Bulb Comp Data AB with company reg. no. 559220-1163 (the “Company”) highly values and protects the privacy of individuals. We aim to act with transparency in how process our personal data and always follow the General Data Protection Regulation (the “GDPR”) and other applicable legislations in order to safeguard the integrity of individuals.

Introduction

The Company provides a web-based service where customers may receive information about Nordic companies’ remuneration to the Board, the CEO and senior executives (“the Service”).This privacy policy provides information on how the Company collects, processes and stores personal data about data subjects processed in the Service and how it manages personal data related to its customers.

Controller of personal data

The Company, with the contact details as found below, is the controller for processing of the direct or indirect personal data published in the web-service and for personal data related to its customers.

Collection and retrieval of personal data

The Company continually collects personal data about Nordic companies’ remuneration to senior executives from public registers and from companies’ websites.

The Company may also obtain personal data related to its customers’ contact persons or other personnel from its customers.

Purpose of the processing

The purpose of the Company’s processing of personal data is to provide its customers with information about Nordic companies’ remuneration to its senior executives through the Service. The Company may also itself use the Service in order to provide remuneration related consultancy services to its customers.

Personal data about the customers’ contact persons and other personnel are collected and processed in order to enable providing the service to the customer and to administer the customer relationship.

Legal basis

The Company processes personal data in the Service and personal data related to its customers on the legal basis that the Company’s legitimate interest to fulfil the above stated purposes, and where these purposes outweighs the data subjects’ rights to not have his or her personal data processed.

The data subjects have the right to object to the Company’s processing which is performed under the legal basis of a weighted assessment of the Company’s and the customer’s interests. More information about the data subjects’ rights may be under section “Rights of the data subjects” below.

Data minimisation and anonymisation

The Company does not collect more personal data than what is absolutely necessary to fulfil the predefined purposes of the processing.

The Company only store the personal data for as long as what is necessary to fulfil the purposes under which the personal data have been collected. The personal data may however be processed longer if such processing is necessary in order to determine, enforce or defend legal claims or compulsory law otherwise requires that the data is to be stored longer.

The Company may irreversibly anonymise personal data and store such information for a longer period for the purpose of providing market statistics.

Security

The Company applies a high level of security to the storage and processing of its personal data, including routines of technical and organisational nature. These routines are regularly updated and ensures that no data is manipulated, lost or wrongfully made available to unauthorised persons within or outside the Company’s organisation.

Subcontractors and transfer of personal data to third countries

The Company uses subcontractors to provide the service and to administer its customer relationships. All subcontractors engaged by the Company have signed data processing agreements which safeguards the rights and interests of any personal data of which the Company is the controller.

All processing of personal data of which the Company is the controller is performed within the EU/EES.

Rights of the data subject

The Company is responsible for processing any personal data in accordance with applicable law. As part of this, the Company would like to inform any data subject of its rights under the general data protection regulation:

• A data subject has the right to obtain information about the Company’s processing of its personal data, including inter alia what information are processed, the purpose and legal basis of the processing, potential recipients, estimated duration of the processing (if possible) and the existence of automated decision making, including profiling, as referred to in article 22 (1) and (4) of the GDPR.
• A data subject has the right to rectification of inaccurate personal data concerning him or her.
• A data subject may have the right to erasure under the circumstances stated in article 17 of the GDPR.
• A data subject may have the right to restriction of the Company’s processing under the circumstances stated in article 18 of the GDPR.
• A data subject have the right to data portability, including the right to receive the personal data concerning him or her in a structured, commonly used and machine-readable format.

If you as a data subject has concerns or objections about the Company’s processing your personal data, please contact us or submit a written complaint to the Swedish Data Protection Authority (https://www.datainspektionen.se/other-lang/in-english/about-us/contact-us/).

For additional information of how we process your personal data, please notices below or contact us.

Privacy notices

Information to data subjects processed in the Service (https://www.bulbcompdata.com/homebulb/InfoDataSubjects )

Information to customers (https://www.bulbcompdata.com/homebulb/InfoCustomers )

Contact details

Bulb Comp Data AB, org. no. 559220-1163

Annavägen 4

184 51 Österskär

Sweden

[email protected]