Ons beleid

Privacy Policy

Latest update 28th August 2023

Purpose

The purpose of this Privacy Policy is to describe NCAB Group’s ambition to ensure compliance with relevant data protection legislation, to outline the principles that guide our processing of personal data, explain, in part, how we collect and use your personal data and to inform you of your rights as a data subject.

Protection of your personal rights and privacy is the foundation of trust in NCAB Group’s business and employee relationships. As controller, NCAB Group is responsible to ensure that all processing activities are performed in compliance with relevant data protection legislation, to ensure an adequate level of protection for your personal data.

Roles and responsibility

The Board of NCAB Group is ultimately responsible for ensuring that NCAB Group complies with the relevant data protection legislation.

The Lead Privacy Officer is responsible for formulating NCAB Group’s data protection strategy and advising the entire organization on strategic matters relating to data protection compliance.

The Data Protection Officer is responsible to advise the entire organization on the obligations of GDPR and other relevant data protection legislation and all data protection related issues affecting the business. Moreover, the Data Protection Officer is responsible for monitoring the level of compliance within NCAB Group.

Every person within NCAB Group is responsible to act in accordance with this Privacy Policy, related guidelines, rules, and routines to make sure NCAB Group complies with the GDPR, UK GDPR, PIPL, US State legislation and other related legislations.

Guiding principles

NCAB Group is responsible to make sure that every performed data processing activity adheres to the principles that form the foundation of data protection. These following principles require that personal data shall be:

• collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes
• adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed
• accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay
• kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organizational measures required by the GDPR in order to safeguard the rights and freedoms of individuals
• processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures

Lawfulness of processing

NCAB Group is responsible to ensure that every processing activity is based on a lawful basis prescribed by the relevant data protection legislation. The choice of appropriate legal basis depends on what data is being processed, the purpose of the data processing activity, and the relationship between you and NCAB Group.

The GDPR provides six different lawful bases, four of which are used by NCAB Group:

Consent

If a data processing activity relies on consent NCAB Group will ensure that you have given us a clear consent that you can easily rescind if you choose to do so.

For example, NCAB Group will process your personal data on this basis for the purpose of:

• planning business trips and conferences if you are an employee
• cookie management if you are visiting our websites
• accepting invitations to partake in webinars and other forums

Contractual performance

Contractual obligations are one the foundations of every enterprise. NCAB Group will process your personal data in contractual relationships to ensure that both we and you perform according to the terms of any agreement we enter between us.

For example, NCAB Group will process your data on this basis for the purpose of:

• Manage your employment if you are an employee
• Manage our relationship with you if you buy NCAB Group stock in your capacity as a private person

Legal obligation

We take our legal obligations seriously. There are many laws and regulations that NCAB Group needs to comply with, therefore there are situations where NCAB Group is obligated to process your data to ensure legal compliance.

For example, NCAB Group will process your data on this basis for the purpose of:

• complying with national tax legislation
• complying with national labor law legislation
• complying with requests from supervisory authorities and law enforcement

Legitimate interest

We may process your data personal data if there is a legitimate interest to either us, or to you, of doing so. However, NCAB Group does not process your personal data with legitimate interest as a basis if you are a Chinese citizen.

When we process your data based on legitimate interest we do so after having carefully considered whether:

• the same objective could be achieved with other means
• the data processing activity might cause you harm or affect your ability to exercise your rights
• you would expect us to process your data in such a way
• you would consider it reasonable to process your data in such a way

For example, NCAB Group will process your data on this basis for the purpose of:

• completing obligations to you as a customer, such as execution of purchase, invoicing and providing support
• providing the products and services ordered by you
• maintaining, improving, and documenting our customer relationship with you
• identify and develop a new customer relationship with you
• manage our partner relationship with you
• protecting and asserting the legal rights of any party

Categories of data subjects

Existing and potential customers

When NCAB Group is conducting business activities with you, such as delivering an order or presenting you with an offer, we process your data as an existing och potential customer.

NCAB group collects your data either directly from you, by external monitoring (such as websites and social media), personal contacts or other public sources. Your data is also collected by us if you choose to register in our customer portal.

The categories of personal data that we process about you varies depending on the purpose of the specific processing activity, but the following categories are examples of the kind of personal data that NCAB Group will process to facilitate our customer relationship with you:

Cookies

What are cookies?                                                                          

Cookies are small text files with information that are stored on your computer (or other Internet enabled devices, such as smartphones or tablets) when you visit a website. A cookie normally contains the name of the website it originates from, the duration period of the cookie (i.e. how long the cookie will be stored on your device) and a value, which is usually a randomly generated unique number.

What does NCAB Group use cookies for?

Cookies are used to make our website work more efficiently, but also to provide us with certain information. Cookies make it possible to distinguish between users, which can give each user a more customized and positive experience of the website.

Cookies that are used on the websites

There are five types of cookies on the websites:

• Necessary cookies helps us to make our websites usable by enabling basic functions like page navigation and access to secure areas of the websites. The websites cannot function properly without these cookies.
• Preference cookies enable our websites to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
• Statistic cookies helps us as website owners to understand how you interact with the websites by collecting and reporting information anonymously.
• Marketing cookies are used to track you across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.
• Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.

Personal data processing outside of the EU and UK

As a global company, NCAB Group is comprised of entities and affiliates outside of Europe and we might use processors that are established in countries outside of Europe. Therefore, it is possible that your personal data will be transferred or made accessible to entities outside of the EU, the UK or countries that provide adequate levels of data protection by decision of the Commission, such as Japan, and the US if the recipient entity is bound by the EU-US Data Privacy Framework.

To ensure that your personal data is given an adequate protection when your data is processed outside of the EU, UK or countries that provide adequate levels of data protection by decision of the Commission, we ensure that appropriate legal, technical, and organizational safeguards are put in place.

Sharing your personal data

NCAB Group may come to share your personal data with, or make your personal data available to, other parties. The purpose for doing so varies but it will either be to ensure that NCAB Group adheres to legal obligations or to serve a legitimate interest, either to us or to you.

Suppliers and vendors

NCAB Group uses several processors to facilitate our business. Processors may only process your personal data in accordance with clear instructions given by us, and they may not use your personal data for their own ends.

NCAB Group is obligated to ensure that we only appoint processors that can provide sufficient guarantees that the requirements of the GDPR and other data protection legislation will be met, and the rights of the data subjects protected. These processors are not allowed to engage another processer without prior and specific, or general, written approval by us. All processors that we use are to be bound by a data processing agreement, regulating the data processing they perform on our behalf.

Whether NCAB Group uses a processor to process your personal data our not, we are still responsible to ensure that your personal data is sufficiently protected.

Government agencies and public authorities

In certain situations, NCAB Group is obligated to provide government agencies and public authorities with your personal data that we have collected or that you have provided to us. This includes providing government agencies with your personal data for the government agency to perform its task, such as national taxations agencies. In addition, we might disclose your personal data to adhere to lawful requests by national security agencies or law enforcement.

Unions and Employers’ organizations

We will share your personal data with Unions and Employers’ organizations in certain situations to fulfill national labor law regulations.

External advisors

NCAB Group will share your personal data with external advisors, such as law firms, to meet and manage legal demands, in case of litigation and legal process, should they arise.

In addition, we might share your personal data collected by us with PR agencies, customer survey and marketing providers and other such parties to ensure that NCAB Group’s services reach our target groups and are optimized based on customer feedback.

Your rights as a data subject

As a data subject, you are entitled to the following specific rights under data protection legislation such as the GDPR, UK GDPR and PIPL.

Right of access

You have the right to obtain information from NCAB Group regarding whether we process your personal data. If that is the case, we are obligated to inform you of:

• the purpose of the processing
• the legal basis of the processing
• the categories of personal data concerned
• the recipients of categories, especially if these are located outside of the EU and the UK
• if possible, how long we will store your personal data
• your other rights as a data subject
• your right to lodge a complaint with a supervisory authority
• any available information we have about the source from which we collected your data if it was not from you yourself
• the existence of automated decision-making, including profiling

Right to rectification

You have the right to have inaccurate personal data rectified or completed if it is incomplete.

Right to erasure

You have the right to have your personal data deleted, also known as the right to be erased. However, this right is not absolute, seeing as there are situations when, for example, NCAB Group is legally obligated to continue to process your personal data even if you make a request of having it deleted.

Right to lodge a complaint with a supervisory authority

If you are in any way dissatisfied about how we process your personal information, you have the right to lodge a complaint to a supervisory authority. The supervisory authority with the primary jurisdiction over NCAB Group is the Swedish agency Integritetsskyddsmyndigheten (IMY). You can lodge a complaint with IMY here.

NCAB Group’s ambition is to make sure that anytime you want to exercise your rights, we will adhere to your request within 30 days.

Changes to this privacy policy

NCAB Group reserves the right to make changes to this Privacy Policy from time to time.

Contact

If you have any questions regarding this Privacy Policy, the processing of your personal data, or any other question regarding data protection or cookie management at NCAB Group, feel free to contact us at: info@ncabgroup.com

If you want to contact the data protection officer with questions and or concerns, feel free to contact the data protection officer at: dpo@ncabgroup.com

NCAB Group AB
Löfströms Allé 5
172 66 Sundbyberg
Sweden
Phone: +46 8 403 000 50