PRIVACY POLICY FOR SWEDE DREAM

SCOPE AND PURPOSE

This policy is applicable to the Processing of Personal Data at all companies included in the Hästens Group (“Swede Dream” or “we”). The purpose of this policy is to provide our current, former and potential customers, partners and other individuals (jointly referred to as “individuals” or “you”) with a general understanding of:

  • The circumstances under which we collect and process your Personal data
  • The types of Personal data we collect
  • The reasons for collecting your Personal data
  • How we handle your Personal data
  • Distribution of responsibility for the Processing of Personal data between various legal entities at Swede Dream, and
  • Contact details for us so you can receive information about and claim your rights in relation to our processing of your Personal Data.

This policy is updated continuously to reflect the measures taken by Hästens in relation to your Personal data.

You can always contact us for privacy and data protection issues by sending an email to privacy@SwedeDream.com.

By using Swede Dream Services, you agree to our Data Protection Policy and our processing of your personal information. You also agree that Swede Dream uses electronic communications channels to send information to you. It is important that you read and understand our data protection policy before using our services.

The Processing of your Personal data forms an important part of our provision of products and services to you. We appreciate the trust you place in us when providing us with your Personal data and we consider your privacy an essential part of the services Swede Dream provide.

In order to offer you our services, we need to process your personal information as below. We do this with the utmost account of your integrity.

GENERAL PRINCIPLES

Your Personal data belongs to you. We strive not to make any assumptions regarding your privacy preferences and aim to design our services so that you can choose whether or not to share your Personal data with us.

Swede Dream will only process its customers’ Personal data if it is adequate, relevant and necessary in relation to the purpose for which it has been gathered. We aim to anonymize your Personal data when a function or service can be achieved with anonymized data. If we combine anonymized or non-Personal data with your Personal data, it will be treated as Personal data for as long as it remains combined.

Swede Dream believes in being transparent about which Personal data we process and for which purposes. To us it is also vital to protect your Personal data since one of Swede Dreams’ core values is to protect what is important to you.

LEGAL COMPLIANCE

It is Swede Dream policy to comply with the applicable laws, rules and regulations governing privacy and data protection in every country where we operate. Where necessary, we will adjust our Processing of your Personal data as described in this policy to ensure legal compliance.

The Personal data which Swede Dream collects about you will be used

  • To provide you with products and services, including to verify your eligibility for certain purchases and services as well as to offer you enhanced offers and experiences
  • To fulfill information needs to be able to carry out all parts of the order process (e.g. lead, quotation, order, delivery, payment, warranty, return and refund)
  • To inform you of updates to, or changes in, our products and services, including but not limited to changes to our terms and conditions and policies
  • To inform you of new products, services and events
  • To provide product support and services (warranty service etc.)
  • To evaluate and improve our offering to, and communication with individuals
  • To comply with legal requirements or lawful authority requests
  • To carry out market research
  • For analysis and customer profiling purposes (online and social included)
  • To guarantee security for you and our employees at Swede Dream facilities

DATA COLLECTION

Information that you provide to us: You may directly or indirectly provide us with information about yourself in a variety of ways, for example by contacting us, order beds and accessories or services and sign up for newsletter, personal meeting, events and warranty through Swede Dream website, customer service, sales contacts, fairs and retail stores where you provide personal information. We may also obtain such data from our authorised dealers and other third parties. Such data (“Customer-provided personal data”) may include:

  • Your contact information (name, address, telephone number, email, etc.)

  • Data pertaining to your purchase and use of our products and services (customer preferences and settings, purchase history etc.).

Information we collect about you: When you use our services (such as when you confirm a purchase, sign contracts, confirm service agreements, attend events and use services provided on Hästens website) and for cold outreach marketing, we may collect the following information:

  • Your contact information (name, address, telephone number, email, etc.)
  • Demographic information (age, marital status, household composition, etc.)
  • Data pertaining to your purchase of products and services (customer preferences, purchase history, payment and credit history etc.)
  • How you interact with Swede Dream (how you use our services)
  • Client (PC, tablet, smartphone etc.) information (IP-address, language preferences, browser settings, time zone, operating system etc.)
  • Surveillance information (video surveillance in facilities, access system logs etc)

Cold outreach marketing will be performed on legitimate interest basis with balance against the individual’s interests, rights and freedoms. Only basic contact personal information will be used to send out marketing material by email or mail and phone calls can be made to follow up marketing materials. Contact information can be collected thru public services that provide personal information.

We are particularly careful and apply additional measures if and when collecting and Processing Sensitive Personal data, as required by applicable law. For avoidance of doubt, it is noted that applicable law may require other kind of data to also be treated as Sensitive Personal data.

The information you provide, as well as information about the products / services and your financial information is generally necessary to enter into a contractual relationship with us, while the other information we collect generally is necessary for other purposes, as described below.

WEBSITES AND COOKIES

In general, you can visit Swede Dream website without telling us who you are or revealing any information about yourself. However, to be able to provide you with certain services or offerings, we often need to record certain items of Personal Data such as your name and email address. We may also collect (by means of cookies) anonymous information on how you have used our websites prior to such recording. This information will be helpful to us in order to improve our websites or marketing. See Swede Dream Cookie Declaration at www.SwedeDream.com for information on the cookies we use.

CONSENT

Where reasonably practical or as required by applicable law, we will obtain your consent prior to collecting or using your Personal data. The request for your consent will be clear and specific and provide you with a reasonable basis with which to make your decision. We will never take your consent for granted. Instead, we will make sure that you can actively consent in a clear and transparent manner. Your consent is voluntary and may always be revoked, for example by contacting Swede Dream at the address indicated in the “Information and Access” section below. If you do not give your consent, it may not be possible to use services or parts of services.

INTERNATIONAL TRANSFERS

Swede Dream may in rare cases transfer your Personal Data to recipients in countries outside of the European Economic Area which may have differing data protection laws. This includes countries which the EU Commission does not consider to have an adequate level of protection for personal data. If this occurs Swede Dream will ensure there is are legal grounds for the transfer in accordance with applicable data protection legislation. You will also be informed about the legal grounds, what safeguards were implemented, and where you can obtain a copy of these safeguards.

DATA USE

For most Processing acts, you are able to terminate our use of your Personal data by updating your preferences or revoking your consent to the Processing by contacting Swede Dream at the address indicated in the “Information and Access” section below or as otherwise instructed by us. However, and unless otherwise follows from applicable law, you may generally not opt out of the Processing of your Personal data:

  • Which we perform in order to send you important notices, such as changes to our terms and conditions and policies or in case of product recalls

  • Which we perform in order to comply with our legal obligations.

RETENTION

We will only retain your Personal data for as long as it is necessary to fulfil the purposes outlined in this policy or the purposes of which you have otherwise been informed. This means that when you have consented to our Processing of your Personal data, we will retain the data for as long as the customer relationship lasts (and, where applicable, until the expiry of the warranty period) or until you withdraw your consent. If you have revoked your consent, we may nevertheless retain certain Personal data for the period required in order for us to meet our legal obligations and defend ourselves in legal disputes. If we have not received your consent for Processing, the data will only be retained to the extent we are permitted to do so by law.

DATA QUALITY

When we process your Personal data, we strive to ensure that it is correct and up to date. We attempt to delete or correct Personal data that is incorrect or incomplete. For more information regarding your right to ensure the accuracy of your Personal data held by us, please see the “Information and Access” section below.

INFORMATION AND ACCESS

Once per year you have the right to request, and receive free of charge, information on what Personal data relating to you that we process, the purpose of the Processing, and the recipients or recipient categories with which the Personal data is shared. Requests for such information must be made in writing and be signed by you personally, and include information on the name, address and ideally the email address as well. You are also entitled to request that we correct, block or delete any incorrect information related to you. Requests should be sent to the legal entity stipulated in the end of this document. Your requests will be dealt with in a prompt and proper manner. Requests to delete Personal data will be subject to any applicable legal requirements. Where the applicable law provides for an administrative fee for complying with such a request, such a fee may be charged by Swede Dream.

SECURITY

Swede Dream has taken technical and organisational measures in order to protect your Personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and any other unlawful forms of Processing.

DISCLOSURES TO THIRD PARTIES

Swede Dream may share your Personal data:

  • Among Swede Dream´s legal units
  • In connection with the sale or transfer of a Swede Dream entity or its assets
  • As required by law, for example in connection with a government inquiry, dispute or other legal process or request
  • When we, in good faith, believe that disclosure is necessary in order to protect our rights, for example in order to investigate potential violations of our terms and conditions or to detect, prevent or disclose fraud or other security issues

Swede Dream as the data controller of your Personal data will, as a general rule, only disclose your Personal data to a third party if we have received your consent to do so. However, if permitted by law we may share your Personal data without your consent, unless we consider your consent necessary in the individual case or your consent is required by law, in the following situations:

  • Situations in which disclosure is required by law
  • Situations in which disclosure is necessary for the purpose of a legitimate interest pursued by Swede Dream (for example in order to protect our legal rights, as described above)

MARKETING

We will not sell or trade your Personal data with third parties unless we have your consent to do so. We will not share your Personal data with third parties for their marketing purposes, unless we have received your consent for such disclosures. If you have provided such consent, but wish to stop receiving marketing materials from a third party, please contact that third party directly. We may provide you with information regarding new products, services, events or similar marketing activities. If you wish to unsubscribe to a particular e-mail newsletter or similar communication, please follow the instructions in the relevant communication.

CONTACT DETAILS

To contact data protection representative use following contact details.

privacy@SwedeDream.com

COMPLAINTS

You may at any time lodge a complaint with a supervisory authority regarding Swede Dream collection and processing of your personal data.