context is primarily recruitment and contact information. The processing is necessary for our legitimate interest to recruit personnel and/or engage consultants.
- To send you our newsletter, press releases and financial reports, if you subscribe to it. The personal data processed in this context is contact information such as name and e-mail address. This processing is based on your consent, which you provide when you subscribe to newsletters, press releases or financial reports.
- To comply with applicable laws. The personal data processed in this context is contact information and any other information necessary for our compliance with applicable laws, such as the Bookkeeping Act (Sw. bokföringslag (1999:1078)). This processing is based on our legal obligations.
- To establish, exercise or defend legal claims. The personal data processed in this context is contact information and any other information necessary for us to establish, exercise or defend legal claims.
- To communicate with you when you contact us. The personal data processed in this context is contact information and any other information you may share when you contact us. This processing is necessary for our legitimate interest of responding to your queries. Please bear in mind that you should not share more personal data than necessary for your inquiry.
5. Disclosure and retention of personal data
5.1. We may share your personal data with our affiliates, partners and suppliers in order to be able to fulfil the aforementioned purposes of processing and conduct our business. In some cases, these third parties may require access to some, or all of your personal data processed by Novedo. Where any such access is required in such context, we will undertake steps to ensure that your personal data is processed in accordance with the requirements of the Applicable Data Protection Laws.
5.2. In line with the above, we may transfer personal data to third parties that may be established, or otherwise process personal data, outside the European Union/European Economic Area (“EU/EEA”). In such case, we will ensure that any such transfers comply with Applicable Data Protection Laws, including applying appropriate safeguards such as the EU Commission Standard Contractual Clauses and supplementary measures, as necessary.
5.3. At times, we may be legally required to disclose personal data, in situations where we, e.g., are involved in legal proceedings, where we are obliged to comply with legal obligations, legal requests by a public authority, to comply with a court order. Such situations may also include instances where we prevent and investigate fraud or other illegal activity to protect ourselves, you and other partners, suppliers and other stakeholders, including, where necessary, for the purposes of an investigation.
5.4. Novedo may disclose your personal data to group companies and other related parties, as well as to potential owners, part owners and their advisors and other advisors in connection with a sale of shares and/or assets in the company, a stock exchange listing and in the case of other corporate restructurings. Your personal data will be disclosed only to the extent it is necessary and only if Novedo has a legal basis to disclose the information. The disclosure will be based on Novedo’s legitimate interest to be able to divest and restructure its business, which is considered to prevail over your interest of protection of your personal data. A disclosure to external parties will only be made to parties that have entered into a non-disclosure agreement or that are subject to an equivalent statutory obligation of confidentiality.
5.5. The Website may contain references to third parties. Please note that Novedo is not responsible for the personal data processing that occurs when you visit third party websites or contact third parties. In order to obtain information on how your personal data is processed by third parties, please read their privacy policies.
5.7. Novedo retains personal data for the time period than is necessary for achieving the purpose(s) for which the personal data was first collected. Some personal data may have to be stored for a number of years, such as the Bookkeeping Act (Sw. bokföringslag (1999:1078)).
5.8. Personal data processed by Novedo in the context of recruitment will be deleted six (6) months after a completed recruitment process, unless the candidate has consented to Novedo storing their application documentation (e.g. CV, motivation letter) longer for the purpose of matching the candidate with similar jobs in the future, or if there is a dispute with respect to the recruitment process or a legal obligation requiring further retention.
7. Your rights
7.1. Pursuant to Applicable Data Protection Laws, you have the right to request access to and information about the personal data that we process about you. Additionally, you may also request that we rectify, complete, and in some cases, erase or restrict the processing of personal data relating to you. You also have the right to request a copy of the personal data we process relating to you, free of charge.
7.2. Moreover, in certain situations, you have a right to object to the Novedo’s processing of personal data relating to you. You have an absolute right to object to personal data processing done for the purposes of direct marketing, in which case the Novedo will immediately cease such processing.
7.3. You have the right to lodge a complaint with a supervisory authority. The supervisory authority in Sweden is the Swedish Authority for Privacy Protection (Sw. Integritetsskyddsmyndigheten). You can find their contact information here: https://www.imy.se/en/.
8. Contact us
If you have questions, complaints, or if you want to exercise your rights as listed above, feel free to contact us: firstname.lastname@example.org
When you contact us to exercise your rights, please state your full name and provide contact details through which we can reach you. Please note that we may need to verify your identity before we proceed with your request.
/Adopted and issued by Novedo Holding AB (publ) November 22, 2022.