Latest update: 2019-11-12

This personal data policy applies to the companies within the ProSales Group, with the parent company Ganevi Holding (corporate registration number 556666-5351).

The policy applies to such personal data that we collect via our digital platforms, when you purchase one of our services, when you register for a subscription or user account, register for one of our events and conferences, participate in one of our competitions, or when you contact our customer service (the “Services”).

We protect your privacy, and it is important that you feel safe when you entrust us with your personal information. This document describes how we collect and process your personal information. It is based on current data protection legislation and clarifies how we collect and process personal data.

Unless otherwise stated, the company within the ProSales Group whose Service you are using is responsible for the use of personal data collected through the Services it provides. The ProSales Group consists of the following companies:

ProSales Institute Sweden Ltd. (corporate registration number 556246-8172; ”PI”)

ProSales Consulting Sweden Ltd. (corporate registration number 556595-1505; ”PC”)

ProSales Systems Sweden Ltd. (corporate registration number 556666-5351; ”PS”)

There may be additional terms that apply to some of the Services we offer. Please read these when buying one of our services, when registering for our newsletter or user account, when signing up for one of our events and conferences, when participating in one of our competitions, or when contacting our customer service.

Within the ProSales Group, we are sharing administrative systems, as well as managing joint customer support and data analysis, and therefore we are sharing certain personal information about our users and customers in accordance with this policy.

PERSONAL DATA WE COLLECT

Personal data mean all kinds of information that can be derived from an individual. We process the following types of information about you:

• Identity (e.g. first name, last name and title)
• Contact information (e.g. email address, phone number, and billing address)
• Authentication data (encrypted passwords)
• Technical information (e.g. login, IP address, browser and version, time zone, operating system and other information about what technology you are using when visiting our sites)
• Profile (e.g. feedback, survey responses, areas of interest, and favorite pages on our site)
• Usage (e.g. how you are using our sites, our social media channels and our services)
• Marketing and communication data (your preferences when it comes to getting marketing communications from us)
• Financial information (e.g. billing and payment information)
• Transactions (information necessary to make payments in case of a purchase, e.g. credit card numbers and the associated security code)
• Purchase history (data about your purchases: sum and time of purchase)

We do not collect any sensitive data about you, e.g. ethnicity, belief, sexual orientation, political views, health data, biometric data, or data about crimes or punishment.

HOW WE COLLECT PERSONAL DATA

We collect information about you in several different ways:

DIRECT INTERACTION

Some information you provide directly, for example when filling out a form when signing up for a newsletter, registering as a user on our site, asking us to send you material, filling out a survey, giving us feedback, registering for an event or contacting us for support.

AUTOMATIC COLLECTION

When you are using our site and our services, we can automatically collect technical data about your equipment, reading and use. We collect this information through the use of cookies, server logs and similar technologies. See the section "Cookies" below for more details.

THIRD-PARTY SOURCES

We can also collect information from external companies or authorities, so-called third-party sources. It may vary over time but has previously included:

• Data providers from whom we receive or buy identity and contact information, e.g. Allabolag.se, or Bisnode
• Social networks (we collect information from social media about our visitors to target relevant offers or display relevant ads on, for example, Facebook and Linkedin)
• Partners (we can access information from companies we are cooperating with to offer Services or participate in joint marketing)
• Public sources, for example open government databases or other data available to the public

LEGAL BASIS FOR COLLECTING PERSONAL DATA

We will only process your personal information when there is legal basis. Personal data is processed with the support of one or more of the following reasons:

• The data is necessary to fulfill our obligations according to an agreement
• We have a legitimate interest in processing the personal datum and we do not infringe any of your rights and freedoms
• The datum is necessary to fulfill our other legal obligations

HOW WE ARE USING PERSONAL DATA

We are using information that we collect about our customers and users for five main purposes:

1. Customer care and information about our services and events
2. Personalized services
3. Improvement and adaptation of our services
4. Sales and marketing activities
5. Research studies and surveys

CUSTOMER CARE AND INFORMATION ABOUT OUR SERVICES AND EVENTS

We are using personal information to carry out your purchases with us and provide you with our Services. For example, we may contact you by e-mail, telephone or other means to inform you when the Service is about to terminate or feed back to you in a customer service matter. We may also use all the other personal information that we have collected about you to handle your question or matter depending on what is relevant in each case.

PERSONALIZED SERVICES

Some of our Services mean that we customize them based on what we know about your interests, your company, and your title in order to make the Service as good as possible for you. We are analyzing and grouping such data and making selections and groupings, for example in the form of invitations, table placement, or customization of what content is displayed to you in our web portal.

IMPROVEMENT AND ADAPTATION OF OUR SERVICES

We are using data to improve our existing Services, for instance by updating features and gaining an increased understanding of how we can make the user experience better for you. We are mainly using anonymous or anonymized data at the aggregate level to do this type of analysis. However, we may sometimes also use personal information that we have collected if it is relevant, for example questionnaire responses in evaluations, to improve content in our events.

SALES AND MARKETING ACTIVITIES

We are using personal information to provide you with relevant marketing that you may be interested in when you visit our web pages and subscribe to our newsletters. This enables us to direct interest-based advertising to our users who visit our web pages. When you visit our web pages, we place cookies on your computer that are specifically designed to remember how you have navigated on our web pages and in our social media channels. These are used to help us understand the types of pages you are interested in. We can then provide recommendations on services based on your perceived interests.

We are also use retargeting, which allows us to display advertisements to you based on your reading and click patterns on a website that is not controlled by ProSales or social media. For example, if you have visited our website, you may see ads from us showing offers that you have visited on our web pages. You may be reminded of our Services through an advertisement on, for example, di.se.

You always have the right to object to direct marketing. Read more in the section “Your individual rights”.

Here you can ask us to stop sending ads at any time: https://www.prosales.com/hs/manage-preferences/unsubscribe-simple

RESEARCH STUDIES AND SURVEYS

The core of ProSale’s activities is continuous surveillance of the world and investigation of current issues in the marketing and sales area. Therefore, we can use your personal information to contact and remind you about surveys and interviews. We treat your answers strictly confidential, and as soon as the data collection is complete the results are anonymized by deleting the email address from the response data.

HOW WE SHARE PERSONAL DATA

Our starting point is to not disclose your personal information to third parties unless you have consented to it or if it is not necessary to fulfill our obligations according to agreement or law. We may, however, for the purposes above, have to share your personal information with other companies within the ProSales Group, or with companies that are executing services on our behalf. You can find a list of these companies below, more precisely below “Third-party actors”.

If we share information about you with our suppliers, we have ensured that these companies comply with our personal data processing requirements described in this policy by establishing personal data access agreements.

We share the payment information you provide to go through with a purchase with banks and other payment institutions that process payments or provide other financial services to prevent fraud and reduce credit card risks, for example the payment service company DIBS.

We also share information with companies we use to provide marketing and traffic measurement. We will disclose personal data as a part of a joint deal, for example a merger or a sale of assets.

Finally, we may need to disclose information about you when we believe it is necessary to:

• Follow the law or during a legal process and provide information to the police and other proper authorities
• Protect our customers, for example to prevent spam or fraud attempts
• Manage and maintain the security of our products, including preventing or checking an attack on our systems or networks
• Protect rights or property belonging the ProSales Group, including enforcing the terms governing your use of the Services

INTERNATIONELL ÖVERFÖRING

När vi delar dina personuppgifter med tredje part i enlighet med vad som angetts i denna personuppgiftspolicy, kan dina personuppgifter komma att överföras till en stat som inte är medlem av EU eller EEA. Den här personuppgiftspolicyn gäller även om vi överför personuppgifter till andra länder.

COOKIES

At www.prosales.com and our other websites, we use cookies.

Cookies are information stored in your computer’s browser when you visit a website, and these can at a later visit also be retrieved from the browser for different types of applications. They contain data on how a user has moved on the website so that it on recurrent visits can display tailored information based on the user’s latest visit. Cookies can also be used to analyze traffic, for marketing and for development of the websites. Cookies are used by almost all websites and cannot damage your system.

We use cookies to track your use of our websites. It allows us to understand how you are using the sites and see patterns in your and others usage. It helps us to develop and improve the websites and our Services based on your needs.

On our websites, two types of cookies are used: temporary ones and permanent ones. Temporary cookies, or session cookies, contain temporary information between page loads. They are only stored on your computer during a session and are automatically deleted when you close your browser.

Permanent cookies are stored for a shorter or longer period of time as a file on your computer and remain when you close your browser. The cookie can be read by the website that created it when you visit the site again. Some permanent cookies can be used to track a user’s visit to several different websites. We are using the following permanent cookies:

If you want to see or change what cookies you have accepted, you can usually do so in your browser settings. You can set your browser to store some or no cookies, or to alert you when websites are trying to store cookies. As a visitor you should know that if you do not allow cookies, the website will work but you will have an inferior user experience.

YOUR RIGHTS AND OPTIONS

It is important that you understand what rights you have regarding the processing of your personal data, which we will inform about below. Contact information about where you can turn to take advantage of one of your rights can be found below the heading “Contact” below.

You have the following rights:

• You have the right to request access to and access to a copy of your personal data (a so-called register extract), request correction of incorrect information and, in certain circumstances, request that your personal data be deleted.
• If our processing of your personal data is based on your consent, you have the right to at any time withdraw the consent for future processing of your personal data.
• You have the right to to, in some cases, object to the use of your personal data or require that we limit the processing of your personal data.
• You have the right to at any time object to direct marketing, which means that we are no longer allowed to continue using the information for that purpose.
• You have the right to file a complaint with a data protection authority. Datainspektionen (The Data Inspection Board) is the Swedish that exercises supervision of how we as a company comply with the legislation.

Exercising your rights is free of charge. We reserve the right to, in the case of an unreasonable or a manifestly unfounded objection or request, charge a reasonable fee for the action or, alternatively, not take any action.

We will respond to requests within 30 days. Measures are taken within a reasonable time which, depending on the circumstances, can be up to three months. In any case, we will keep you updated on the status of your case.

STORAGE

We will protect your personal information from unwanted access, use and disclosure. For example, personal information you enter is stored on computer systems that have limited access and are located in protected premises. When transmitting highly sensitive data (such as credit card numbers and passwords) over the Internet, we will protect these data with encryption.

We may store your personal data using our own technology, through cloud services and with third parties that we have contracted to support our business operations. Such third-party organizations will not process your personal information and do not have access to it except for cloud storage and access by us, and we require such operators to apply at least the same level of IT security that we are using ourselves to protect your personal information.

The personal data processing mainly takes place within the EU / EEA. In some cases, we may use suppliers established outside the EU / EEA. If the personal data processing takes place outside the EU / EEA, it is done with legal support through decisions by the EU Commission that the country ensures an adequate level of protection for the processing of personal data or that other appropriate security measures are in place.

We will store personal data for as long as it is necessary for the reasons for which they are used, for example as long as is required for us to provide the Services, to maintain and improve existing Services, to send necessary communication and market communication, and to fulfill our obligations under law . Since the needs may vary for different types of data and for different types of Services and contexts, for how long we will save the data will vary.

The criteria that determine for how long personal data will be saved are:

• For what reason we are using the data, i.e. if we are using the data to meet legal requirements they will be saved for a longer period of time than, for example, contact information for direct marketing.
• How the data are saved, i.e. data that is not pseudonymized is saved for a shorter period of time than if they are not pseudonymised.
• What relationship we have with you, i.e. if you are an existing, former or potential user / customer, or if are you visiting us without being logged in.

We have the right to use your contact information for direct marketing while we have a user or customer relationship and a certain amount of time after our user or customer relationship has been terminated as long as you have not objected to it. We will store your information for up to 36 months after termination of the Service.

We may contact potential customers by telephone or email to promote our Services. If you choose not to enter into a customer relationship with us, we will save your contact information up to 12 months from the time of contact.

If you have registered a user account, we will use your information on, for example, interests and favorites and reading history until you have closed your account and up to 36 months after that if you do not request that we delete certain information. We will save data to analyze user and customer behavior in order to improve our Services and for interest-based marketing.

Your personal data will be deleted or anonymized when they are no longer relevant for the purposes for which they were collected. When analyzing customer insights, trends etc., we are using anonymous data that does not consist of personal data or pseudonymized data that cannot be attributed to a particular person.

Your personal data will be stored for a longer period of time than stated above if we are required to do so by law, or to retain data that must be retained to resolve a dispute or if you have consented to it. We will use your information for marketing purposes only if it is permitted by law and if you have not objected to it.

MODIFICATIONS

We will update our personal data policy when necessary to reflect customer feedback and changes in our Services. When the policy is updated, the date of the latest update is changed at the top of the policy, and the changes are described at the bottom of the page below “Change history”, after which the changes will take effect.

If there are major changes in the policy or in how we are using your personal information, you will be notified through notifications on the web page or e-mails before the changes will take effect if required by law. Please read this personal data policy from time to time and you will be informed on how we are protecting your personal information and your integrity.

THIRD-PARTY ACTORS

ProSales are using third-party actors for certain tasks, and for storing personal information and related data. It is necessary to provide you as a customer with the best possible services, follow-ups and customer experience. We are responsible for personal information and all stored data. Here is a list of the third-party actors we are using:

Glesys                        Storage of all web data.

Google                       Company mail and document storage.

SMS-teknik               SMS service provider. Is managing phone numbers.

Oneflow                     E-signing tool. Is handling personal information related to customer agreements.

Getaccept                   E-signing tool. Is handling personal information related to customer agreements.

Hubspot                     CRM and marketing tool. Is handling personal information for potential and existing customers.

Eventbrite                   Event system. Is handling personal information related to notifications and events.

Delegia                       Event system. Is handling personal information related to notifications and events.

CONTACT

• If you want your personal information deleted, please send an email to info@prosales.com
• If you in any other way want to limit our processing of your personal information, please send an email to info@prosales.com
• If you want us to stop sending emails to you for marketing purposes, you can change your settings here: https://www.prosales.com/hs/manage-preferences/unsubscribe-simple
• If you have other viewpoints, ideas, opinions and comments regarding our Services, you are welcome to send an email to info@prosales.com

REVISIONS

2019-11-12 Unsubscribe link changed to: https://www.prosales.com/hs/manage-preferences/unsubscribe-simple