General Information about processing personal data
At Inizio we take personal integrity very seriously and protect your personal data. We comply with legislation that is applicable at any given time with the aim of protecting you as a private individual.
Our objective is that you should feel secure that your personal integrity is respected and that your personal data is processed correctly. We take responsibility that personal data that is processed by Inizio is used solely for the intended purposes and protected against unauthorised access. All processing of personal data within Inizio takes place in accordance with applicable personal data legislation. From 25 May 2018, the general data protection regulation (GDPR) applies within the EU/EES.
Please read this integrity policy carefully in order to understand how and for which purposes we process your personal data. In providing your personal data to us and approving applicable conditions, you consent to your personal data being processed in accordance with that stated in the specific terms and conditions for the respective service and this integrity policy. If the law requires more specific consent from you, we will naturally ask for it.
Amendments in this integrity policy are notified in that the new terms and conditions are published on Inizio’s websites and we therefore recommend that you regularly appraise yourself of them. If you add personal data about other individuals, you are also responsible that Inizio processes the personal data in accordance with applicable integrity conditions.
What is personal data and processing of personal data?
”Personal data” refers to all information that can be directly or indirectly linked together with other information about a currently living natural person. It means that widely divergent information such as name and contact details, IP-addresses, survey responses, choices made and behaviour comprise personal data.
Processing of personal data is everything that takes place with personal data. Every measure that is taken with personal data constitutes processing, regardless of whether or not it is compiled automatically, such as collection, registration, organisation, structuring, storage, processing or change, production, reading, use, issue through transfer, dissemination or supply by other means, adjustment or compilation, limitation, deletion or destruction.
To ensure that you have as good an insight as possible into how we work with personal data, we have organised our integrity policy in the following sections:
1. Who is responsible for your personal data and contact information
2. Legal grounds and legitimate interests for personal data processing
3. What personal data do we process?
4. Why we collect your personal data and how long it is saved
a. Processing of personal data for children
b. External links
5. What rights you have
6. Who we share your information with
8. Security measures
1. Who is responsible for your personal data?
Inizio Sweden AB is data controller for the information that is provided directly to us by an individual. In certain contexts Inizio can act as data processor. In these cases, a data processor agreement is drawn up in order to regulate how your personal data is processed by Inizio. If you have points of view, questions or other considerations concerning our integrity policy or processing of personal data, you are always welcome to contact us via e-mail or by post to:
Inizio Sweden AB
SE-411 10 Göteborg
Tel.: +46 (0)70-984 58 34
Corp. ID no. 556650-7124
2. Legal grounds and legitimate interests for personal data processing
Inizio always processes your personal data in accordance with applicable legislation. We process your personal data when it is necessary to fulfil a contract with you or answer a request from you and when we have another legitimate and rightful interest to process your personal data, e.g. an interest in marketing ourselves to visitors in our digital channels or an interest in developing our digital channels. If Inizio should process your personal data for any purpose which, according to applicable legislation, requires your consent, we will obtain your consent in advance.
3. What data do we process?
When you visit/use our digital channels or their services or communicate with us, we may collect information about you such as name, address, postal address, e-mail address, telephone number, identification details, information about your usage of our services and products and transaction history and for certain services, images and site information as well.
Where appropriate, personal identity number and card details may also be processed.
In addition, Inizio may collect technical data about the units you use to gain access to our digital channels, including IP-address, unique unit ID, type of web browser and cookie information.
The collection described herein takes place, for example, through you providing your personal data in various forms in our digital channels or their services, that you communicate with Inizio and others via Inizio’s platforms and in social media, provide points of view in our contact form or via telephone, download reports from Inizio’s web pages or register for newsletters or events that Inizio arranges.
When you contact us via forms in our digital channels, in connection with queries for example, your contact details and case information will be processed by us.
If you visit or communicate with us via our accounts in social media (i.e. third party platforms such as Facebook and Twitter for example), Inizio may receive information concerning your profile and your interactions on the third party platform from the supplier of the platform.
4. Why and for how long do we process your personal data?
Within Inizio we process personal data for users and customers of Inizio who use our services. We process personal data about you principally in order to administer mailings of offers and information to you, but also in order to collect information about current social issues and to conduct surveys on behalf of companies and organisations inside and outside Sweden. In detail, we use your personal data:
To enable us to supply the products and services you ordered and administer our contract with you;
To invite you to participate in, or conduct market research and/or opinion polls commissioned by companies and organisations inside or outside Sweden;
To invite you to participate in user panels;
To clarify or further develop answers to questions that we have asked you in a survey;
To enable us to communicate with you in contacts via telephone, e-mail, forms and in our accounts in social media;
To ensure that the information we have about you is correct and current;
To administer marketing activities;
For marketing purposes, including marketing via post, e-mail and SMS/MMS (which you can deselect via a link in each mailing made via e-mail or SMS/MMS);
To analyse and group the visitors according to selection, priority and preferences, which means that so-called profiling takes place with the aim of being able to provide you with relevant and customised information, surveys, recommendations, advertisements and offers. It is also possible that data which derives from usage of various digital channels from Inizio and from our collaborative partners is coordinated for this purpose, as well as for the purpose of developing products and services;
To process inward payments and/or outward payments or prevent or detect fraud;
To produce statistics about the use of our digital channels and their services; and
To maintain, develop, test and improve our digital channels and the technical platforms on which they are provided.
The personal data will only be processed by us for as long as it is necessary to fulfil the purposes for the processing or to fulfil Inizio’s legal obligations.
If you have not participated in a survey or been in contact with us within a period of 36 months, your information will be deleted, provided that it is not required to meet other legal obligations.
4, a. Processing of personal data for children
Underage refers to persons under 16 years old, in Sweden.
Inizio’s surveys and digital channels are not targeted at children and consequently Inizio does not consciously collect personal data about children. If you are guardian and become aware that your child has provided personal data to Inizio, we ask you to contact us at the addresses indicated in item 1 so that you can exercise your rights with respect to, for example, correction or removal.
4, b. External links
This integrity policy applies for information which Inizio processes about you within the framework of our digital channels. Inizio’s digital channels can sometimes contain links to external websites or services that we do not control. If you follow a link to an external website, you are urged to appraise yourself of the principles for personal data processing and information about cookies that applies for the relevant page.
5. Your rights
If you want to utilise any of the following rights, please contact us via email (mail address) or post to the address provided in item 1.
- Right to information: you can ascertain at any time which information, if any, we have about you in our register and how we process it. We will respond to your wishes without unnecessary delay and within one month. If for any reason we are not able to fulfil your wishes, a justification will be provided.
- Right to correction: You are entitled to request correction in relation to personal data that we process about you. At your request or when Inizio detects it, Inizio will correct or delete incorrect or incomplete information.
- Right to deletion/be forgotten: You can request at any time that we cease processing your personal data and also delete the information we have about you. If you have registered for newsletters, subscriptions or notification of other updates and do not want to have further e-mail messages, you can also unsubscribe via the link in the mailing.
- Data portability: you are entitled to access the information you have provided yourself in order to transfer it to another service.
- Objection to processing: you are entitled to object to processing of your personal data.
- You are also are entitled at any time to submit a complaint to the applicable supervisory authority if you consider that your personal data is being processed in contravention of applicable personal data legislation.
Inizio is not responsible for problems that arise as a result of the personal data being old or incorrect if you have neglected to notify us of the change.
6. Who do we share your information with?
Inizio can engage external collaborative partners (suppliers) to perform tasks on Inizio’s behalf, e.g. to provide IT-services, payment solutions or help with marketing, analyses or statistics. The execution of these services may mean that Inizio’s collaborative partners, both within the EU/EES and outside the EU/EES, have access to your personal data. Companies which process personal data on Inizio’s behalf always sign a contract with Inizio to ensure there is a high level of protection for your personal data at our collaborative partners too. In relation to collaborative partners outside the EU/EES, specific precautionary measures are instituted, for example, contracts which include standard clauses for data transfer which have been adopted by the European Commission and which are available on the European Commission’s website.
Inizio may provide personal data to third parties, for example, the police or another authority, if it concerns investigation of crime or if we are otherwise legally obliged to provide such data based on an official decision.
Inizio will not surrender your personal data to any another extent than that described in this item 6.
A cookie makes it possible to recognise your computer and collect information about which pages and functions have been visited. Cookies are sometimes used to collect information that is regarded as constituting personal data, for example: IP-addresses and information linked to the IP address. Cookies are essentially used by all websites and are often a prerequisite that the website or the digital channel is able to function.
On Inizio’s websites cookies are used from:
- Google Analytics in order to analyse web traffic and user behaviour. These cookies store information about how the visitors use the website, for example, where they come from, how many and which pages are visited and how long they spent on the website. These cookies help us to analyse the visitors’ behaviour on the website in order to improve the user experience and ensure the website’s functionality.
- WPML automatically checks which language setting your web browser has, directs to the right language page and also saves a cookie on your computer with the most recently selected language settings.
An approval of web tracking and analysis can be withdrawn at any time. An addition to your web browser can be downloaded from Google’s website and installed. Alternatively, you can delete cookies from your computer or mobile unit yourself via the web browser. For instructions on how to manage and delete cookies, go to the ”Help” option in your web browser. You can select to deactivate cookies or obtain a notification each time a new cookie is sent to your computer or mobile unit. Note that if you select to deactivate cookies, you will not be able to utilise all functions on our website
No information is transferred to any third parties.
8. Security measures
Inizio takes appropriate technical and organisational steps to ensure that your personal data is processed securely and in accordance with this policy against improper access, alteration, distribution and/or destruction.