- When do we Process your Personal Data?
- Data controller
- Why do we Process your Personal Data?
- What Personal Data is Processed on what legal basis?
- 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
- How do you contact us?
Your privacy is important to us.
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 from disclosing information without the client’s approval, even regarding other information than the client’s own.
3. WHEN DO WE PROCESS YOUR PERSONAL DATA?
(i) when RosholmDell provides services to you or the company or organisation you work for or on behalf of;
(ii) to mailings of invitations to event 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 contacts 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
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 for us to:
(i) Provide our services and fulfil the agreement entered into with you, the company or organisation you represent, or the company or organisation you work for or on behalf of;
(ii) arrange 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 or social media platforms;
(iv) inform about and market our business through, inter alia, publishing customer references and other material on our Website, in presentation material used at events, or in brochures;
(v) provide information regarding events and news, and address 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 out risk management; and
(viii) comply with other 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 or organisation you work for or on behalf of.
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 always 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 BASIS?
The Personal Data listed below is Processed by us for the purposes explained under section 5 above:
(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-documentation;
(xiii) customer references; and
(xiv) information in correspondence with you.
The Processing of your Personal Data is necessary in order for RosholmDell to (i) provide its legal services, (ii) perform and administer its assignment, (iii) in order to look after our client’s interests and thereby fulfil the agreement that has been entered into with you or the company or organisation you work for or on behalf of. 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 on or 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 Information on your consent or on our legitimate business interest.
We may also in other situations Process your Personal Data with your consent, e.g. when you consent to our marketing or 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 also 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.
Your Personal Data is also Processed, in relevant situations, 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?
The majority of the Personal Data which is Processed in connection to an assignment is stored for a period of ten years from the day of the completion of the assignment or for the longer period which is necessary due to the nature of the assignment. This is in accordance with the RosholmDell’s obligation under the Bar Association’s code of conduct.
Personal Data which is Processed in connection to a job application is stored for 12 months after your application process has ended. 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 work for or on behalf of.
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.
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 is necessary or statutory for each purpose respectively.
8. SOCIAL MEDIA PLATFORMS
RosholmDell uses Facebook and LinkedIn as platforms to come in contact with our clients, as well as for marketing purposes and to otherwise 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 visitor 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 kindly ask our visitors 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 page or LinkedIn page.
9. YOUR RIGHTS
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 or Personal Data 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, as far as possible, correct, block or erase such Personal Data.
Right to erasure
You have the right to request that we, without unnecessary delay, erase 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 your 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 may 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, all 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 adhere to, 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 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 Process 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 to 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 Process about you and which is Processed in an automated manner, in a machine-readable format. This may inter alia be 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 our Processing of your Personal Data, you decide if and when your wish to withdraw the consent that you have given to the Processing of your Personal Data. You can withdraw your consent by (i) contacting us, or (ii) following the link in the mailings if the consent regards receiving marketing information or other information.
11. TO WHOM DO WE TRANSFER YOUR PERSONAL DATA?
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 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 of an assignment, this is necessary in order to look after your rights or rights of the company you work for or on behalf of. 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. accountants in accordance with agreements with you or the company you work for or on behalf of, 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. However, we may, in case that RosholmDell decides to sell, buy, merge with another company 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 hacking attacks etc., RosholmDell takes several 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 Datainspektionen, see www.datainspektionen.se.
14. THIRD PARTY’S TERMS AND CONDITIONS
RosholmDell’s services may in some situations 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 or in our e-mails, to other websites.
16. HOW DO YOU CONTACT US?
RosholmDell Advokatbyrå AB