PRIVACY POLICY
SECTION 1 - INTRODUCTION
Protecting the privacy of users of our services is important to us at BE Group, and we want to ensure that your personal data is protected in the best possible way. This policy is designed to explain what personal data we collect about you, what it may be used for, and how we ensure that your personal data is handled in accordance with applicable legislation.
Data controller
BE Group or the company within BE Group which you entered into a contract with or are in contact with (“BE Group”, “we”, “our” or “us”) is the data controller for the processing of your personal data.
BE Group AB
Corporate ID number: 556578-4724
Address: Krangatan 4b, SE-211 24 Malmö, Sweden
Telephone: +46 (0)40 38 42 00
E-mail: info@begroup.com
Who should I contact if I have any questions or want to exercise my rights?
Questions/rights
If you have any questions about our processing of your personal data, you are welcome to contact us by e-mailing integrity@begroup.com.
Complaints
If you have comments on our processing or are dissatisfied with the response you received, you are entitled to lodge a complaint with the Swedish Authority for Privacy Protection (IMY). www.imy.se
SECTION 2 – INFORMATION FOR DATA SUBJECTS
We process the personal data provided to us, for example in connection with the signing of a customer contract or by people contacting us through a contact form or to express their interest in recruitment. The following personal data may be processed:
- Personally identifiable information – Name, account details, title, e-mail address, telephone number, company name, company address, and invoicing and delivery address.
- Information about devices – IP address, language settings, browser settings, time zone, operating system, platform, screen resolution, as well as similar information about your device settings.
- Information in connection with recruitment – CV, personal statement, information provided about you in connection with reference checking.
For what purposes do we process your personal data?
Contact persons at Corporate Customers
Purpose of the processing and legal basis
If you are a contact person and employee of one of our customers, your personal data will be processed to the extent necessary to contact the customer, to administer the customer relationship, and to enable us to fulfil our obligations to the customer. The processing is based on our legitimate interest in being able to fulfil the contract or the customer relationship that arises from, for example, an order that the customer places with us. We will also process your personal data if necessary to market our services to the customer on the basis of our legitimate interest.
Recipients of personal data
The data may be disclosed to authorities in accordance with that prescribed by law, to any partners who deliver support services to the company, including marketing, finance and IT services, and in the manner and to the extent necessary to enable us to fulfil our obligations to our customer. Your personal data may also be shared between companies within BE Group.
Storage and screening
Your personal data is stored for as long as the customer relationship exists and thereafter for the period required or permitted by applicable legislation and practice at any given time. If your personal data is supplied as a reference in invoicing documentation, it will be retained for seven years in accordance with the Swedish Accounting Act. If you terminate your employment with our customer, we will replace your contact details with your successor’s details on receiving information about this from you or your employer.
Contact persons at Suppliers and Retailers
Purpose of the processing and legal basis
If you are a contact person and employee of one of our suppliers or retailers, your personal data will be processed to the extent necessary to contact the supplier or retailer, to administer the supplier or retailer relationship, and to enable us to fulfil our obligations to the supplier or retailer. The processing is based on our legitimate interest in being able to fulfil the contract or the supplier relationship that arises from, for example, us placing an order with the supplier.
Recipients of personal data
The data may be disclosed to authorities in accordance with that prescribed by law, to any partners who deliver support services to us, such as IT services, and in the manner and to the extent necessary to enable us to fulfil our obligations to you as a data subject. Your personal data may also be shared between companies within BE Group.
Storage and screening
Your personal data is stored for as long as the supplier or retailer relationship exists and thereafter for the period required or permitted by applicable legislation and practice at any given time. If your personal data is supplied as a reference in invoicing documentation, it will be retained for seven years in accordance with the Swedish Accounting Act. If you terminate your employment with our supplier or retailer, we will erase your personal data on receiving information about this from you or your employer.
Candidates (recruitment)
Purpose of the processing and legal basis
If you apply for a job with us or submit a general expression of interest (spontaneous application), we and the recruitment company that we have engaged for the recruitment process will process your personal data to the extent necessary for the relevant recruitment process. It is important that the information you provide to us is factual and that you avoid providing privacy-sensitive personal data unless this is relevant to the employment in question.
We will process your personal data on the basis of legitimate interest. The processing covers the documentation you send us, information from referees, notes from interviews, and any work samples and tests.
Recipients of personal data
Your personal data may be shared with recruitment companies engaged by us.
Storage and screening
Your personal data is stored for as long as the recruitment process continues and a further two years with reference to the Swedish Discrimination Act, to enable us to demonstrate the basis on which the employment decision was made.
If you submit a general expression of interest, it will be saved for two years.
If your personal data is supplied in invoicing documentation, it will be retained in our accounting records for seven years in accordance with the Swedish Accounting Act.
Visitors to our website and webshop
Purpose of the processing and legal basis
We may process your personal data if you visit our website. Whether we process personal data about you, and if so what data that is, depends partly on the settings you choose in your browser, and partly on the settings you chose when you visited our website. Our website uses cookies, which are small text files that collect different types of information about how you as a visitor use our website. You can read about our use of cookies and which cookies we use in our Cookie Policy.
If you apply for and create an account for BE Group’s webshop, your personal data will be processed to the extent necessary to administer your account. We use cookies as part of this service for statistical purposes and to improve the service. The processing is based on our legitimate interest in being able to fulfil the contract or the customer relationship that arises when you create an account for our webshop.
We also process your personal data when you contact us through our website, for example if you complete one of our online forms. When you contact us via the website, we process your personal data on the basis of our legitimate interest in being able to process your enquiry or order and to communicate with you.
Recipients of personal data
The data may be disclosed to partners who deliver support services to the company, such as marketing services and other technical services in connection with provision of the website. Your personal data may also be shared between companies within BE Group.
Storage and screening
Your personal data is stored for as long as the customer relationship exists and thereafter for the period required or permitted by applicable legislation and practice at any given time. If your personal data is supplied as a reference in invoicing documentation, it will be retained for seven years in accordance with the Swedish Accounting Act.
Visitors to our social media channels
We are the data controller for the personal data we publish on our social media channels. We have a responsibility not to publish inappropriate or offensive posts on our channels. Any posts identified as such will be removed.
Purpose of the processing and legal basis
The purpose of our channels is to provide information about our business and our services to existing customers and to potential new customers. If you interact with any of our social media channels, you also agree to receive our posts in your personal feed. You can stop liking the page at any time or hide individual posts or all posts published by us. We may use the information to contact the company or organisation you represent and provide information about our goods/services. The legal basis is our legitimate interest.
If you would like more information about how your personal data is processed, we refer you to the relevant social media channel.
Recipients of personal data
The data may be disclosed to partners who, on our behalf, deliver support services to the company, such as marketing services. Your personal data may also be shared between companies within BE Group.
Storage and screening
Personal data that you provide in the form of interactions or comments where it is clear that you as an individual are the sender will be retained until further notice or until you delete the interaction or comment yourself. We will remove unsolicited comments on an ongoing basis where applicable.
Subscribers to Newsletters and/or Job vacancies
Purpose of the processing and legal basis
The purpose of the processing is to provide and administer e-mail addresses and other personally identifiable information that you provide in order to receive BE Group’s newsletter and/or information about new job vacancies. We may also use your personal data to market, for example, services, events, products, fairs, etc. in the newsletter. The legal basis for this processing is your consent. You can withdraw your consent at any time by unsubscribing from the newsletter or job vacancies using the link provided in the mailing.
Recipients of personal data
The data may be disclosed to any partners who deliver support services to the company, such as IT services, or a party engaged by BE Group to administer the newsletter.
Storage and screening
Your personal data is stored for as long as you are a subscriber to BE Group’s Newsletter and/or Job vacancies. When you unsubscribe, BE Group will erase your personal data. You can unsubscribe using the link at the end of the newsletter.
SECTION 3 – TRANSFER OF PERSONAL DATA OUTSIDE THE EU/EEA
If we have to transfer personal data to a country or company located outside the EU/EEA, we will adopt appropriate safeguards to ensure the security of your personal data.
- We use third-party cookies on our website. The use of third-party cookies means that your personal data may be transferred to third parties located in a third country, such as the United States.
- We use social media channels. The use of social media channels means that your personal data may be transferred to third parties located in a third country, such as the United States.
If personal data is transferred to a third country (incl. the United States), we always adopt appropriate safeguards to ensure the security of your personal data. Appropriate safeguards may include:
- ensuring that the EU Commission has decided that the country to which the personal data is transferred achieves an “adequate” level of protection equivalent to that ensured by GDPR.
- entering into the EU Commission’s standard clauses with the recipient of the personal data in a third country. When personal data is transferred to a third country on the basis of the EU Commission’s standard contractual clauses, we assess whether there is legislation in the recipient country that affects the protection of your personal data. If required, we take special technical and organisational measures to ensure the protection of your data when transferring it to the relevant country outside the EU/EEA. However, due to US security legislation, there is a certain risk that US authorities, in order to combat crime or safeguard national security, may gain access to personal data transferred to the United States despite the fact that we take technical and organisational security measures.
You can contact us via integrity@begroup.com and request a copy of the safeguards.
SECTION 4 – YOUR RIGHTS
As a data subject, you have certain rights. These rights are based on the General Data Protection Regulation (GDPR) and are set out below. Should you wish to exercise your rights, you are welcome to contact us. Contact details are provided in section 1 of this policy.
Response from us within one month
When you exercise your rights, in principle we will comply with your request and get back to you within one month of you contacting us. However, processing can take up to three months if the volume or complexity of the matter requires it. If this is the case, we will inform you. We will always respond to your request in writing.
Rights
Below are the various rights you may have when we process personal data about you.
Depending on the legal basis for our processing of data and the purpose of the processing, there may be exceptions or limitations to your ability to exercise your rights.
If the request is manifestly excessive (unreasonable) or unfounded, particularly if requests are repetitive in nature, we may either charge a fee or refuse to act on the request. In such cases we must be able to demonstrate that the request is manifestly unfounded or excessive.
Access to your personal data
You have the right to obtain confirmation from us about how we process personal data concerning you, and, where that is the case, to request access to the personal data we process about you, a so-called register extract.
More information about the right of access can be found on IMY’s website
Request rectification of inaccurate data
You have the right to request rectification of inaccurate data if it is incorrect. You also have the right to provide relevant supplementary data if the controller holds incomplete personal data about you.
More information about the right to rectification of inaccurate data can be found on IMY’s website
Request to have data erased
You have the right to request that your data be erased. In the event of such a request, we erase data that we no longer need to process or retain in relation to the purpose for which the data was collected. We also erase your data if you withdraw your consent to processing. In some cases, we will be unable to erase your personal data. This applies in cases where the data is either still required for processing for the purpose for which it was collected, where our interest in continuing to process the data overrides your interest in having it erased, or because we are required to retain it by law.
More information about the right to erasure can be found on IMY’s website
Request that the processing be restricted in certain circumstances
You have the right to request that our processing of your personal data be restricted in certain circumstances.
The possibility of restriction applies if: a) the data subject contests the accuracy of the personal data; b) the processing is unlawful and the data subject opposes the erasure of the data and instead requests a restriction of its use; c) the controller no longer needs the data, but the data subject requires the data for the establishment, exercise or defence of legal claims; or d) the data subject has objected to the processing pursuant to Article 21(1) pending verification of whether the controller’s legitimate grounds override those of the data subject.
More information about the right to restriction of processing can be found on IMY’s website
Request the right to data portability
When we process personal data for the performance of a contract with you or based on your consent, you have the right to request to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit this data to another data controller.
More information about the right to data portability can be found on IMY’s website
Right to object to processing
You have the right, on grounds relating to your particular situation, to object at any time to the processing of personal data concerning you which is based on point (f) of Article 6(1) in GDPR, legitimate interest. The right to object applies to, among other things, processing that involves profiling.
More information about the right to object to processing can be found on IMY’s website
SECTION 5 – CHANGES TO THIS PRIVACY POLICY
We reserve the right to make changes to this policy at any time to the extent we deem necessary based on changes to our personal data processing and to meet new legal requirements, interpretations of legal requirements, technical requirements or to remedy problems or disruptions. The policy in force at any given time is available on BE Group’s website.