Privacy policy

 

1. General

1.1. This policy is applied in situations where Rite Internet Ventures Holding AB and its affiliated companies (“Rite”) process personal data. Rite processes personal data in accordance with the General Data Protection Regulation 2016/679/EU (“GDPR”).

1.2. Your personal integrity is crucial to Rite and Rite therefore aspires to the highest standard regarding data protection. This privacy policy explains how Rite collects and uses your personal information. The policy also describes your rights and how you can exercise such rights.

2. Controller

Rite Internet Ventures Holding AB (corporate identification number 556783-3875), Artillerigatan 6 4TR, 114 51 Stockholm, is the controller of your personal data and is thereby responsible for the processing of personal data undertaken by Rite.

3. How Rite uses your personal data

Purpose

Processing undertaken

Categories of Personal Data

To enter into or to fulfill a contract.

o Collection and storage of contact details

o Assessments/background checks prior to investments

o Communications with and transfer to service providers and partners

o Notifications to and/or contacts with relevant authorities

o Name

o Personal identification number

o Contact details (i.e. address, e-mail and phone number)

o Payment information

o Your correspondence with Rite

Legal basis: Necessary for the performance of a contract / Legal obligation / Legitimate interest. In order to enter into or to fulfill a contract with you Rite may need to process the data above, if you do not provide the data Rite may not be able to grant you enter into or fulfill the contract. Some of the information above is required by law (inter alia applicable law for accounting and money-laundering), if said information is not provided by you Rite may be unable to enter into or fulfill the contract. Your personal identification number will only be collected and processed when Rite has a legal obligation to do so or a legitimate reason to positively confirm your identity.

Duration of the processing: During the contract term and for eleven (11) years after the expiry of the contract or as long as Rite has a legal obligation to keep your personal data.

E-mails will for this purpose be stored up to ten (10) years after being sent or delivered.

Additionally, Rite may come to store your personal data for as long as necessary for the establishment, exercise or defence of legal claims (such processing will be based on Rite’s legitimate interest).

Purpose

Processing undertaken

Categories of Personal Data

To evaluate job applications and to recruit new employees.

o Necessary processing for the evaluation and recruitment of new employees such as contacting you or any references you may have supplied and comparing your work experiences with other applicants as well as contact details and general information about you.

o Name and personal identification number

o Phone number and e-mail address

o Work history and experience

o Criminal record

Legal basis: Legitimate interest / necessary steps at the request of the data subject prior to entering into a contract. Even if no employment contract is entered into between you and Rite, Rite may come to store your personal data for the establishment, exercise or defence of legal claims, or for practical reasons such as potentially using the information for the next recruitment process.

Duration of the processing: From the conclusion of the recruitment process and up to an additional 24 months thereafter.

 

Purpose

Processing undertaken

Categories of Personal Data

To contact clients and other persons who may wish to be contacted by Rite or otherwise comes into contact with Rite for marketing purposes.

o Collection and storage of contact details

o Organization of contact details

o Communication with clients and potential clients regarding our services and offerings.   

o Name

o Phone number

o E-mail address

o Address

o Financial information

Legal basis: Legitimate interest. Rite has a legitimate interest to market its services and for maintaining a personal relationship with its clients (business to business) that outweigh the interests of the data subjects (employees of clients and of prospective clients).

Duration of the processing: Contact information is kept for as long as legitimate interest exits or for as long as client/business relationship is ongoing and for an additional period of one (1) year thereafter.

Additionally, Rite may come to store your personal data for as long as necessary for the establishment, exercise or defence of legal claims (such processing will be based on Rite’s legitimate interest).

 

4. From what sources are your personal data collected

In addition to the data that you provide us, or that Rite collects from you due to the correspondence, phone calls, e-mail and/or other forms of communication between Rite and yourself, Rite may also collect personal data from someone else, a so-called third party. The data Rite collects from such third party is the following:

- data about your address collected from public registers in order to maintain current contact information about you;

- data regarding your credit rating from credit reference agencies, banks and other companies that provide such information if necessary to, inter alia enter into a contract; and

- contact information from professional/business related social media (such as LinkedIn) for marketing purposes.

- employment and/or engagement information from companies in which we have invested or may plan to invest in.

- curriculums and other related information from recruitment agencies. 

5. To whom your personal data will be disclosed

5.1. In connection with any of the purposes outlined above in section 4. “How Rite uses your personal data” Rite may disclose details about you to:

- competent authorities (including authorities regulating Rite and its business);

- your employer and/or your employers advisers;

- anyone to whom Rite may transfer its rights and/or obligations; and

- credit reference agencies or other organisations that help Rite make decisions and reduce the incidence of fraud.

5.2. Information about you Rite possesses may be transferred to other countries (which may include countries outside the European Economic Area (“EEA”):

- where Rite does business;

- which are linked to your engagement with us;

- from which you regularly receive or transmit information; or

- where our third parties conduct their business.

5.3. These countries may have less stringent data protection laws than does Sweden, so any information they hold can become subject to their laws and disclosure requirements, including disclosure to governmental bodies, regulatory agencies and private persons. In addition, a number of countries have agreements in place under which information is exchanged with other countries for law enforcement, tax and other purposes.

5.4. When Rite or its permitted third parties, transfer your personal data outside the EEA, Rite will impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the EEA. Rite or its permitted third parties may also require the recipient to subscribe to international frameworks intended to enable secure data sharing.

5.5. Rite may also transfer your data when:

- the transfer is to a country deemed to provide adequate protection of your personal data by the European Commission; or

- where you have consented to the transfer.

5.6. If Rite transfers your personal data outside the EEA in other circumstances (for example because it has to by law), Rite will make sure the data remains adequately protected.

5.7. Rite may share non-personal, anonymized aggregated information with third parties for several purposes, including data analytics research, submissions and promotional activity.

6. Rite’s website

6.1. When you visit Rite’s website, www.riteventures.com, Rite may collect information that helps Rite understand how people use the site so that Rite can continue to improve its site and thereby making the site more useful and valuable over time. No information collected in this way is directly or indirectly traceable back to a specific person.

6.2. In addition to the collection of basic user information, Rite also collects information that helps it monitor network traffic and enables Rite to identify unauthorized or unusual activity on the site. The information collected includes:

- name of the domain and host from which you access the internet (such as aol.com);

- internet protocol address of the host server you are using (such as ww3.aol.com);

- name and version of your web browser;

- date and time you access the site; and

- internet addresses of the site from which you linked to Rite, where applicable.

6.3. Some parts of the site may use a cookie, which is a small text file that is placed on your computer’s hard drive. The cookie captures no personally identifiable information. The site may use a cookie in order to log which pages you visit or to provide enhanced capabilities during your visit. You can set your browser to refuse to accept cookies; however, if you choose to do this, some features of the site and others may not function properly.

6.4. Rite’s website may contain links to other sites not owned or controlled by Rite. Rite is not responsible for the privacy practices and policies of other sites and/or their collection of your personal data. Rite encourages you to be aware when you leave Rite’s website and to read the privacy policies or statements of such other sites. 

7. Protecting your personal data

Rite uses a range of measures to ensure it keeps your personal data secure, accurate and up to date. These include:

- education and training of relevant staff to ensure that they are aware of your privacy obligations when handling personal data;

- administrative and technical controls to restrict access to personal data to a “need to know” basis;

- technological security measures, including fire walls, encryption, “remote swipe” and anti-virus software; and

- industry standard physical security measures to prevent unauthorized access our premises.

8. How long Rite keep your personal data for

Rite strives to ensure that it only keeps your personal data for the longest of:

- the period necessary for the relevant activities or services;

- any retention period that is required by law: or

- the period in which litigation or investigations might arise in respect of the services.

9. Your rights

9.1. You have various rights in relation to your personal data. In particular, the following rights:

Right of access

9.2. 

As a data subject, you have a right of access with regards to you personal data. Please note that Rite may require additional information in order to ensure an effective processing of your request and that the data is transferred to the right person.

Right to rectification

9.3. Should your personal data be incorrect you can have it corrected. You may also have the right to complete any incomplete personal data.

Right to erasure

9.4. You can demand to have your personal data erased in the following cases:

- the data is no longer necessary for the purposes it has been gathered or processed;

- you object to Rite’s balancing of it legitimate interests against your personal integrity and your reasons for objecting are deemed to outweigh Rite’s legitimate interest;

- you object to the processing for direct marketing purposes;

- your personal data has been unlawfully processed; or

- the personal data must be erased to comply with a legal or regulatory obligation that Rite has.

9.5. Rite may be unable to erase certain personal data due to obligations in i.e. applicable accountancy or consumer law. It may also be the case that the processing is necessary for the establishment, exercise or defence of legal claims. Should Rite be unable to comply with your request for erasure you have the opportunity to demand that the personal data is blocked from use for all purposes but the purpose for which the data must be saved.

Right to restriction of processing

9.6.In certain situations, you have the right to request that Rite restricts its processing of your personal data. If the processing is to be restricted, Rite may only, in addition to the actual storing of your data, process the personal data to the establishment, exercise or defence of legal claims, to protect the rights of someone else or if you have given your consent to the processing.

Right to object

9.7. You always have the right to not be subject to direct marketing and to object to processing of personal data that is based on a balancing of interests. In order to keep processing your personal data after such an objection Rite needs to demonstrate compelling legitimate grounds for the processing that overrides your interests and rights. In other cases, Rite may only process the data to the establishment, exercise or defence of legal claims.

Right to data portability

9.8. If our processing of your personal data is based on your consent or the fulfillment of an agreement with you, you have the right to request to have the data that relates to you and that you have supplied to Rite transferred to another controller (so-called data portability) provided that the transfer is technically possible and can be carried out by automated means.

10. Competent authority

If you are dissatisfied with Rites processing of your personal data, you can always turn to the Swedish Data Protection Authority at www.datainspektionen.se.  

 

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