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INTEGRITY POLICY

For us at NorthTracker, it is important that you and your personal data are treated responsibly with regard to your privacy and that you find out what information we collect about you and how we use it. This is described in this policy as well as your rights and how you go about exercising your rights.

Who is responsible for personal data?

The person responsible for personal data is NorthTracker AB, reg.no. 666826-4674, Box 94, 178 02 Drottningholm. If you have any questions regarding the handling of your personal data or regarding this privacy policy, please contact us at dataskydd@northtracker.com.

For personal data that is collected to fulfill agreements with our customers, it is often the customer himself who is responsible for personal data. NorthTracker then acts as personal data assistant to the customer and in these cases a personal data assistant agreement is entered into between the customer and NorthTracker.

Our processing of personal data

We collect and process the personal data that you provide to us, for example when you email us or use our services. Personal data that we process:

1) Contact details including name, address, phone number and email address.

2) Identity documents or background information that we received from you or collected as part of our customer knowledge.

3) Payment information, payment history and any financial information in connection with credit assessment.

4) Purchase history.

5) Information you provide in connection with meetings, when we initiate a business relationship, via e-mail, or otherwise via oral or written contacts.

6) Information about you that we receive from other sources, such as public records and business partners.

7) Data generated automatically when using our services, such as GPS position and travel data including start and stop addresses, speeds, direction, duration, distance, temperature, digital signature, registration number and other information about car, serial number on ID card, driver’s license, employment number, position/role. Logging of user patterns, statistics and analysis data including IP address.

 

Purpose and legal basis for the processing

NorthTracker processes personal data first and foremost as part of implementing the agreements we have entered into with our customers, but also for customer service, customer follow-up, customer administration, marketing and invoicing. Processing also takes place as part of fulfilling our legal obligations and to establish, enforce or defend legal claims.

 

Customer surveys

After you have been in contact with NorthTracker, we may ask you about your experience. By participating in the customer survey, you help us improve our products and services. If you do not want to share this type of information with us, you do not need to participate in the customer survey.

 

Newsletter and marketing

You may receive marketing, information in the form of newsletters and news, promotions and invitations, as well as system alerts about your services from NorthTracker. You can register or unregister to receive these communications at any time.

 

How long do we store your personal data?

We will only retain your personal data for as long as is necessary to fulfill our commitments to you as a customer and the purposes specified in this policy. When we save your data to fulfill legal obligations, we save it only as long as it is necessary and/or legally required for the respective purpose. We will carry out regular thinning and remove personal data if it is no longer needed.

 

Who may receive access to your personal data?

In order to provide our goods and services to you, we may transfer to, or share your information with, selected third parties:

 

1) Banks in connection with the administration of payments.

2) Debt collection and credit reporting companies when loans/credits/receivables are due for payment and in the case of searches made by credit reporting companies in connection with entering into an agreement.

3) The Tax Agency, the Police and other authorities in connection with statutory reporting or other statutory obligations.

4) External providers of services in, among other things, accounting, support and IT.

5) Professional advisers and other personal data assistants according to personal data assistant agreements.

6) Insurance companies.

7) Third party, when necessary due to legal obligation. If we are required to disclose your personal data due to an injunction or similar, we will inform you to the extent that we are not legally prevented from doing so.

 

We do not transfer your personal data by selling your personal data or otherwise making your personal data available for commercial purposes without your consent.

 

How do we protect your personal data?

NorthTracker strives to protect your personal data and maintains appropriate technical and organizational measures f to prevent inappropriate or involuntary disclosure, use, access, loss, alteration or damage to your personal data.

 

We only process your personal data within the EU/EEA.

Your rights

According to current data protection legislation, you have a number of rights linked to our processing of your personal data.

Right of access (“register extract”)

You have the right to receive confirmation of whether personal data concerning you is being processed and, if so, access to your personal data.

Right to rectification

You have the right to have incorrect or incomplete information about yourself changed/corrected.

Right to erasure (“the right to be forgotten”)

If you no longer want us to save your data, you have the right to have your data deleted provided that it is no longer necessary for the purpose for which it was collected. However, there may be legal obligations such as the Accounting Act, which means that we cannot immediately delete parts of your data. In such cases, we will only save the data that we are obliged by law to keep. If the processing is based on consent and this is revoked, your data will be deleted.

 

Right to limitation

You have the right to demand that the processing be restricted (if you dispute the accuracy of the personal data, if the processing is illegal and you request restriction instead of deletion, if you need the data for a legal claim or if you have objected to the processing and are awaiting a check).

 

The right to object to certain types of treatment

If your personal data is processed on the basis of a general or legitimate interest, you have the right to object to the processing. For example, you have the right to object to your data being processed for marketing purposes.

 

Right to data portability

You have the right to receive the personal data that you have provided to us in a structured, commonly used and machine-readable format. This applies if the processing is automated and is based on your consent or an agreement to which you are a party. You also have the right to request that this data be transferred to another personal data controller if it is technically possible.

 

Right to withdraw consent

If our processing of your personal data is based on your consent, you can withdraw your consent at any time.

 

The NorthTracker BLE app

The NorthTracker BLE app uses location data from the phone. Positioning is used to be able to position the various Bluetooth devices and display them on a map. This is to get an overview and control over where the material equipped with a Bluetooth device from NorthTracker is located.

 

One can manually set the app to search for the Bluetooth devices in the background to simplify and automate the search for the devices.

Bluetooth is used to search and find Bluetooth devices from NorthTracker. When the app is in contact with the device, it can read the distance to the bluetooth device. For one of the two different Bluetooth models from NorthTracker, the app can also read temperature, humidity and whether the device is in motion.

 

Right to complain to the supervisory authority

If you are not satisfied with the way we process your personal data, you have the right to submit a complaint to the Data Inspectorate, which is the Swedish supervisory authority. You can find the Datainspektionen’s contact details at www.datainspektionen.se.