Integrity Policy

Privacy Notice NICONOVUM AB

This Privacy Notice explains how Niconovum AB ("we", "us" or “Niconovum”) processes your personal information as a data controller depending on your relation to Niconovum.

We are always committed to protecting and respecting your privacy and to process your personal data in accordance with relevant data protection legislation, i.e. the General Data Protection Regulation (the “GDPR”) and any national legislation.

If you have any concerns or questions regarding Niconovum’s processing of your personal data, please do not hesitate to contact us using the below listed contact information.

1. Data Controller
The entity responsible for the processing of your personal information is:

Niconovum AB
Järnvägsgatan 13, 4tr
252 24 Helsingborg
Sweden

Email: info@niconovum.se
Phone: +46 (0)42 19 94 43


2. DESCRIPTION OF THE PROCESSING
In the following tables you will find information about how Niconovum processes your personal data depending on your relation to Niconovum and the purposes of which we process your personal data.
In the schedules you will find information on how we process your personal data, including information on our purposes with processing, the categories of personal data we process about you, how we collect your personal data, the legal basis on which we rely on when processing your personal data, information on the parties that we may share your personal data with and information on how long we retain your personal data.

You can choose between information on how we process your personal data, when:

  • you visit our website
  • you receive and participate in Niconovum marketing and branding
  • you communicate with us and our customer service
  • you are a customer, supplier, business partner or other third-party representative

Please choose the table that is relevant for you.

 

When visiting our website

Niconovum processes your personal data when you visit our websites by setting cookies that collect personal data about you. Niconovum may use personal data collected through cookies for statistics, analysis, optimization and functionality purposes as well as marketing and targeting purposes depending on which one of our websites you visit. You can find out more about the exact purposes in the cookie information on our websites.

Niconovum only uses non necessary cookies if you have given your consent to do so. You can always withdraw or change your consent by deleting or blocking cookies in your browser or in the cookie overview or by contacting us. See more about Niconovum’s use of cookies, including how to delete and block cookies in our cookie overview and policy [here] and see more in section 6 on how to withdraw your consent by contacting us.

Categories of personal data and sources
We may process the following categories of personal data about you:

Ordinary personal data:
Information about your behaviour on our website and technical information about your visit, including details of your visits on our website and your navigation around the website, traffic data, information about the device you use, your MAC address, your IP address and information from your IP address such as location, browser type etc. Further, we process the consent that you have given.

Sources:
We collect your personal data directly from you through your use of our website.

Niconovum may also process your personal data for communication and customer service purpose if you choose to communicate with us through our website, e.g. by using chat functions or contact formulas available on our websites.

Please refer to “When communicating with us and our customer service” for information on how we process your personal data for this purpose.

Legal basis
We process your personal data on the following legal bases:

  • Article 6.1.a (consent to the processing of personal data through the use of non-necessary cookies)
  • Article 6.1.f (necessary for the pursuit of our legitimate interest in business operations and business and product development, including compiling statistics and analysis of the use of our website and to optimize the user experience on our website as well as marketing of our products)


Recipients
We may share your personal data for the described purpose with:

  • Business partners and third parties, including suppliers and vendors, that we work with to assist our company
  • Group entities
  • (Potential) purchasers in case of a sale

Social media and other third parties as described in our cookie overview and policy:

Niconovum may use third party cookies e.g. to remember your settings, for traffic measurements, statistics, to show targeted advertisements and do look-a-like and retargeting and to track your use of our website.

For these types of processing Niconovum will in some cases be a joint controller with the provider of the third-party cookie(s).

You can read more about our use of third parties and also find links to the relevant third parties’ own privacy policies in the cookie overview and policy on our website here.


Data retention
The retention periods depend on each cookie that are being set on our websites.

You can read more about our cookies and the retention period in our cookie policy here.


When receiving and participating in Niconovum marketing and branding

Niconovum may process your personal data for marketing purposes if you have signed up to receive newsletters and other marketing material from Niconovum, if you follow and/or interact with our accounts on social media or if you participate in any Niconovum marketing activities, such as events, parties, competitions, lotteries etc. as well as when you sign up to receive discounts and offers.

Categories of personal data and sources
We may process the following categories of personal data about you:

Ordinary personal data:
Name, email address, information about your age, information about your social media account, information about how you interact with us on social media platforms.

Information that you choose to give us when interacting with us on marketing platforms or as part of marketing activities.

If you participate in any Niconovum events we might also take pictures and videos from the event but only with your consent to do so.

Information related to you receiving newsletters from us, including information about whether you have opened a newsletter, which parts of the newsletter you have clicked on etc., but only if you have given your consent to such tracking.

Sources:
We collect your personal data directly from you

Legal basis
We process your personal data on the following legal bases:

  • Article 6.1.a (consent)
  • Article 6.1.f (necessary for the pursuit of our legitimate interest in marketing of our business and our products) including:
    • Sending newsletters and other marketing material to you and optimizing the effect of such marketing
    • Managing offers and discounts
    • Hosting and participation in marketing activities
    • Promoting our products and business on social media and other platforms as well as interacting with our customers and consumers on various social media and platforms

 

Recipients
We may share your personal data for the described purpose with:

  • Business partners and third parties, including suppliers and vendors, that we work with to assist our company (e.g. suppliers, service providers, technical and IT and digital support)
  • Group entities
  • Social media; in some cases, we are joint controllers together with the social media provider, such as Facebook. See Facebooks privacy notice here
  • The public; if you give us your consent to use any material that includes you to publish publicly, e.g. on our website
  • (Potential) purchasers, sellers and advisors in case of a sale or purchase


Data retention
We will retain personal data processed for this purpose as long as you are signed up to receive newsletters from us.

Don’t forget - you can always unsubscribe in the bottom of the newsletters that we send you! See more below on how to withdraw your consent.

Marketing material will be kept in accordance with our agreement and the specific case in question, but will be deleted as soon as possible, e.g. when a competition or lottery is over.

Pictures and videos of you will be kept for a maximum of 2 years.

Some personal data follow the retention periods under “When communication with us and our customer service” below.

 

When communicating with us and our customer service

Niconovum processes your personal data for the purpose of communicating and interacting with you as well as providing customer service to you and to handle any questions, inquiries, etc. that you might have about our products, services and Niconovum in general, e.g. as a business, as a workplace for recruitment purposes as well as for the purpose of improving our business and the quality of our service and products in this regard.

We communicate with and provide customer service to both consumers and customers, and we may communicate with you through email, phone, website communication such as contact formulas and chats and through social media chats and platforms, e.g. Instagram/Facebook when you follow or interact with our accounts on social media, depending on how you choose to contact us.


Categories of personal data and sources
We may process the following categories of personal data about you:

Name, email, telephone number, job title, information about your social media account and any information that you give us in your inquiry when you contact, e.g. the questions you might have and the information related to these as well as further information that we might need to handle your inquiry.

Information related to any claims, complaints or other inquiries that you might have about our products, e.g. your experience with our products, side effects etc. Such information might in some cases be sensitive information if you choose to give us such.

When you call our customer service, we might record our conversation for internal training purposes if you give us your consent to do so.

If you communicate with us and our customer service for recruitment purposes, e.g. for the purpose of knowing more about life at Niconovum, the recruitment process etc. we will also process the information about you that you give us, i.e. your contact information, your inquiry, our correspondence and any attachments such as application, CV, etc. This information will be kept locally at Niconovum for a maximum of 2 years after which it will be deleted. In case of a formal recruitment process, we will always guide you to our official recruitment channel for job applications or our HR department and we will then delete the material you might have sent.

If you communicate with us and/our customer service as a non-consumer, please also see below “When you are a customer, supplier, business partner or other third-party representative”.

Sources:
We collect your personal data directly from you when you contact us.

Legal basis for the processing
We process your personal data on the following legal bases:

Article 6.1.a (consent) with respect to recordings
Article 6.1.b (necessary for the performance of a contract)
Article 6.1.c (necessary to comply with our legal obligations), including
- regulation that we are subject to for the purpose of handling any claims or complaints that you might have about our products, including regulation that set out our obligations towards you

Article 6.1.f (necessary for the pursuit of our legitimate interest in operating, developing, market and brand our business), including
- providing customer services to you and interaction in general,
- optimizing and improving our products, our business and our customer service, and
- to handle claims and complaints

Article 9.2.f (necessary for the establishment, exercise or defence of legal claims) with respect to sensitive data processed to handle claims, complaints and other inquiries, e.g. information about side effects and your experience with our products.


Recipients
We may share your personal data with:

  • Business partners and third parties, including suppliers and vendors, that we work with to assist our company (e.g. suppliers, call centres, service providers, technical and IT and digital support)
  • Social media if we communicate with you through such
  • Group entities
  • Public authorities if requested and/or necessary
  • (Potential) purchasers, sellers and advisors in case of a sale or purchase


Data retention
We will retain your personal data for as long as it is necessary in order for us to find a solution on your inquiry, i.e. to answer your questions and/or handle your complaints and claims. As a main rule this is up to 6 months from the end of the communication or the end of the case your inquiry is about.

We may retain your personal data for a longer period of time if your inquiry is or might develop into a potential dispute, or if it is otherwise applicable by law. The retention period is hereafter depending on the circumstances around your inquiry, including what your inquiry is about, if it involves any damages, side effect reports etc., and we will only retain the personal data in order to be able to document the case and handle a potential (legal) dispute or obligation arising from or involving your inquiry and only for the period of time we might be met with a dispute etc. in accordance with the limitation regulation.

Any recordings of conversations that you are a part of based on your consent will be deleted after 30 days.


When you are a customer, supplier, business partner or other third-party representative

Niconovum processes your personal data for business operations purposes when you represent your employer or have a relation to a third party when your employer or such third party is a (potential) customer, supplier or other third-party to Niconovum, e.g. if you communicate with Niconovum as a part of you working for one of Niconovum’s (potential) business partners or other parties that Niconovum is communicating and co-operating with.

Examples of such communication and co-operation could be as a part of marketing of our products, sale and distribution of Niconovum’s products, accounts and customer management, KYC purposes, contact with public authorities, government officials, politicians, investment communitees contact with journalists, media stakeholders, shareholders, participation in events, competitions and other marketing activities, when we use third-party suppliers and agencies to support our business, e.g. IT and digital support, drivers and carriers, co-operation with organisations, retailers, external consultants, Niconovum ambassadors, cleaning firms, food suppliers, on site guards, etc.

Categories of personal data and sources
We may process the following categories of personal data about you:

Ordinary personal data:
Name, job title, workplace, log in details, signature and contact information such as your email and telephone number as well as other information that you choose to give us. We might also process copy of passport or other ID for KYC purposes.

Information about and related to the task/job/case etc. that our relationship concern, including all communication and processing of personal data in this regard, e.g. communication about our (potential) co-operation, our products and sales and distribution of our products, orders and returns, negotiations, potential disputes and complaints, general business matters, market, product and sales analysis, strategic, economics and budget managements, evaluations and performance, billing, invoicing and bookkeeping matters, crisis management, project and planning, external affairs and audits, branding and marketing, politics, business strategy, business plans, account and (potential) customer and account management, segmentation and service, management of IT systems and support etc.

Information related to your participation in events hosted by us or other events that we encourage you to participate in together with us.

If you are visiting or working at our locations, we may also process information about you through our use of CCTV surveillance and logging of the use of access cards.

Sources:
We collect your personal data either directly from you or from the third party that you work for a have a relation to: Niconovum’s customer, supplier or other third-party that we work with or have a relation to.


Legal basis for the processing

We process your personal data on the following legal bases:
Article 6.1.c (necessary for the fulfillment of our legal obligations to perform KYC checks of our customers)
Article 6.1.f (necessary for the pursuit of Niconovum’s legitimate interest in business operations and development), including:
- communication and co-operations with customers, suppliers and other third parties and business partners that we work with or have a relation to,

- production of products,

- sale and distribution of products,

- marketing of our products and our business

- customer management and development

- security measures, such as the use of surveillance and access cards

- as well as other business-related matters.


Recipients
We may share your personal data with:

  • Business partners and third parties, including suppliers and vendors, that we work with to assist our company (e.g. suppliers, warehouses, carriers, other service providers, technical and IT, legal and digital support)
  • Social media depending on the character of our agreement and the actual circumstances, e.g. if you are an ambassador for Niconovum or if you participate in an event hosted by Niconovum
  • Group entities
  • Public authorities if requested
  • The third party that you work with or have a relation to; Niconovum’s customer, supplier or other third parties and business partners
  • (Potential) purchasers, sellers and advisors in case of a sale or purchase
  • Hosting events that we participate in with our customers as well as even bureau assisting us with planning these


Data retention
We will retain personal data processed for this purpose for:

As a main rule we will retain your personal data for up to five years as from the end of the year in which the last purchase or delivery was made, or as from the end of our relationship/collaboration or the relationship/collaboration with the party that you represent or have a relation to.

However, we may store the personal data for an extended period if deemed necessary in a specific case, e.g. for establishing legal claims or in order for Niconovum to be able to document the relationship and/or certain circumstances with respect to the customer, supplier or other third-party.

We may also delete your personal data earlier, which will be the case for example if you appear on CCTV, if you have participated in an event, a quiz or any other marketing activities.

Some inquiries follow the retention periods as mentioned under “When communicating with us or our customer service” – please refer to this purpose for more information.


3. TRANSFERS TO COUNTRIES OUTSIDE THE EU/EEA

In some cases, we will be transferring personal data to countries outside the EU/EEA.
Such transfers will take place on the basis of the following legal basis:
a) The country/countries has/have been deemed by the Commission of the European Union to have an adequate level of protection of personal data, i.e. the country is a “secure/adequate third country”

b) The country/countries has/have not been deemed by the Commission of the European Union to have an adequate level of protection of personal data. We will provide appropriate safeguards for the transfer:

• through the use of "Model Contracts for the Transfer of Personal Data to Third Countries", as published by the Commission of the European Union, or any other contractual agreement approved by the competent authorities. You may obtain a copy of the contract/agreement by contacting us at gdpr_emails@Niconovum.com.

c) In the absence of a decision that the country is secure/adequate and appropriate safeguards as mentioned above the transfer might in some, however limited cases take place if i) you have given your consent to the transfer, ii) the transfer is necessary for the performance of a contract between you as a data subject and Niconovum as data controller or the implementation of pre-contractual measures taken at your request, or iii) the transfer is necessary for the conclusion or performance of a contract concluded in the interest of you as a data subject between Niconovum as the controller and another third party.


4. AUTOMATED DECISIONS
We will not use automated decision-making pursuant to GDPR article 22.

5. MANDATORY INFORMATION
Some of the information we process about you might be mandatory for us to collect in order to provide you the service that you request. The consequence of not providing us any mandatory information is however alone that we will not be able to provide you the requested service.

6. YOUR RIGHTS
You have the following rights:

  • You have the right to:
    - request access to your personal data (GDPR article 15)
    - request rectification of your personal data (GDPR article 16)
    - request erasure of your personal data (GDPR article 17)
    - have the processing of your personal data restricted (GDPR article 18)
    - receive your personal information in a structured, commonly used and machine-readable format (data portability) (GDPR article 20)
    If processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. Your withdrawal will not affect the lawfulness of the processing carried out before you withdrew your consent. You may withdraw your consent by contacting us at info@niconovum.se and +46 (0)42 19 94 43. If you wish to withdraw your consent with respect to cookies, please also see our cookie overview and policy.

    Furthermore, you have the right to object to processing of your personal data as follows.

    • If processing of your personal data is based on article 6(1)(e) or article 6(1)(f), see above regarding legal basis, you have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data.

    • Where your personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data about you for such marketing.

You can take steps to exercise your rights by contacting us at info@niconovum.se and +46 (0)42 19 94 43
There may be conditions or limitations on these rights. It is therefore not certain that for example you have the right of data portability in the specific case - this depends on the specific circumstances of the processing activity.

You may also always lodge a complaint with the local data protection supervisory authority:

The Swedish Data Protection Agency, Datainspektionen,
Drottninggatan 29, plan 5
111 51 Stockholm

Email: datainspektionen@datainspektionen.se
Phone: +46 (0)08-657 61 00

Last updated: 5 January 2021