Privacy Policy
1. General
1.1 This privacy policy describes how Promote International AB, company registration no. 5565732962, (“Promote”, “we” or “us”) processes personal data.
1.2 Promote provides a web-based platform for training initiatives, consultancy services and courses
about training design (the “Service”).
1.3 The service is provided to Promote’s customers (“Customers”). When providing the service,
Promote will be processing personal data. Unless otherwise specified, Promote is the data controller
for the processing of personal data which takes place in accordance with this Privacy Policy.
1.4 Promote also processes personal data as data processor for customers who use the Service. In
these cases, the customer is the data controller for this processing. In this privacy policy, it is clearlystated if Promote performs processing as a data processor. For questions relating to the processingof personal data performed by Promote as data processor, please contact us or the Customer who isthe data controller for the processing.
1.5 Promote will only collect and process personal data in accordance with the Data ProtectionRegulation (EU 2016/679). This privacy policy also describes a data subject’s rights and opportunities
to e.g. request records.
1.6 The latest version of the privacy policy can be found on Promote’s website. Collection of personaldata
2.1 Promote processes the following data as data controller:(a) Personal data relating to those of a Customer’s users who use the service:– name– company name– e-mail– phone number– title– profile image– links to social media– self presentations– comments(b) If a person at a Customer contacts Promote by e-mail, telephone, or through the Service, Promotecollects name, phone number and e-mail address, depending on the contact form, as well as otherpersonal information necessary to assist the person contacting Promote.
(c) Personal data relating to contacts at potential customers:– name– e-mail– phone number– title

(d) Promote International is the accrediting body of the Brinkerhoff Certification for High
Performance Learning Journeys certification program. To authenticate achievements, Promote
International will keep a permanent record of certification along with personal details (name, email
address, organization).
(e) All live on-line sessions of the Brinkerhoff Certification for High Performance Learning Journeys
will be recorded. Recordings will be published on the corresponding Promote program. Therecordings will be deleted after a maximum of two (2) years.
2.2 During visits to the Promote Website or use of the Service, Promote also collects additionaldata, namely:(a) traffic data, location data, weblogs and other communication data as well as IP address, device
type, operating system and browser used by the visitor(b) the personal information which visitors themselves leave via live chat
3. How Promote processes personal data
3.1 Promote processes personal data to provide and improve the Service, and fulfil our commitments
to you. Promote processes personal data for the following purposes and based on the following legalgrounds.
Purpose of theprocessing

Legal basis for theprocessing

Categories of personal
Storage perioddata

In order to provide theService.

In order to fulfil
Three years from when a
The categories listed in
Promote’s contractual
customer stops using thesection:2.1 (a).
obligations.
service.

To be able to inform
Other legitimate
about Promote and theinterests.
Service.

1 year from when theThe categories listed in potential customer was
section:2.1 (a) and 2.2 contacted, unless the(b).
recipient does not object tofurther communication.

To ensure that content
is presented to users of
Other legitimate
the Service effectively,interests.
and to improve theService.

The categories listed in
1 year from user session.
section2.2.

To issue invoices andprocess payments forthe use of the Service.

In order to fulfil
Until the claim is paid, thenPromote’s contractual The categories listed in for up to seven years in
obligations and comply section:2.1 (a).
accordance with Swedish
with applicable law.
accounting rules.

To comply withapplicable legislation

In order to comply with The categories listed in In accordance with the law
applicable legislation. section 2.1 (a) + (b)(for seven years, accordingsuch as the Act onAccounting.

to Swedish accounting
rules).

To authenticate
Brinkerhoff Certification
Other legitimate
for High Performanceinterests.
Learning Journeys
certification

The categories listed in Until user revokes thesection 2.1 (d)certification.

4. Disclosure of personal data
4.1 Promote may transfer or share data with other parties processing data on Promote’s behalf, inorder for Promote to be able to provide the Service. Promote uses the following subcontractors or
categories of subcontractors.
Subcontractor (name Country/region where Mechanism for transfer toof service)
the service is provided third countries

Type of service

LinodeGermany

Not transferred

Hosting service server

AmazonGermany

Not transferred

Backup hosting

Freshworks

EUStandard Contracual Clauses(SCC)

CRM, digital marketingsystemVisma SPCS AB

EU

Not transferred

Invoicing system

Standard Contracual Clauses(SCC)

Video hosting service

Wistia Incorporated USA

4.2 Promote only cooperates with companies that process personal data within the EU/EEA or
companies that maintain the same level of protection as in the EU/EEA, e.g. by joining the so-called
Privacy Shield agreement between the EU and the US.
4.3 Promote discloses necessary personal data to authorities such as the police, tax authorities orother agencies if Promote is required to do so by law. An example of legal disclosure is disclosure
with the aim of combatting money laundering and financing terrorism.
5. Processing of personal data as a data processor
5.1 Promote processes personal data about a Customer’s employees. Such processing is carried out
by Promote as a data processor for the respective Customer, who is the data controller. Promoteprocesses personal data about a customer’s employees in accordance with the data controlling
Customer’s instructions, as well as the applicable data processing agreement between Promote andthe data controlling Customer.
5.2 For more information about which personal data Promote processes as data processor for aCustomer, we recommend that you read the relevant Customer’s information about their handling of
personal data, or contact the data controlling Customer.
6. Rights of data subjects

6.1 Right to records. Once per calendar year and at no cost to you, you have the right to receive
records of your personal data which we store and process. Your request must be submitted to us inwriting and bear your signature.
6.2 Right of rectification. You have the right to correct inaccurate or incomplete information about
yourself. You can correct inaccurate or incomplete information through the Service. You can also
contact us if you need help with this.
6.3 Data portability. For personal information you have provided to us, you have the right to request
a transfer to another provider. Contact us if you need help with this.
6.4 Deactivating and deleting user account (the right to be forgotten). You have the right to object toour processing of your personal data. The consequence of this may be that you can no longer use theService. If you want to delete your account, please contact us using the contact details below.
6.5 Marketing communications. You can always opt out of receiving marketing communications from
Promote by clicking “unsubscribe” in e-mail and SMS communications sent by Promote. Datasubjects are always welcome to contact Promote for help to opt out of Promote communications.
7. Security
7.1 Security is important to Promote, and we take adequate technical and organisational security
measures to ensure that personal data cannot be misused, lost or accessed by unauthorised persons
in connection with Promote’s processing of personal data in accordance with this privacy policy.
8. Changes to this data protection policy
8.1 Promote reserves the right to make changes to this privacy policy.
8.2 Any changes to this privacy policy will be published on our website. Please visit our website
regularly to stay informed of any changes.
9. Contact
9.1 For more information about Promote’s personal data management, or if you have questions, youare welcome to contact Promote on:
Promote International AB
info@promoteint.com
Tel: +46 8-58638800
9.2 If you are unhappy with how we process your personal information, you can contact the Swedish
Data Protection Agency, +46 8 657 61 00, datainspektionen@datainspektion.se, Box 8114, 104 20
Stockholm.
10. Effective dateThis privacy policy applies from 2018-05-25 and until replaced by an updated version.