INTRODUCTION AND SCOPE
This Privacy Notice describes how Smart Eye Aktiebolag (publ), registration number 556575-8371, (”Smart Eye”, ”we”, ”our” and ”us”) process personal data about you who visits our website or otherwise interact with us as a business contact or shareholder/investor.
In this Privacy Notice, we explain what kind of personal data we may process and for what purposes. Furthermore, we explain what choices and rights you have. We kindly ask you to read this Privacy Notice carefully and make yourself familiar with its content.
Please note that some of our services and parts of our business may involve the handling of types of personal data that are not listed in this Privacy Notice, such as for employees, consultants and participants in eye tracking studies/research. We will however always notify you clearly in connection with collection and processing of such personal data in connection with these situations when that would be the case.
Please contact us if you have any questions or concerns, or if you want to exercise any of your rights in relation to our processing of your personal data. You will find our contact information at the bottom of this page.
WHOM DO WE PROCESS PERSONAL DATA ABOUT?
We process personal data regarding the following categories of persons:
Business contact, meaning private persons who represent our existing or future customers and business partners, such as service providers, suppliers etc.
Investor relations, meaning private persons who represent our existing or future investors, such as shareholders, financial actors and any other stakeholders with an interest in Smart Eye.
Website visitors, meaning private persons who visit our website and interact with us through the functions of our website.
PERSONAL DATA PROCESSED
Personal data includes any information that can identify you, either directly or indirectly. We may collect personal data concerning you from various sources, such as the company or investor which you represent (e.g. your contact information) but also collected directly from you (e.g. contents of communication).
We may process the following personal data about you when you interact with us as a representative of a customer or other business partner:
We may process the following personal data about you when you interact with us as a representative of an investor/as a shareholder:
WHY WE PROCESS YOUR PERSONAL DATA AND OUR LEGAL BASIS FOR OUR PROCESSING
We process your personal data and information about the company that you represent for the following purposes:
The legal basis for processing of your personal data as set out above is a legitimate interest, meaning that the processing is necessary for our legitimate interest to initiate, maintain and follow up on our business relations with the company which you represent as well as to provide the company with information and relevant offers on our products and services.
We process your personal data about you as a shareholder and/or information about the investor that you represent for the following purposes:
Our legal basis for the processing of your personal data as set out above is either i) a legitimate interest, meaning that the processing is necessary for our legitimate interest to communicate with you/the investor which you represent as well as to provide you/the investor with relevant information on our business, or ii) a legal obligation, i.e. we must process your personal data to meet our legal obligations in relation to conducting shareholders’ meetings and managing related issues (such as voting, dividends and whether you are a direct or nominee-registered shareholder), maintaining an insider logbook, etc.
If you want more information on our legal basis or legitimate interest in relation to a specific processing, please do not hesitate to contact us.
HOW LONG WE PROCESS AND STORE YOUR PERSONAL DATA
We keep your personal data for as long as you represent the company, alternatively for as long as we have an on-going business relationship with the company which you represent or otherwise have a need to keep the information that includes your personal data for the purpose of a project. We will delete your personal data that is not required for the purpose of a project as soon as we receive information from you that you no longer represent the company, alternatively when we no longer have an on-going business relationship with the company which you represent.
If you contact us via our website or by phone, your personal data will be collected and kept for as long as necessary to answer your question, handle your matter or similar.
Personal data that we process to fulfil our legal obligations, for example to comply with legal requirements in accordance with the Swedish Companies Act (2005:551) and Accounting Act (1999:1078), are processed for the duration of such requirements. Personal data processed for the purpose of distributing information about our operations and business are processed for as long as you or the investor which you represent have an interest in receiving such information, which, unless you declare otherwise, is assumed to be for as long as you are a shareholder.
Smart Eye may share your personal data to the categories of recipients listed below.
Companies within the Smart Eye group, such as Affectiva Inc. and iMotions A/S;
Partners and suppliers who provide us with their services, for example assistance with invoicing, orders or financial administration, marketing agencies or other marketing platforms, recruitment companies or suppliers of IT and cloud services, with whom we conclude the necessary data processing agreements ;
Authorities in Sweden or other countries that exercise supervision over our business and in regard to which we have an obligation under law or contract to provide requested information or transparency, such as tax authorities etc.;
Authority, court of law or other third party when required by applicable law or regulation as well as to assert, establish or defend legal claims, or to protect your or any other person’s fundamental interests;
Potential buyer (and its representatives and advisers) in connection with a proposed purchase, merger or acquisition; and
Other parties that you have given your consent to such sharing, or when required as a result of exercising any of your rights below.
SECURITY AND TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES
Smart Eye takes appropriate technical and organizational measures to prevent unauthorized or unlawful processing and access, loss, destruction or damage to personal data, thereby ensuring an appropriate level of security.
Smart Eye may process personal data within as well as outside of the EU/EEA. We will and must take necessary actions in order to ensure that the transfer of personal data is conducted lawfully and that the personal data will continue to be protected by the recipients outside of the EU/EEA.
You have the right to obtain confirmation as to whether personal data about you are being processed by us, and, if that is the case, access to such personal data and information about how we are processing it. This is called extract from the register.
You have the right to have inaccurate personal data about you rectified without undue delay. In some cases, you also have the right to add information to any incomplete personal data. You can also request that we limit our processing of your personal data while the accuracy of such data is being investigated by us. There are also other situations where you have the right to request that we limit our processing of your personal data.
Under certain circumstances, you have the right to have your personal data deleted, for example if the data is no longer needed for the purpose for which it was collected or if the personal data has been unlawfully processed.
You have the right to object to our processing of your personal data based on our legitimate interest, for example if you consider that our weighing of interests is inaccurate.
You have the right to receive personal data about you in a structured, generally used and machine‑readable format if the processing of your personal data is being based on your consent and have been provided by you. You are also entitled to transfer such personal data to another controller (data portability).
If you have any concerns regarding our processing of your personal data, please contact us by using the contact information below. You also have the right to file a complaint tothe supervisory authority in the Member State where you reside, work or where you consider that the personal data have been processed in violation of data protection laws. In Sweden, the supervisory authority is the Swedish Supervisory Authority for Privacy Protection (www.imy.se).
CHANGES TO THIS PRIVACY NOTICE
We may change or update this Privacy Notice. In such case, we will publish information on the changes or updates on our website. If we make changes that are not strictly editorial, we will inform you about this appropriately.
If you are dissatisfied with how we have processed your personal data, we ask that you contact us, refer to our contact details below:
Smart Eye AB
Första Långgatan 28B
SE-413 27 Göteborg, Sweden
Telephone: +46 31-606160
You also have the right to submit a complaint about our personal data processing to:
The Swedish Data Protection Authority
PO Box 8114
SE-104 20 Stockholm, Sweden