WHAT PERSONAL INFORMATION ARE COLLECTED?
Personal information is data that can be used to identify or contact you. Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as: “any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”. If we do collect personal data, we will nevertheless never collect sensitive personal data about you. The EU’s General Data Protection Regulation (GDPR) defines sensitive personal data as “categories of personal data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation.” We are committed to ensuring that the information we receive and use are appropriate for the below purposes.
A. WHEN YOU SIGN UP FOR A NEWSLETTER
We may collect and process the following information: Email address, Full name, We use the above information from the following purposes: So you can receive updates about the Closely project So you can receive marketing communication via email or SMS So we can send you surveys about our services and products So we can notify you about changes to our services The legal grounds to process your personal data are: The processing of your personal data is necessary for the contact between you and Closely (to fulfill your application and subscriptions), for compliance with our legal obligations and our legitimate interests*
B. WHEN YOU INTERACT WITH OUR WEBSITE
We may collect and process the following information: Email address, Information gathered when you visit our website We use the above information from the following purposes: So you can sign up to our newsletters and receive information, news and offers about our products So we can provide, update, maintain, improve and protect our website, business and services So we can deliver relevant website content and online advertisements. The legal grounds to process your personal data are: The processing of your personal data is based on your consent (when you sign up for our NL) or based on our legitimate interests*
C. WHEN YOU APPLY FOR EMPLOYMENT
We may collect and process the following information: Name, Email address, Telephone number, Correspondence history, curriculum vitae, personal letter, information, ID documentation We use the above information from the following purposes: So you contact, communicate with us So we can manage, administrate all your queries So we can verify your identity when you request further information based on your rights The legal grounds to process your personal data are: The processing of your personal data is necessary for the contract between you and us, and based on our legitimate interests*
D. WHEN YOU APPLY TO BECOME A TESTPILOT
We may collect and process the following information: Contact details such as email address, full name, telephone number, address, your written replies and information submitted in the application. We use the above information from the following purposes: So we can smoothly and perfectly manage the application (contact applicants, recommend best product for test-report, deliver merchandise for evaluation, deliver discount-code/voucher) The legal grounds to process your personal data are: The processing of your personal data is necessary for the contract between you and us *When we rely on the ‘legitimate interests’ condition, Closely will always meet the following requirements: We must process the information for the purposes of our legitimate interests or for those of a third party to whom we disclose it; The above interests must be balances against your interests. The “legitimate interests” condition will not be met if the processing is unwarranted because of its prejudicial effect on your rights and freedoms, or legitimate interests. Closelys’s legitimate interests do not need to be in harmony with those of the individual for the condition to be met. However, where there is a serious mismatch between competing interests, your legitimate interests will always come first.
If you sign up or willingly give us your email address, you will receive marketing messages by email and/or SMS. These marketing messages are only meant to inform you about our current and next offers. You can of course decide to unsubscribe from us at any time. How do you unsubscribe from marketing communications? 1. NEWSLETTER By clicking on the unsubscribe link at the end of the email By contacting our Customer Care Service 2. TEST PILOT By clicking on the unsubscribe link at the end of the email communications sent By contacting our Customer Care Service
SHARING YOUR INFORMATION
We will never sell your personal data to any third party. However, we may share your personal information with companies who are experts in their field and assist us in operating the website, conducting our business or servicing you. Do not worry though! Each of our service providers have been selected by us for their ability to provide the particular services needed, including their ability to handle your personal information. All those providers provide sufficient guarantees to implement the technical and organizational measures necessary to meet the requirements of the GDPR and our own. We share your personal information in the following cases: To any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries; If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of Closely, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction; If we are processing it on behalf of a customer; To companies for the performance of any contract we enter into with you or them and that help us provide our services adequately such as, payment service providers, delivery companies or our warehouse. To other professional services companies such website hosts, advertising/marketing agencies and analytics or search engine providers helping us run, improve and optimize the Website or helping us store your data. With your expressed consent.
TRANSFERS OF YOUR INFORMATION OUTSIDE THE EUROPEAN ECONOMIC AREA
Where a third-party provider is located outside the European Economic Area, we will always ensure that the transfer of personal data will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission where the data protection authority does not believe that the third country has adequate data protection laws or with companies that are Privacy Shield Certified.
TO ACCESS WHAT PERSONAL INFORMATION IS HELD IDENTIFICATION WILL BE REQUIRED
Where you request access to your information, we are required to use all reasonable measures to verify your identity before doing so. These measures only exist to protect your information and to reduce risk of identity fraud, theft or unauthorized access to your information. We therefore kindly ask you to send us original or certified copies of the following documentation: passport, identity card, birth certificate or driving license. One of those above documents is required in order to request personal information. We will endeavour to respond within one month. If you want to exercise one of the above rights, please contact us either via email or using the contact details provided below in the paragraph "How to contact us".
HOW LONG DO WE KEEP YOUR INFORMATION?
We will hold your personal data for as long as you are you have an account and for as long as is necessary to comply with our legal/ regulatory obligations, resolve disputes, prevent fraud and abuse or enforce our terms and conditions. When we no longer need to retain your personal data, it will be deleted or be anonymized so that you can no longer be identified from it. We securely destroy all financial information once we have used it and no longer need it.
HOW YOUR PERSONAL INFORMATION IS SECURED?
Closely will use all reasonable efforts to protect your personal information. We are using the latest industry standards and security measures such SSL/TLS encryption for protection of user data and personal information. Our goal is to have all appropriate technical and organizational measures to ensure a level of security appropriate to the risk of processing and using personal data. We have safeguard processes in place in order to ensure the ongoing confidentiality, integrity, availability and resilience of our or third parties processing systems and services as well as the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident. Your data is always store in secure environments and we provide training to our Staff on data protection best practices and require them to enter into a confidentiality agreement. You can access and edit personal information after signing into your account. To sign in, you are required to know your login credentials - email address and password. There is no way to access personal information without knowing the login credentials, therefore no unauthorized party can access it. We therefore ask you to keep your password secret and to not share it with any person (even a friend!). Please, immediately inform us if you know or suspect to have lost your login or that someone else is accessing your account.
LINKS TO OTHER WEBSITES OR SOCIAL MEDIA
HOW TO CONTACT US
LAWS AND REGULATIONS
The information we gather, use and process are collected in accordance with: The Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, or “GDPR”) The Swedish Data Protection Act (Personuppgiftslag 1998:204).
This Policy is based on the following principles: Personal data shall be processed lawfully, fairly and transparently; Personal data shall only be collected for specific, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; Personal data shall be adequate, relevant and limited to what is necessary for processing; Personal data shall be accurate and, where necessary, kept up to date with every effort to erase or rectify without delay; Personal data shall be kept in a form such that the data subject can be identified only as long as is necessary for processing; Personal data shall be processed in a manner that ensures the appropriate security; Personal data shall not be shared with third parties except when necessary in order for them to provide services upon agreement; Data subjects must easily exercise their rights.
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Cookies, Web Beacons, and How We Use Them
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List of cookies we collect