Privacy Notice
This Privacy Notice was published 2022-09-05
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?
- 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 Notice
- How do you contact us?
1. Background
Your privacy is important to us.
This Privacy Notice (“Privacy Notice”) explains how RosholmDell Advokatbyrå AB (“RosholmDell”, “we”, “us”) processes your personal data in a legal, appropriate and safe manner when you or the company you represent purchase our services, visit our website or come in contact with us in some other way.
The Privacy Notice describes how RosholmDell 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”). In addition to the Data Protection Rules we are bound by law and the Swedish Bar Association’s code of conduct to exercise confidentiality regarding information that occurs in our business. These rules normally prevent us disclosing information without the client’s approval, even regarding other data than the client’s own.
In addition to this Privacy Notice, our General terms and conditions apply to any purchases of our services.
2. Definitions
In this Privacy Notice, 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 and photo (“Personal Data”).
This Privacy Notice describes how we Process your Personal Data. The term “processing” refers to e.g. our registering, storing, and in other ways using your Personal Data in such a manner as is described in this Privacy Notice (“Processing”).
3. When do we Process your Personal Data?
The Privacy Notice applies in the following cases when Processing of Personal Data arises in our business:
(i) when RosholmDell provides services to you or the company you represent;
(ii) to mailings of invitations to vented and other information;
(iii) upon your participation in courses, workshops, seminars and events that are held or arranged by us;
(iv) in connection to visits to our website www.rosholmdell.se (“Website”) or via social media platforms;
(v) when you apply for a job with us; and
(vi) to requests or other contacts with us via e-mail or phone.
4. Data controller
RosholmDell Advokatbyrå AB, Reg. No. 556858-6290, Kungsgatan 12, 352 33 Växjö, Sweden, is the data controller for the processing of your personal data which is carried out in accordance with this Privacy Notice.
5. Why do we Process your Personal Data?
RosholmDell Processes Personal Data regarding our clients, our clients’ representatives and contact persons, our clients’ associates and clients, potential clients, adverse parties as well as representatives or contact persons of adverse parties, potential adverse parties, witnesses, employment-seekers, suppliers and other associates. RosholmDell only collects and Processes your Personal Data for specific purposes. This entails that Personal Data is Processed in order to:
(i) 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;
(ii) provide seminars, workshops, courses, and other events;
(iii) enable general customer relationships management (quality management, statistics, market and client analyses, as well as business and methodological development) and customer service, e.g. when you contact us via e-mail, phone or via our Website.
(iv) 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;
(v) 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;
(vi) process a job application;
(vii) prevent fraud, money laundering and financing of terrorism, and carry our risk management; and
(viii) 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 for you or the company you represent.
In addition to the Personal Data you provide to us, or that we collect when providing our services, we may also collect Personal Data from third parties. These third parties vary from time to time but include inter alia suppliers of public record information, such as the Swedish Companies Registration Office’s business register or the National Land Survey’s property register, as well as credit rating agencies or banks from where we obtain information regarding creditworthiness or information in order to conduct anti-money laundering controls.
You are not obligated to provide us with Personal Data but if you wish not to, this may lead to us not being able to undertake an assignment as we will not be able to carry out the necessary disqualification controls and/or anti-money laundering controls.
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:
(i) name:
(ii) billing and delivery address;
(iii) phone number;
(iv) e-mail address;
(v) title of profession and place of work;
(vi) personal identification number;
(vii) bank account number;
(viii) payment information;
(ix) client number;
(x) copy of id ID-documentation;
(xi) information regarding health in connection with, for example, registration of food preferences and allergies;
(xii) reviews;
(xiii) resumé;
(xiv) customer references; and
(xv) information in correspondence with you.
The Processing of Personal Data is necessary in order for RosholmDell to provide its legal services and perform and administer the assignment and in order to look after you interests and thereby fulfil the agreement that has been entered into with you. In situations where you act as a representative or contact person for a company or organisation that is a client of RosholmDell or in any other way collaborates with RosholmDell, 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 RosholmDell to provide good service and client care, and thereby meet our legitimate interest of developing our business and communicate our contacts in an efficient and client friendly manner. As a part of this, RosholmDell 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 RosholmDell 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 client, 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 after obtaining 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 RosholmDell to comply by its obligations stemming from applicable legislation, court rulings, decisions taken by the authorities, or the Bar Association’s code of conduct. Such obligations may e.g. follow from the Accounting Act (1999:1078), the Money Laundering and the Financing of Terrorism (Prevention) Act (2017:630), or what constitutes professional conduct when conducting disqualification controls.
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 Notice.
The Majority of the Personal Data which is Processed is stored for a period of ten years from the day of the completion of the assignment, in accordance with the RosholmDell’s obligation under the Bar Association’s code of conduct, or for the longer period which is necessary due to the nature of the assignment.
Personal Data which is Processed in order to develop, analyse, and inform about RosholmDell’s services, is stored for as long as we have a business relationship with you, your employer or the company or organisation you represent.
If you have given your consent to the Processing of your Personal Data, RosholmDell 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 RosholmDell’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 necessary or statutory for each purpose.
8. Social media platforms
RosholmDell uses Facebook, Instagram and LinkedIn as platforms to get in contact with our clients, as well as market and inform about our business and our services. In connection with this, RosholmDell 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. RosholmDell 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. RosholmDell may also, based on what we deem necessary, remove content that has been published on our Facebook, Instagram, or LinkedIn page.
9. Your rights
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 Notice.
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 RosholmDell. 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 RosholmDell, without unnecessary delay, erases your Personal Data. Personal Data shall be erased in the following cases:
(i) if the Personal Data is no longer necessary for the purposes for which it was collected;
(ii) if you withdraw your consent and the Processing was based solely on consent;
(iii) if Processing is carried out for purposes of direct marketing and you oppose your Personal Data being used for such purposes;
(iv) if you oppose the Processing of Personal Data after a balancing of interests has been carried out and your interest outweighs ours;
(v) if your Personal Data has not been Processed in accordance with the Data Protection Rules; or
(vi) 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, as well as from our obligation to store all assignments for a period of at least ten years from the completion of the assignment in accordance with the Bar Association’s code of conduct. 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 RosholmDell temporarily restricts the Processing of your Personal Data. Such a restriction can be requested in the following cases:
(i) if you consider the Personal Data we have about you to be incorrect and in connection with this have requested rectification;
(ii) 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
(iii) 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, RosholmDell 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. RosholmDell 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.
10. 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.
11. 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, RosholmDell 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 Notice and in order to fulfil one or more of the purposes listed in this Privacy Notice. When such third parties are data processors for RosholmDell 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.
RosholmDell may transfer your Personal Data to countries outside the EU/EES, if it is necessary due to the nature of the assignment. The assignment might e.g. need assistance from a foreign counsel or involve an international transaction or dispute. Such transfer will in such case always be carried out in a legal and safe 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 RosholmDell’s liability insurance provider and/or to comply with a court ruling or abide by the verdict of a legal process. We will also disclose your Personal Data when, within the framework af an assignment, this is necessary in order to look after your rights. Such transfers can e.g. be made to courts, authorities, adverse parties, the counsels of adverse parties, as well as to insurance companies in connection to an application for a legal expenses insurance.
Your Personal Data may also be disclosed to e.g. your/your company’s accountant in accordance with agreements with you, to banks in connection with handling of client funds, when the bank requires information, and to the Swedish Bar Association when we are obligated to do so.
RosholmDell will not sell your Personal Data to a third party unless we have previously obtained your consent. However, we may, in the case that RosholmDell decides to 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.
12. 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., RosholmDell takes on appropriate technical and organisational information safety measures. RosholmDell also takes measures in order to protect your Personal Data against unauthorised access, misuse, reveals, changes and damages. RosholmDell 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.
13. 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 Swedish Authority for Privacy Protection, see https://www.imy.se/en/RosholmDell annually reviews this Privacy Notice.
14. Third party’s terms and conditions
RosholmDell’s services may in some cases be subject to third party’s terms and conditions. RosholmDell 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.
15. Changes to the Privacy Notice
RosholmDell reserves the right to change this Privacy Notice 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, the Swedish Bar Association, or other authorities issuing statements pertaining to the Data Protection Rules. Further, this Privacy Notice will be updated when it is necessary due to changes in our business activities.
If RosholmDell makes comprehensive changes to this Privacy Notice or changes concerning how we Process your Personal Data, you will be informed of this before such a change come into force.
16. How do you contact us?
If you have questions pertaining to this Privacy Notice or the current Processing of your Personal Data, wish to file a request in accordance with this Privacy Notice or wish to report a violation of this Privacy Notice etc., you are welcome to contact us via e-mail, phone or letter.
RosholmDell Advokatbyrå AB
Kungsgatan 12
SE-352-333 Växjö
Sweden
E-mail: info@rdlaw.se
Phone number: +46 470 78 88 55
