Shinner AB
This Privacy Policy is effective as of 20230101.
Index
Background
Definitions
When do we process Your Personal Data?
Data controller
Why do we Process Your Personal Data?
What Personal Data is Processed on what legal ground?
How long is Your Personal Data stored?
Location Data Collection and Use:
Social media platforms
Your rights
Consent to the Processing of Personal Data
To whom do we transfer Your Personal Data?
How do we protect Your Personal Data?
Supervision and compliance
Third party’s terms and conditions
Changes to the Privacy Policy
How do You contact us?
This policy (“Privacy Policy”) has been established in order to ensure and make You aware that “Shinner AB”, “we”, “us”) processes Your personal data in a legal, appropriate and safe manner when You or the company You represent purchase or uses our services or products, visit our website or come in contact with us in some other way.
The Privacy Policy is applicable on all services that are provided by Shinner. This means that if You choose to use our services, You also agree to the collection and use of Your personal data according to this Privacy Policy.
The Privacy Policy describes how ï processes Your personal data and which rights You have according to the rules in the EU’s General Data Protection Regulation (GDPR) (EU) 2016/679 with associated statutes of implementation and supplementary statutes on data protection (the “Data Protection Rules”).
2. Definitions
In this Privacy Policy, the term "personal data" refers to any information which can be attributable to an identified or identifiable natural person, such as e.g. name, address, personal registration number, e-mail address, phone number, IP-address and photo (“Personal Data”).
This Privacy Policy describes how we Process Your Personal Data. The term "processing" refers to any operation or set of operations which is performed by us on Your Personal Data or on sets of Personal Data in such a manner as is described in this Privacy Policy, e.g. our collection, registering, storing, disclosure, erasure and any other using of Your Personal Data (“Processing”).
3. When do we process Your Personal Data?
The Privacy Policy applies in the following cases when Processing of Personal Data arises in our business:
when Shinner provides services to You or the company You represent;
to mailings of newsletters, invitations to events and other information;
in connection to visits to our website www.shiner.app or via social media platforms;
when You apply for a job with us; and
to requests or other contacts with us via e-mail or phone.
4. Data controller
ï, Reg. No. 559311-3904, with address Trelleborsgatan 6, 214 35 Malmö, Sweden ïTRELLEBORGSGATAN 6
Ort
214 35 Malmö
is the data controller for the processing of Your personal data which is carried out in accordance with this Privacy Policy.
5. Why do we Process Your Personal Data?
ï Processes Personal Data regarding our customers, our customers representatives and contact persons, potential customers, employment-seekers, suppliers, other business partners and potential suppliers and business partners. ï only collects and Processes Your Personal Data for specific purposes. This entails that Personal Data is Processed in order to:
provide services and fulfil the agreement entered into with You personally, the company or organisation You represent or work for, or the company or organisation You work on behalf of;
enable general customer relationships management (quality management, statistics, market and client analyses, as well as business and methodological development) and customer service and support, e.g. when You contact us via e-mail, phone or via our Website.
inform and market our business through, inter alia, publishing customer references and other material on our Website, in presentation material used at events, or via brochures;
leave information regarding events and news, and address marketing information via e-mail, phone or via social media platforms regarding our business and our services;
process a job application;
comply with applicable legislation.
What Personal Data we collect and Process depends, inter alia, on (i) how You come in contact with us, and (ii) which of our services we provide to You or the company You represent.
When You are asked to provide us with Personal Data, e.g. upon the purchase of a service or participation in an event, You may choose not to do so. If You choose not to provide necessary information, this may lead to us not being able to fulfil our commitments towards You or the company You represent.
Further, we Process Personal Data through the use of cookies (small text files which are stored on Your unit) on our Website. This is done so that our Website and our online services can function as well as possible and provide You with a pleasant customer experience. Read more on our use of cookies under section 9.
6. What Personal Data is Processed on what legal ground?
The Personal Data listed below is Processed by us for the purposes explained under section 5 above:
e-mail address;
IP-address;
reviews;
photos; and
information in correspondence with You.
The Processing of Personal Data is necessary in order for ï to conduct its business through providing sale and delivery of services and thereby fulfil the agreement that has been entered into with You (if You are a sole trader). In situations where You act as a representative or contact person for a company or organisation that is a customer of ï, or in any other way collaborates with ï, we Process Your Personal Data based on our legitimate business interest. For this Processing, we have conducted a balancing of interests where we have, inter alia, taken into account that the Processing does not include any sensitive Personal Data and that we have a clear commercial interest in being able to provide our services to the company or organisation You work for or on behalf of in an efficient manner.
The Processing of Personal Data is also necessary in order for ï to provide good service via our customer service and support and in order to be able to investigate potential complaints, and thereby meet our legitimate interest of handling customer service matters, developing our business and communicate our contacts in an efficient and customer friendly manner. As a part of this, ï will, in some cases, Process sensitive Personal Data regarding health when You, as a part of a registration to an event which is held by us, informs us of, for example, Your food preferences and/or allergies. These sensitive Personal Data are Processed for the sole purpose of ï being able to meet the specifically requested wishes.
The Personal Data can also be Processed regarding other contacts with You, for example through newsletters and other dispatches, such as invitations to events, information regarding seminars and educations or other information which we consider to be relevant for You or the company or organisation that You represent. We Process Your Personal Data based on our legitimate business interest of being able to provide You, who are already an existing customer, or who used to have a business relation with us, relevant marketing and information. For this Processing, we have conducted a balancing of interests where we have, inter alia, taken into account that the Processing does not include any sensitive Personal Data and that we have a clear commercial interest in being able to provide our services to the company or organisation You work for or on behalf of in an efficient manner.
If You are in contact with us in connection with seeking employment with us, we base our Processing of Your Personal Data on Your consent or on our legitimate business interest.
We may also process Your Personal Data with your consent, e.g. when You consent to our publishing of customer references on our Website. In the event that we can no longer Process Your Personal Data for marketing purposes based on our legitimate business interest we may come to obtain Your consent to e.g. send You information. Consent can also be obtained if we wish to store incoming resumés for future recruitment purposes. We will always document whether You have given Your consent to our Processing of Your Personal Data.
Your Personal Data is also Processed, in applicable cases, in order for ï to comply by its obligations stemming from applicable legislation, court rulings and decisions taken by the authorities. Such obligations may e.g. follow from the Accounting Act (1999:1078), the Money Laundering and the Financing of Terrorism (Prevention) Act (2017:630).
7. How long is Your Personal Data stored?
Your Personal Data is stored only as long as needed in order to fulfil the purposes for which the Personal Data was gathered in accordance with this Privacy Policy.
Personal Data which is Processed in order to create your profile, is stored for as long as the user do not ask to remove it.
If You have given Your consent to the Processing of Your Personal Data, ï Processes Your Personal Data for the specific purpose, until You withdraw your consent. You can withdraw Your consent at any time by contacting us and objecting to this.
In order to ensure ï’s compliance with the legal obligations stemming from applicable legislation or in order to safeguard our legal interests we may store Your Personal Data for a longer period of time than what is stated above. The Personal Data is however never stored for longer than is necessary or statutory for each respectively purpose.
8. Location Data Collection and Use:
Type of Data: Precise GPS location (FINE_LOCATION).
Purpose of Use: The app uses this data to provide location-based services, enhance app functionality, and improve user experience.
Legal Basis for Processing: We process this location data based on your explicit consent, which is obtained directly within the app.
Sharing of Location Data:
Third Parties: We may share your location data with trusted third-party service providers who contribute to the functionality of our app. All third parties comply with our strict data privacy and security standards.
Usage: Third parties use this data solely to perform services on our behalf, such as mapping and location analytics.
Data Security and Privacy:
We implement robust security measures to protect your location data against unauthorized access, loss, or alteration. This includes encryption, access control, and secure storage.
You have control over your location data and can manage permissions within the app settings to enable or disable location tracking at any time.
User Rights:
You may access, update, or request deletion of your location data through the app settings or by contacting our support team.
You have the right to withdraw your consent for processing your location data at any time without affecting the lawfulness of processing based on consent before its withdrawal.
9. Social media platforms
ï uses Instagram, TikTok and LinkedIn as platforms to get in contact with our customers, potential customers and other business partners, as well as market and inform about our business and our services. In connection with this, ï is the data controller for publications and information that contain Personal Data and are made by you as a user in the form of e.g. comments, photos and video clips. ï does not allow offensive content to be published or made available on our platforms. We ask our users to report unfit content to us in order for us to ensure that such content does not occur. ï may also, based on what we deem necessary, remove content that has been published on our social media platforms.
10. Your rights and cookies
You have a right to receive information regarding the Processing of Your Personal Data we carry out. Below You find a statement of the rights You can claim by contacting us. Our contact information can be found at the very end of this Privacy Policy.
Right to access
You have a right to, free of charge, request information regarding our Processing of Your Personal Data. You also have a right to receive a copy of Your Personal Data that we Process. Such a request shall be submitted to us in writing. We will respond to Your request as swiftly as possible. If we cannot grant You access to the information Your request concerns, we will provide a reason as to why. The copy of Your Personal Data will be sent to Your registered address unless otherwise is agreed with You in writing. In order to ensure that the right person receives the information, we may come to request more information from You.
Right to rectification
The main responsibility to ensure that the Personal Data we Process is correct lies with ï. If You inform us that the Personal Data You have provided to us is no longer correct, we will promptly correct, block or erase such Personal Data.
Right to erasure
You have the right to request that ï, without unnecessary delay, erases Your Personal Data. Personal Data shall be erased in the following cases:
if the Personal Data is no longer necessary for the purposes for which it was collected;
if You withdraw Your consent and the Processing was based solely on consent;
if Processing is carried out for purposes of direct marketing and You oppose Your Personal Data being used for such purposes;
if You oppose the Processing of Personal Data after a balancing of interests has been carried out and Your interest outweighs ours;
if Your Personal Data has not been Processed in accordance with the Data Protection Rules; or
if erasure is necessary in order to comply with a legal obligation.
There may be obligations which hinder us from immediately erasing all Your Personal Data. These obligations stem from applicable legislation regarding inter alia accounting. If certain Personal Data cannot be erased due to applicable legislation or other rules of conduct that we are obligated to apply, we will inform You of this as well as ensure that Your Personal Data will be used solely for the purpose of complying with such legal obligations and not for any other purposes.
Right to restriction
You have a right to request that ï temporarily restricts the Processing of Your Personal Data. Such a restriction can be requested in the following cases:
if You consider the Personal Data we have about You to be incorrect and in connection with this have requested rectification;
when the Processing of Your Personal Data which is carried out is not compliant with the Data Protection Rules, but you still do not want your Personal Data to be erased but rather restricted; and
when we no longer need your Personal Data for the purposes of our Processing but You need it in order to establish, exert, or defend a legal claim.
If You have objected against the Processing of Your Personal Data, the use of Your Personal Data may be restricted during the time of the investigation. Upon the restriction of Your Personal Data, ï will only store Your Personal Data and for further Processing obtain Your consent.
Right to data portability
You have a right to, in the cases where we Process Your Personal Data with Your consent or in order to fulfil contractual obligations toward You, require that we provide You with all Personal Data we have about You and which is Processed in an automated manner, in a machine-readable format, which may be inter alia an Excel-file or a CSV-file. If it is technically possible, You further have the right to require that we transfer Your Personal Data to another data controller.
Right to object
You have a right to object to our Processing of Your Personal Data if the Processing is based on our legitimate interest. ï will in such a case ask You to specify which Processing You object to. If You object to any Processing we will only continue our Processing of the Personal Data if there are legitimate interests for Processing which outweigh Your interests. We will also inform You about our decision.
11. Consent to the Processing of Personal Data
If You have consented to Processing of Your Personal Data, You decide if and when Your wish to withdraw the voluntary consent that You have given to the Processing of Your Personal Data. You can withdraw Your consent by (i) contacting us and object to this in writing, or (ii) following the link in the mailings if the consent regards receiving marketing information and other information.
12. To whom do we transfer Your Personal Data?
In order to provide some of our services we appoint selected third parties. This entails that we share some of the Personal Data we have collected with them, e.g. to collaborative partners such as suppliers of IT-systems, assignment management systems, or which supply printing and distribution. In connection with such transfer of Your Personal Data, ï takes organisational and technical measures in order to ensure that Your Personal Data is handled in a safe and secure manner. These selected third parties will only process Your Personal Data in manners which follow from this Privacy Policy and in order to fulfil one or more of the purposes listed in this Privacy Policy. When such third parties are data processors for ï we are responsible toward You for that the Processing of Your Personal Data carried out by these third parties is carried out in a correct and legal manner. In such cases, we also have agreements with the suppliers containing instructions for the Processing of Personal Data in accordance with the Data Protection Rules.
ï may transfer Your Personal Data to countries outside the EU/EES, if any of our suppliers or business partners are located there. If Personal Data is transferred to a country outside the EU/EES, ï will ensure that the Personal Data will remain protected as well as take measures needed in order to transfer Personal Data to a country outside the EU/EES in a legal manner.
We will disclose Your Personal Data if it is required by law or if we, as a company, reasonably deem it to be necessary in order to protect our rights, e.g. by disclosing Personal Data to ï’s liability insurance provider and/or to comply with a court ruling or abide by the verdict of a legal process.
As the business is conducted today, ï will not sell Your Personal Data to a third party unless we have previously obtained Your consent. However, we may, in the case that ï decides to divide, sell, buy, merge with another company or organisation, or in any other way reorganise the business, transfer Your Personal Data to potential or actual buyers and their potential advisors.
13. How do we protect Your Personal Data?
In order to protect Your personal integrity, discover, prevent and limit the risks of a hacking attack etc., ï takes several technical and organisational information safety measures. ï also takes measures in order to protect Your Personal Data against unauthorised access, misuse, reveals, changes and damages. ï ensures that access to Your Personal Data is only granted to employees who need to Process it in order to fulfil their work assignments, and that they abide by confidentiality.
14. Supervision and compliance
If You are dissatisfied with how Your Personal Data has been processed or believe that Your Personal Data has been Processed contrary to The Data Protection Rules You can at first-hand contact us. You can also always turn to the supervisory authority in the Member State where You have Your place of residence or where the alleged breach has been conducted to file a complaint. The supervisory authority in Sweden is Datainspektionen, see www.datainspektionen.se.
ï annually reviews this Privacy Policy.
15. Third party’s terms and conditions
ï’s services may in some cases be subject to third party’s terms and conditions. ï is not responsible for such a third party’s use of Your Personal Data as they themselves are data controllers and responsible for the Processing of Your Personal Data. Hence, it is important that You observe and read through the terms and conditions of such third parties. The same applies if there is a link on our Website to other websites.
16. Changes to the Privacy Policy
ï reserves the right to change this Privacy Policy when we deem it to be necessary. Such changes are usually warranted upon potential changes to applicable legislation, due to statements from the supervisory authority or other authorities issuing statements pertaining to the Data Protection Rules. Further, this Privacy Policy will be updated when it is necessary due to changes in our business activities.
If ï makes comprehensive changes to this Privacy Policy or changes concerning how we Process Your Personal Data, you will be informed of this before such a change come in to force.
17. How do you contact us?
If You have questions pertaining to this Privacy Policy or the current Processing of Your Personal Data, wish to file a request in accordance with this Privacy Policy or wish to report a violation of this Privacy Policy etc., You are welcome to contact us via e-mail, phone or letter.
Data Protection Officer
E-mail: info@shinner.app
Phone number: +46-732 000 400
Address: Trelleborsgatan 6, 214 35 Malmö, Sweden