Privacy Policy Below is a description of how we collect, use, and deal with the information, including personal information, which you provide us with, and which is generated as a part of the contract that is formed when you use our services and products. 1. Introduction Soluno BC AB, org.nr 556377-2317 (the “Company”) is the Data Controller of Personal Data for the processing of your personal data related to providing services within telecommunications (the “Service”) and is therefore responsible for ensuring that all Personal Data is processed correctly and in accordance with applicable data protection legislation. This Privacy Policy (hereinafter the “Privacy Policy”) describes the Company’s processing of your Personal Data and has the purpose of making you feel safe knowing how the Company processes your Personal Data. Personal Data means all types of information which can, directly or indirectly, be attributed to a living natural person. Within the Company’s business activities, there may occur Personal Data such as given names and surnames, personal ID numbers, telephone numbers, address, postal codes, e-mail addresses etc. (“Personal Data”). “Customer Data” is Personal Data connected to the Service – e.g. name, address, email, telephone number and social security number. It also includes information about which Service you use, and how you use them, order, user-ID, password and other information you have left when you have been in contact with us. “Traffic Data” is Personal Data connected to what happens when you use our Services. Traffic Data is used with the objective to send electronic messages though an electronic communications network when you use the Services. The Traffic Data is also used to invoice your use of the Services, and for instance shows who you have communicated with, the time that the communication started and ended, the duration of the communication and what networks was used. If you cannot find answers to your questions, please get in touch with us. You will find information about how to contact us under the heading “Contact Information” below. 2. Processing of Personal Data 2.1 Customers or representative of customers as well as potential customers Purpose Type of processing Categories of Personal Data To fulfil obligations within current contracts for the delivery of services and products. We process Personal Data to identify you as a customer or user, to handle and deliver orders in accordance with your agreement and to provide the Services – such as to ensure the operation of the Service. We also process data to charge for the services you use to manage your invoices and payments, for credit disclosure purposes, to correct errors and handle other incidents, and to handle complaints. Customer Data Traffic Data From which sources will we collect your Personal Data? Customer, customer’s employee, SPAR and UC Lawful Basis: Fulfilment of contract Automated decision-making: No, this processing does not mean that decision-making will be made based on automated processing of Personal Data. Retention period: Customer data: As long as you are a customer at Soluno and for 24 months after you have you have ended your contractual relationship with Soluno. Traffic Data: Is saved for billing purposes. The Traffic Data is deleted after 6 months after the invoice is payed. Purpose Type of processing Categories of Personal Data To provide service information and updates. We process data in connection with other communications with you, such as when we send information about our Services and contact you regarding questions about our Services. When you call our customer service, the call can be recorded. When you chat with our customer service, the written texts can be analysed. We do this to educate our employees, improve our speeches and our way of working in order to always help you in the best possible way. Customer Data Traffic Data From which sources will we collect your Personal Data? Customer, customer’s employee Lawful Basis: Legitimate interest (Customer Data) and consent (Traffic Data) Automated decision-making: No, this processing does not mean that decision-making will be made based on automated processing of Personal Data Retention period: Customer data: As long as you are a customer at Soluno and for 24 months after you have you have ended your contractual relationship with Soluno. Traffic Data: We save Traffic Data to help you if something is wrong with the services we deliver. This data is saved for 6-24 months. Purpose Type of processing Categories of Personal Data To evaluate, develop and improve our services, products and offerings. We process data to develop and manage our operations and Services as well as our processes. For this purpose, we may also compile statistics for analytical needs. Customer Data Traffic Data From which sources will we collect your Personal Data? Customer, customer’s employee Lawful Basis: Legitimate interest (Customer Data) and consent (Traffic Data) Automated decision-making: No, this processing does not mean that decision-making will be made based on automated processing of Personal Data Retention period: Customer data: As long as you are a customer at Soluno and for 24 months after you have you have ended your contractual relationship with Soluno. Traffic Data: In order for us to continuously offer better services based on our customers’ needs, we also save statistics based on these tasks. This data is saved for 6-24 months. Purpose Type of processing Categories of Personal Data To administer and customize your visit and access to selected parts of our online services. We process data in order to continuously offer better services based on our customers’ needs and to personalize you use of our online Service. Customer Data Traffic Data From which sources will we collect your Personal Data? Customer, customer’s employee Lawful Basis: Legitimate interest (Customer Data) and consent (Traffic Data) Automated decision-making: No, this processing does not mean that decision-making will be made based on automated processing of Personal Data. Retention period: Customer data: As long as you are a customer at Soluno and for 24 months after you have you have ended your contractual relationship with Soluno. Traffic Data: In order for us to continuously offer better services based on our customers’ needs. This data is saved for 6-24 months. Purpose Type of processing Categories of Personal Data To deliver direct marketing material. We process different types of data in order to market our products and services directly to you. You can receive direct marketing it via e.g. phone, text message and e-mail. For this purpose, we may also compile statistics for analysis. Customer Data Traffic Data From which sources will we collect your Personal Data? Customer, customer’s employee Lawful Basis: Legitimate interest (Customer Data) and consent (Traffic Data) Automated decision-making: No, this processing does not mean that decision-making will be made based on automated processing of Personal Data. Retention period: Customer data: As long as you are a customer at Soluno and for 24 months after you have you have ended your contractual relationship with Soluno. Traffic Data: In order to offer you attractive market deals based on your needs, we save certain data, such as number of texts and phone calls, as well as information about your data usage. We save the information for 36 months. Purpose Type of processing Categories of Personal Data To implement marketing and customer analysis. For this purpose, we may compile statistics for analysis. Customer Data Traffic Data From which sources will we collect your Personal Data? Customer, customers employee Lawful Basis: Legitimate interest (Customer Data) and consent (Traffic Data) Automated decision-making: No, this processing does not mean that decision-making will be made based on automated processing of Personal Data. Retention period: Customer data: As long as you are a customer at Soluno and for 24 months after you have you have ended your contractual relationship with Soluno. Traffic Data: In order for us to continuously offer better services based on our customers’ needs. This data is saved for 6-24 months. Purpose Type of processing Categories of Personal Data To fulfil our obligations under telecom legislation. We process data in order to fulfil our statutory obligations as a telecom service provider/operator. Customer Data Traffic Data From which sources will we collect your Personal Data? Customer, customers employee Lawful Basis: Legal obligation Automated decision-making: No, this processing does not mean that decision-making will be made based on automated processing of Personal Data. Retention period: Customer data: As long as you are a customer at Soluno and for 24 months after you have you have ended your contractual relationship with Soluno. Traffic Data: In order to comply with statutory obligation we may process you Traffic data for 24 months after you have ended your contractual relationship with Soluno. Purpose Type of processing Categories of Personal Data To ensure data security and to avoid misuse of the Service. We process data in order to meet the security of all our services and communications networks, to detect or prevent various types of illegal use or use that otherwise violate the terms of service. We also treat these data to prevent network and service abuse, and to detect and prevent fraud, virus attacks, etc. Customer Data Traffic Data From which sources will we collect your Personal Data? Customer, customers employee Lawful Basis: Legal obligation Automated decision-making: No, this processing does not mean that decision-making will be made based on automated processing of Personal Data. Retention period: Customer data: As long as you are a customer at Soluno and for 24 months after you have you have ended your contractual relationship with Soluno. Traffic Data: In order to comply with statutory obligation we may process you Traffic data for 24 months after you have ended your contractual relationship with Soluno. 2.2 Suppliers and partners Purpose Type of processing Categories of Personal Data To communicate with suppliers and partners We process data to handle deliveries and collaborations. Contact information From which sources will we collect your Personal Data? Suppliers and partners. Lawful Basis: Legitimate interest in order to communicate with representatives for suppliers and partners. Automated decision-making: No, this processing does not mean that decision-making will be made based on automated processing of Personal Data Retention period: Until we have received information that the representative no longer work for the supplier/partner or the representative has changed contact information. 2.3 Potential employees Purpose Type of processing Categories of Personal Data To administer a recruitment process This includes, for example, to review the application and communicate with the applicant. Name Address Social security number Contact informationID From which sources will we collect your Personal Data? Potential employee and their employer. Lawful Basis: Until the position has been filled: Fulfilment of contract. After the position has been filled: Legitimate interest to defend our rights in any legal dispute concerning discrimination, or after consent. Automated decision-making: No, this processing does not mean that decision-making will be made based on automated processing of Personal Data. Retention period: Up to two years after the position has been filled. After the recruitment process the data will be filed in order for us to defend our rights in any legal dispute concerning discrimination. 2.4 Visitors Purpose Type of processing Categories of Personal Data To administer visits. This includes, for example, to register external visitors for safety reasons. Name Contact information From which sources will we collect your Personal Data? Visitors. Lawful Basis: The Company has an legitimate interest in ensuring security. Automated decision-making: No, this processing does not mean that decision-making will be made based on automated processing of Personal Data. Retention period: One month after the visit. 3. Processing of Cookies The Company is the Data Controller for the processing of your Personal Data collected through cookies when you visit our website (http://www.soluno.se). We process the information that’s is created by the cookies that are set when you visit our website (including your IP address), such as the length of your visit, the number of page views, the choices you make on our website and how you found our website. Your Personal Data is processed for the purpose of our visitors being able to use the site in our intended way and for statistics. Such Personal Data is processed based on a balance of interests between your and our legitimate interests. Our legitimate interests in processing your Personal Data are to give you a desirable user experience of our website and our commercial interest in obtaining information. The retention period for such Personal Data will vary depending on which cookie is added to your browser. Permanent cookies remain on your computer until you delete them or expire due and you will return to our website. Session cookies does not have any expiration date and are stored temporarily in your computer while you are on our website. When you close your browser, any session cookies disappear. Third party cookies are cookies coming from a third party and used on our website to, for example, get statistics that can help us simplify and customize our website. You can choose whether you want to accept or block cookies. Most browsers automatically accept cookies, but you can change browser settings to block cookies. Below you will find examples of how to do for each web browser. Google Chrome Safari Mozilla Firefox Internet Explorer Please note that if you choose to block cookies, this may in some cases impair the functionality and experience of our website / web application. 4. Recipients of Personal Data and transfers to third countries outside the EU/EEC In our capacity as Data Controller, we may assign the processing described above to a partner or supplier, e.g. Zendesk Inc (ticketing system), Interoute (International numbers). Such processing will not be made for other purposes than as described above. Some partners and suppliers may have parts of their businesses in countries outside the EU/EEC (so-called Third Countries). Transfer is only made to such countries that offer an adequate level of data protection according to the EU Commission, or if the supplier has a legally binding and enforceable instrument that guarantees the safety of the Personal Data. Data may be disclosed to the following third parties: Third Party Purpose Data that is shared For more information about third party data processing Google Analytics To generate statistics on how our website is used. IP address. Web-browser type. Third-party cookies. Google Analytics Terms of Service Google Analytics security and privacy principlesGoogle Privacy Policy Hotjar To see how website visitors interacts with our website and to collect feedback in order to improve our website’s user experience. HTML changes that happen while you use our webpage. Mouse movements. Mouse clicks. Scroll movements. Keystrokes only for whitelisted input fields.Browser viewport size changes. Hotjar Terms of Service Hotjar Privacy Policy Olark To offer you our products and services when we have identified mutual interest or needs. Name. Phone number. Address.E-mail. Olark Terms of Service Olark Privacy Policy Upsales To analyse website visitor behaviour, contact potential customers though customized advertising and to show our ads on external websites. Third-party cookies. Upsales Privacy Policy Facebook To analyse website visitor behaviour, contact potential customers though customized advertising and to show our ads on external websites. Third-party cookies. Facebook Privacy Policy 5. Your rights as Data Subject You have the right to: request information on what type of Personal Data we process and you may request a copy thereof (record extract); have incorrect Personal Data rectified and, in certain cases, request to have your Personal Data deleted; object against the processing of certain Personal Data and request that the processing of your Personal Data is restricted; withdraw your consent to Personal Data processing; have the Personal Data you’ve provided us transferred to another Data Controller (right to data portability); and if you are unhappy with how we process your Personal Data, you may file a complaint with the Swedish Data Protection Authority, which is the supervisory authority. Contact information to the Swedish Data Protection Authority may be found at www.datainspektionen.se. You may at any time obtain, erase or restrict the processing of your Personal Data. Please notice that if we restrict the processing of or erase your Personal Data we might not be able to provide the Service to you. 6. Protection of the Personal Data The Company has undertaken appropriate technical and organisational measures in order to protect Personal Data against loss, abuse, unauthorized access, disclosure, alteration and destruction. In order to ensure that the Personal Data is processed in a secure and confidential manner, the Company uses firewalls and other security measures to protect networks against breach, authentication methods pursuant to industry standards. OWASP 2017 guide lines are followed for http interfaces. In order to secure the integrity of the Personal Data the Company may use encryption techniques when the Company transfers such Personal Data over the Internet to the Company´s servers. Company employees and suppliers are bound by confidentiality agreements and are obligated to follow the Company’s rules for information and IT security and other internal policies that further regulates Personal Data processing. 7. Amendments to the Privacy Policy The Company reserves the right to amend this Privacy Policy at any time. The date for the latest revision is stated at the end of the Privacy Policy. If the Company makes any changes to the Privacy Policy the Company will notify this through our newsletters and notice on this web site. You are therefore recommended to regularly review this Privacy Policy in order to note any changes. If this Privacy Policy is substantially revised compared to when the Company obtained your consent, the Company will notify you regarding these changes and, if necessary, obtain a new consent to the Company’s processing of your Personal Data. 8. Contact information If you have any questions regarding the Privacy Policy or any other question regarding our processing, please feel free to contact us: Soluno Business Communications AB, reg. no. 556377-2317 Att: Data Protection Officer Lumaparksvägen 9 120 31 Stockholm 010 410 50 00 dpo@soluno.se The Privacy Policy was adapted on 2018-06-25 Mobile first – driving the future of business communication ABOUT SOLUNO Our story Sustainability INFORMATION Contact Operational information Privacy policy Cookies © 2021 Soluno.com