Privacy Policy THIS IS TRICKLE’S PRIVACY POLICY FOR TRICKLE.SE AND FOR THE SERVICES THAT ARE PROVIDED THROUGH THIS SITE BY TRICKLE AB, WITH COMPANY REGISTRATION NUMBER 559163-3465. We use information that we collect for the following main reasons, which are described in more detail below: To operate our business and provide (including improve and adjust) the services we offer To fulfill our commitment as a client, supplier and employer To send communication, including campaigns and newsletters To market our services and show advertisements, on our own sites and on platforms where we have permission from you or where it is allowed according to law. Due to these reasons, we combine the data we collect to give you a smoother, more coherent and personally-tailored experience. Please read on how we use your personal data, how it affects your integrity and how you claim your rights. PERSONAL DATA THAT WE COLLECT Trickle collects data to make sure our services function effectively and that we can give you the best possible experience. Some of this information you provide to us directly, for example when you sign up to our newsletter, download a guide, register for a Trickle event, buy a Trickle Academy course, or contact us for support. We receive part of the information by registering how you interact with our Services, for example by using web technology like cookies on our sites and by receiving user data from program software that runs on your device. When we treat your personal data, we do this with your consent and/or based on legitimate interests and needs Which data we collect depends on the context of your interactions with Trickle, your choices, including your integrity settings, and the services and functions you use. The data we collect can include the following: Name and contact details. We collect your first and last name, email address, job title, company, number of employees at the company, and other similar contact details. Demographic data. We collect data about you, such as age, sex, country and language setting. Device and user data. We collect data about your device and how you and your device interact with Trickle and our services. For example, we collect information about which pages you visit and which guides you download. We also collect data about the device, connection and configuration, which means data about your device and the network you use to connect to our Services. This can also include information about operative system and IP address. Interests. We collect data about your interests, for example which kind of content you are most interested in. On top of the interests that you expressly tell us, your interests can also be derived or concluded from other information we collect. We also collect information that you provide to us and the content in messages that you send to us, such as information provided in our contact form or feedback that you write, or questions and information you submit to support. HOW WE USE YOUR PERSONAL DATA We use information that we collect for the following main reasons, which are described in more detail below: To operate our business and provide (including improve and adjust) the services we offer To fulfill our commitment as a client, supplier and employer To send communication, including campaigns and newsletters To market our services and show advertisements, on our own sites and on platforms where have permission from you or where it is allowed according to law. Due to these reasons, we combine the data we collect to give you a smoother, more coherent and personally-tailored experience. To improve the protection of your integrity, we have built in technical and organizational measures that are formed to prevent certain combinations of data. [For example, we have limited access to the data that we collect and on our part, we can only see the information we need to fulfill our assignment, so-called level security safety.] Provide and improve our products and services. We use data to provide and improve the services we offer and to perform necessary business operations. This includes managing the services, maintaining and improving the services, developing new functions and offers. We also use marketing automation software to improve our products and services as well as provide a better experience on the site. Communication. We use data to stay in touch with you. For example, we can contact you by [email, phone or other means] to answer your questions about our offers and services. We also send you newsletters when you subscribe to our emails. If you no longer wish to receive our newsletter, you can unsubscribe from a specific newsletter or all of Trickle’s communications. We will then delete your personal data. Advertisements. We use the data we collect through our interactions with you on our home page, emails and third party websites, to show advertisements. For example to: Market a local breakfast seminar or conference. Market a guide, news item or article. The ads you see on our sites and in social media can be selected based on data about you that we process, such as your interests, your job title, your company, search queries or content you consume. The ads can also be selected from other information that we find out about you with time and with the help of demographic data, position data (where possible), search queries, interests, user data from our website and from our advertisers’ web sites. We refer to these ads as “interest-based advertising” in this policy. REASONS WHY WE SHARE YOUR PERSONAL DATA It can sometimes be necessary for us to share your information with our sister companies or with companies that perform services on our behalf so they can deliver the services and products that you have ordered. We also share information with companies that we have hired to protect and secure our systems, and these companies need access to personal data in some cases in order to provide these services. In the instances where we share information about you with others, we have made sure that these companies follow our demands for data protection and they are not allowed to use the personal data they receive for any other purpose. We may also share personal data as part of a joint business deal, for example a merger or sales of assets. Finally, we may need to share or save your personal data when we consider it necessary to: follow the law or legal process and provide information to the police or other authorized authorities, protect our clients, for example, to prevent spam or fraud, or to facilitate the prevention of death or serious injury, manage and maintain the security of our services, including preventing or stopping an attack on our systems or networks, protect the rights or property of Trickle, including enforce the terms governing the use of the Services. If we get information that someone uses our services to trade stolen intellectual or physical property belonging to Trickle, Trickle assigns the matter to the authorities. Please observe that some of our sites link to products and services from a third party, whose Privacy Policy is different from Trickle’s. If you enter your personal information to some of these services, your data will be treated according to their respective privacy policy. HOW YOU ACCESS AND CONTROL YOUR PERSONAL DATA You can easily unsubscribe from our newsletters by clicking on a link in our emails. Through that link, you can also update and change your personal information, such as your email address, your job title and your company. If you want to be forgotten or get access to your data, please email distribution@trickle.se and we will return to you within 30 days. COOKIES AND SIMILAR TECHNOLOGY Trickle uses cookies to improve services and the user experience on our website and to perform necessary business operations, as well as provide statistics on the usage of the home page or service. If you visit a homepage, a small text file that contains text information, a so-called cookie, gets stored on the visitor’s computer. According to the Electronic Communications Act, which entered into force on July 1, 2011, anyone visiting web pages should be informed about what cookies are used for and agree to their usage. You can decide yourself if you accept cookies or not. This can be set in your web browser. YOUR INDIVIDUAL RIGHTS Trickle adheres to current data protection laws in the European Union, which includes the following rights: If processing personal data is based on your consent, you are entitled to withdraw your consent for future processing of personal data at any time. You have the right to request a registry extract (as defined in the law), access to a copy of your personal data, and request rectification and, in certain circumstances, deletion of your personal data. You are entitled to oppose the processing of your personal data. You have the right to file complaints with a data protection authority. As we process your personal information, we do so with your consent and/or on a need basis in order to operate our business, comply with our contractual and legal obligations, protect our systems, improve the content and quality of our website or meet other legitimate interests as described in the sections “How we use your personal data” and “Reasons why we share your personal data” above. SECURITY OF YOUR PERSONAL DATA Trickle works actively for the safe and secure management of your personal information. To secure your data we have introduced centrally-managed security measures. For example, we have encrypted and privileged portals for running servers and services. Trickle carries out annual internal audits where introduced IT and information security measures are tested and verifies compliance with processes, routines and guidelines. Please do not send sensitive information to Trickle via email. Sensitive data should be handled securely via SSL (Secure Sockets Layer), a 128 bit encryption service. Pages which use this technology have web addresses that start with HTTPS instead of http, such as Trickle’s own website https://Trickleagency.com. When sharing large amounts of documents or sensitive data externally, permission-restricted tools, such as SharePoint or other web-based file transfer over SSL, are used. OUR STORAGE OF PERSONAL DATA Trickle retains personal information as long as it is necessary to provide the products and services, fulfill the transactions you have requested and approved, or for other necessary purposes, such as complying with our legal obligations, resolving disputes and enforcing our agreements. Because these needs may vary for different types of data and for different types of products, services and contexts, actual retention periods may vary. Criteria that determine how long we store data are, for example: How long are personal data needed to provide the products and services? This includes, for example, maintaining and improving the performance of products and services, protecting our systems, and administering necessary business and accounting information. This is the general rule underlying the calculation of most storage periods. Is the personal information extra sensitive? In that case, a shorter retention period is usually used. Has Trickle adopted and informed about a specific retention period for a particular type of data? We store your contact information in our cloud-based marketing automation system. We keep the data for delivering educational materials (such as articles, guides) as well as interest-based advertising for up to 24 months if we do not get your permission to retain them for a longer period of time. You can always unsubscribe from our mailing list by clicking on the link in the email. Sensitive information is stored locked and restricted on our production server. They are continuously being removed after completion of customer assignments, regardless of whether the customer is active or not. Have users approved to the use of a longer retention period? In that case, we store the information in accordance with your permission. Does Trickle have legal, contractual agreements or otherwise committed to storing the information? Examples may be mandatory legislation on retention of information in certain jurisdictions, government orders to preserve data relevant to investigations, or data that must be retained in order to resolve a dispute. CHANGES TO THIS PRIVACY POLICY We update our Privacy Policy continuously to reflect changes to our Services. If there are major changes in the policy or how Trickle uses your personal data, you will be notified via web or email notification before the changes take effect. CONTACT US If you have questions about your personal data, a complaint or a question to our Data Protection Representative, please contact distribution@trickle.se. We will answer your query within 30 days. Any questions? Mail us +46 70 66 71 100 distribution@trickle.se Rosenlundsgatan 40 118 53 Stockholm