Privacy Policy

9th of March 2020

In this privacy policy you can read more about how Wittra Sweden AB, reg.no 556932-0988 (“Wittra”, “we”, “us” or “our”) may process your personal data when you are visiting wittra.se and/or signing up for a user account at wittra.se or interact with us in any other way. Wittra is data controller of any processing of your personal data.

1. WHAT PERSONAL DATA DO WE COLLECT?

We collect personal data when you (i) sign-up for a mailing list or request news and information, (ii) voluntarily complete surveys or similar, (iii) register a user account and/or place an order for Wittra services, and (iv) visit wittra.se. Such personal data will include your name, country, e-mail address, IP address, other required contact details and potentially credit card information, bank account details or other relevant payment information, and other information that you voluntarily provide us.

Most of the personal data, which we process about you, is personal data that you have voluntarily provided us with, for example by submitting an enquiry on our website, by registering an account and/or when you contact us through our social media accounts or in any other way. We may also collect some personal data from you automatically through cookies; for instance, standard Internet log information and visitor behavior information (please see more under “Cookies” below).

2. PURPOSE, LEGAL GROUND AND STORAGE PERIOD

We will only use your personal data for the purposes, and on the basis of the legal grounds, as set out below. We will not use your personal data for any purpose that is incompatible with the below purposes. Further, we will only use your personal data during the period as set out under "Storage period", after such period your data will be erased.

2.1. When you sign up for our mailing lists, news and information 

Purpose: When you sign up for a mailing list or request news or information, we will process your data to provide the services as requested by you. We will make sure we obtain your consent before we begin processing your personal data for this purpose. The request for your consent will be clear and specific and provide you with a description of the purpose of our data processing. We will never assume your consent, but ensure that your will to consent is clearly expressed.

You have the right to withdraw your consent at any time, in which case we will stop processing the personal data provided by you or collected by us under the consent. Please direct a request for withdrawal to legal@wittra.se

Legal ground: Your consent/our legitimate interests to maintain good customer relations.

Storage period: We will erase your data when you opt-out or unsubscribe from the processing.

2.2. When you complete one of our surveys

Purpose: When you complete surveys, we will process your personal data to analyze the responses/results and to improve our services on the basis of such responses/results. We will make sure we obtain your consent before we begin processing your personal data for this purpose. The request for your consent will be clear and specific and provide you with a description of the purpose of our data processing. We will never assume your consent, but ensure that your will to consent is clearly expressed.

You have the right to withdraw your consent at any time, in which case we will stop processing the personal data provided by you or collected by us under the consent. Please direct a request for withdrawal to legal@wittra.se

Legal ground: When you voluntarily participate in a survey, you consent to our usage of your personal data for the mentioned purposes.

Storage period: We will erase your data within a reasonable time after completion of our analysis. You can always withdraw your consent.

2.3. When you register a user account and/or place an order for Wittra services 

Purpose: When you register a user account and/or place an order for our services, we will process your personal data in order to register you as a user and be able to provide our services to you in accordance with respective Terms of Service. We will also process your personal data for billing purposes and to provide support.

Legal ground: the processing is necessary for our delivery of the services and for the performance of the obligations under the respective Terms of Service. We may use your personal data for the purposes of analyzing and developing the services and for marketing purposes. The legal ground for our processing is that the processing is necessary for our legitimate interests to improve our services and our marketing measures. To the extent the aforementioned purposes can be achieved on the basis of anonymized data, we might anonymize your personal data and aggregate it with other users’ anonymized data. Should your personal data have been anonymized, it will no longer be considered personal data under applicable data protection laws and for the purposes of this privacy notice.

Storage period: You can delete your account and personal data at any time. If Wittra does not delete your personal data earlier in accordance with respective Terms of Service, your account and personal data will be deleted within one year after termination of the respective Terms of Service. The aforementioned does not apply to the extent Wittra is required to retain your personal data (partly or in full) for a certain period under applicable mandatory law.

2.4. When you visit Wittra.se website

Purpose: When you visit wittra.se, we will process your personal data to improve our website.

Legal ground: Our legitimate interest to improve our website and services. Please see more under “Cookies” below. 

Storage period: Please see more under “Cookies” below.

2.5. Anonymous use of your data

Please note that in some instances Wittra might choose to anonymize your personal data and aggregate it with other users’ anonymized data in order to achieve its legitimate purposes of data processing

Purpose: To anonymize your personal data, in order to compile anonymous and aggregated tracking data (including to analyze visitors’ use of our sites by tracking information such as page views, traffic flows, search terms and click throughs) for the purpose of improving our website.

Legal ground: Our legitimate interests to create anonymous user statistics. Should your personal data has been anonymized, it will no longer be considered personal data under applicable data protection laws.

Please note that the above storage periods do not apply to the extent Wittra is required to retain your personal data (partly or in full) for a certain period under applicable mandatory law.

3. Who do we share your personal data with?

To achieve the purposes, we may share your personal data with our subcontractors. Such subcontractors provide payment services, CRM system services, cloud and storage services, advertising services and services for troubleshooting and correction of any defects in our website. Some of our subcontractors may process your personal data outside the European Economic Area (EEA). However, a transfer outside the EEA will only occur, if there is a legal ground for the transfer, e.g. by (i) executing EU standard data protection clauses with the recipient of the personal data, or (ii) ensuring that the country has an adequate level of protection of personal data, as decided by the EU Commission, or (iii) for transfers to and processing in the USA, ensuring that the recipient holds self-certifying registrations under the EU-U.S. and the Swiss-U.S. Privacy Shield Frameworks administered by the U.S. Department of Commerce’s International Trade Administration.

4. Your rights

You are entitled to the following rights under applicable laws:

4.1. The right to access: you may at any time request to access your personal data. Upon request, we will provide a copy of your personal data in a commonly used electronic form.

4.2. The right to rectification: you are entitled to obtain rectification of inaccurate personal data and to have incomplete personal data completed.

4.3. The right to erasure (“right to be forgotten”): under certain circumstances you may request us to delete your personal data. Please note that this right is not unconditional. Therefore, an attempt to invoke the right might not lead to an action from us.

4.4. The right to object: to certain processing activities conducted by us in relation to your personal data, such as our processing of your personal data based on our legitimate interest. The right to object also applies to processing of your personal data for direct marketing purposes.

4.5. The right to restriction of processing: you may under certain circumstances request from us to restrict the processing of your personal data. Please note that this right is not unconditional. Therefore, an attempt to invoke the right might not lead to an action from us.

4.6. The right to data portability: you are entitled to receive your personal data (or have your personal data directly transmitted to another data controller) in a structured, commonly used and machine-readable format.

4.7. You also have the right to lodge a complaint with the supervisory authority, which in Sweden is Datainspektionen.

5. COOKIES

We use cookies, pixels and other technologies (collectively, “cookies”) on our website to improve your experience with us.

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our website, we may collect information from you automatically through cookies. For further information, visit allaboutcookies.org

We use cookies to (i) recognize your browser, device and location, (ii) store and honor your preferences and settings, (iii) learn more about your interests and serve you personalized content and ads which we believe improves your experience with us, (iv) analyze how you use our site and platform, and (v) provide you with essential features and services.

To illustrate the primary purposes for which we typically set cookies, please see below a general categorization of cookies we commonly use. Please note that the information these cookies collect may include personal data. 

Essential cookies - These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the website will not work.

Performance cookies - These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our website. They help us to know which pages are popular and see how visitors move around the website. If you do not allow these cookies, we will be less able to optimize the website's performance.

Functional cookies - These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies some services may not function properly.

Targeting cookies - These cookies may be set through our website by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. If you do not allow these cookies, you will experience less targeted advertising.

Third-party cookies - As mentioned above, some cookies are placed by third parties acting on our behalf (such as advertising and analytics partners, social media networks and search engines). Third parties use cookies to (i) deliver content, including ads which we believe are relevant to your interests, (ii) analyse the effectiveness of the ads, and (iii) perform services on behalf of Wittra.

Most browsers allow you to control and manage browser cookies through their settings. Please note that removing or blocking cookies can impact your user experience and some functionality may no longer be available.

Information about Albacross’ processing of your personal data

We inform you regarding the processing of personal data on behalf of Albacross Nordic AB (“Albacross”).

Information collected from cookies set in your device that qualify as personal data will be processed by Albacross, a company offering lead identification and ad targeting services with offices in Stockholm and Krakow. Please see below for full contact details.

The purpose for the processing of the personal data is that it enables Albacross to improve a service rendered to us and our website (e.g “Lead Generation” service), by adding data to their database about companies. The Albacross database will in addition to “Lead Generation” be used for targeted advertising purposes towards companies and for this purpose data will be transferred to third party data service providers. For the purpose of clarity, targeted advertising regards companies, not towards individuals. 

The data that is collected and used by Albacross to achieve this purpose is information about the IP-address from which you visited our website, and technical information that enables Albacross to tell apart different visitors from the same IP-address. Albacross stores the domain from form input in order to correlate the IP-address with your employer.

For the full information about our processing of personal data, please see Albacross’ Privacy Policy.

Albacross Nordic AB
Companyreg. no 556942-7338
Kungsgatan 26
111 35 Stockholm, Sweden
www.albacross.com - contact@albacross.com

6. DATA SECURITY

In order to keep your personal data secure, we apply a number of security measures in line with industry practice and we will take any reasonable steps and precautions against security breaches to ensure safekeeping of your personal data. We shall comply with our internal security guidelines available on wittra.se or such other place as we designate.

7. CONTACT INFORMATION

If you have any questions relating to our handling of your personal data or our use of cookies or if you would like to invoke any of your rights under applicable privacy legislation, please send an email to legal@wittra.se.

8. CHANGES

If we change how we handle your personal data or how we use cookies, we will promptly update this website privacy policy and publish it on this website.