Privacy Policy
Privacy policy for Filterly AB
Filterly AB (org. no. 559430–2449) processes personal data that you enter in connection with entering into an agreement to purchase our service, when you apply for a job with us and if you otherwise contact us. In these cases, we are the data controller for the personal data we process about you and are thus obliged to process your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”). We care about the protection of your privacy and therefore ask you to carefully read the below summary of how we process your personal data.
Personal data controller and contact details
Filterly AB
Svartmangatan 16
111 29 Stockholm
gdpr@filterly.eu
- Personal data processing
Personal data refers to all information that can be directly or indirectly attributed to you. For example, it can be your name, email address and picture. Different types of electronic identities (e.g. IP addresses) are also personal data if they can be linked to natural persons. Every action taken with personal data constitutes so-called processing, regardless of whether it is performed automatically or not. Examples of treatments are collection, registration, organization, structuring, storage, processing, transmission and deletion.
Below we describe in which cases we process your personal data.
2.1 Personal data you provide to us
When you enter into an agreement for our service
When you enter into an agreement about our service as a business customer, we collect personal data from the person entering into the agreement in order to administer the agreement, provide the service and be able to communicate with you regarding the service.
| Personal data | First and last name, e-mail address and telephone number and social security number. |
| Purpose | So that we can fulfill our commitments according to the agreement and to fulfill our obligations according to the Accounting Act. |
| Legal basis | In the event that you purchase a service, we prepare the data based on itagreementwe entered into by you purchasing the service, 6(1)(b) GDPR, as well as legal obligation according to the Accounting Act 6(1)(c) GDPR. |
| Storage time | We store the personal data as long as you are a customer with us and delete the personal data two months after the end of the customer relationship.
In the event that you make a purchase, we store the personal data for 7 years and the current accounting year in accordance with the Accounting Act. |
Personal data that Filterly’s corporate customers transfer to Filterly within the scope of the service, the customer alone is the Personal Data Controller for and Filterly acts as a personal data assistant, the parties and respective responsibilities are regulated separately in a service agreement.
When you contact us by email
When you contact us by e-mail, we process the information you choose to provide in connection with the question you asked us in order to be able to help you with your case.
| Personal data | Email address, name and phone number |
| Purpose | The data is collected in order to be able to answer the questions you have asked us and to be able to get in touch with you. |
| Legal basis | Legitimate interest Article 6(1)(f) GDPR. Filterly assesses that our and your legitimate interest in helping you in your matter with us outweighs your interest in the protection of your personal data, and that the processing is necessary to achieve the purpose. |
| Storage time | Email messages are stored for one (1) year from the time the message was received and then deleted. |
When you apply for a job with us
If you send us a job application, we process the information you chose to provide for recruitment purposes.
| Personal data | First and last name, telephone number, e-mail address, social security number, address and application documents |
| Purpose | The processing takes place so that we can administer your application. |
| Legal basis | Our legitimate interest 6(1)(f) GDPR. We judge that our interest in handling your application outweighs the protection of your fundamental rights and is necessary to fulfill the purpose of the processing. |
| Storage time | Application documents that do not concern the person who has received the position or the person who has appealed the appointment decision are stored for two years after the employment decision has become legally binding. The personal data is then deleted or de-identified as a starting point.
Spontaneous applications that do not relate to an advertised position are deleted as a general rule immediately. We may save the data longer for the purpose of future recruitment, but then you will receive a request as to whether you agree to us saving your data for a longer period of time. |
When you visit our website
When you visit our website, Filterly collects information about your electronic equipment generated by service logs and other tools, including your operating system and browser version. This is done through so-called necessary cookies so that we can provide you with the website.
| Personal data | IP address, device_id, language settings and browser version. |
| Purpose | In order for us to provide our website at your request. |
| Legal basis | Our legitimate interest 6(1)(f) GDPR. We consider that our interest in providing our website at your request outweighs the protection of your fundamental rights and is necessary to fulfill the purpose of the processing. |
| Storage time | We store the personal data during the time you visit our website and are deleted when you leave the website. |
2.2 Transfer of personal data to third parties
Data storage providers: Suppliers or subcontractors that Filterly hires for the purpose of providing storage or IT services have the right to process the personal data they receive from Filterly on behalf of Filterly, so-called personal data processors.
Purpose and legal basis: In order for Filterly to be able to provide its service, it is required that Filterly can store personal data on a server. These servers host Filterly with a data storage provider. Filterly needs to store the personal data with this provider in order to provide its service. Filterly has a legitimate interest in being able to store data with the provider (Article 6(1)(f) GDPR). Filterly ensures that that processing is necessary to pursue that interest, and that our interest outweighs your interest in the protection of your fundamental rights. You have the right to object to this processing, due to circumstances in your individual case. You can find more information about your rights in Section 5.
Agencies: In some cases, we may share your personal data in the form of first and last name and social security number with government authorities.
Purpose and legal basis: Released to authorities only happens in case of suspicion of crime or in cases where we are obliged to do this according to an order from an authority or court. In such cases, the disclosure takes place with the support of our legal obligation according to law or authority decision.
- Transfer outside the EU/EEA
We strive not to transfer personal data outside the EU/EEA area (EU countries as well Iceland, Lichtenstein and Norway. Filterly’s servers are located within the EU/EEA.
One of our subcontractors offers support through their subsidiaries in Canada and the UK. In the event that we need to use this support, we may need to transfer personal data to these companies. Both Canada and Great Britain have decisions on adequate level of protection from the European Commission, see here and here.
- Security measures
Filterly only processes personal data for the purposes for which it was collected and as stated above. Personal data is only available to authorized employees who hold a position that requires them to process personal data to perform their work. Personal data is not processed longer than is required for the current purpose. Your personal data is protected through both contractual (personal data processing agreement), organizational and technical security measures.
- Your rights
You have certain rights according to the GDPR regarding the personal data that we process about you. If you wish to exercise any of your rights below, please contact us. Contact details for Filterly can be seen from Part 1 of this document.
Right of access
You have the right to access the personal data we process about you, a so-called register extract. This means that you have the right to receive, free of charge, a copy of which personal data we process about you, the purposes of the processing and the category of personal data to which the processing applies.
Withdraw consent
If you have given your consent to certain treatment, you always have the right to withdraw your consent. However, this does not affect the legality of the processing.
Right to rectification
You have the right to have inaccurate personal data concerning you corrected without undue delay. When you discover that there are errors in the information we have registered about you, you can contact us to have your information corrected. You also have the right to complete incomplete information we have about you.
Right to erasure
You also have the right in certain cases to demand that we delete all or some of your personal data provided that it is not necessary for us to retain this data in order to fulfill our legal obligations. You have the right to have your data deleted
- the personal data are no longer necessary for the purpose of the processing,
- you withdraw your consent on which the processing is based,
- if you have objected to the processing and we are not considered to have a legitimate interest,
- the personal data has been processed in an illegal manner
To the extent that it is necessary to continue processing your personal data, for example to fulfill our legal obligations, we are not obliged to delete your personal data. This means that certain data can be stored until we are no longer obliged to process them. Data that we must store due to legal, statutory or contractual retention obligations will be blocked instead of deleted, so that it cannot be used for other purposes.
Limitation
You also have the right to request that the processing of personal data be limited for a shorter period of time. A restriction can be made for several reasons.
- If you dispute that the personal data we process is correct, you can request limited processing during the time we work to check whether the personal data is correct.
- If you require us to delete your data but we cannot comply with the request. For example, it may be because we need the information we have about you to establish, assert or defend legal claims. In these cases, you can request limited processing of the data with us.
- If you have objected to a balance of interests of legitimate interest that we have made as a legal basis for a purpose. Then you can request limited processing during the time we work to check whether our legitimate interests outweigh your interests in having the data deleted.
In the event that the processing has been restricted according to any of the situations above, we may only, in addition to the storage itself, process the data to establish, assert or defend legal claims, to protect someone else’s rights or because you have given your consent.
Objection regarding balance of interests
When processing takes place with the support of a balancing of interests (legitimate interest), you have the right to object to the processing, due to circumstances in your individual case. A continued processing of your personal data requires us to show a justified reason for the current processing. Otherwise, we may only process the data to establish, exercise or defend legal claims. You also have the right to object to direct marketing.
Data portability
This means a right to, under certain conditions, obtain and transfer your personal data in a structured, generally used and machine-readable format to another personal data controller. A prerequisite for data portability is that the transfer is technically possible and can take place automatically, and that Filterly processes your personal data based on your consent or to fulfill an agreement.
Right to complain
If you believe that we are processing your personal data inadequately or in violation of the GDPR, you have the right to file a complaint with the Swedish Data Protection Authority. For more information and contact details, please see www.imy.se.
Changes to the Privacy Policy
To ensure that our privacy policy always meets applicable legal requirements, we reserve the right to make changes at any time. It also applies when the privacy policy needs to be changed to apply to new or revised treatments.
Last updated 2023-09-04.