Information to Data Subjects Processed in Service
Data controller
Bulb Comp Data AB (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.1. Purpose of the processing
- 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”). The Company collects and processes personal data from publicly available sources (e.g. annual reports, interim reports and financial statements) for the purpose of providing the Service.
- The Company may use the Service, and thus process personal data, in order to provide remuneration related consultancy services to its customers.
- Personal data may also be used for the development of the Company’s business and methods, market analyses and marketing.
2. Legal Basis
- The Company processes personal data in the Service based on the Company’s legitimate interest to fulfil the above stated purpose, and this purpose outweighs the data subject’s rights to not have its personal data processed. In light of the fact that the personal data is normally available to the public and the fact that access to the personal data is restricted (see item 5.1), the commercial interest, in the Company’s estimation, outweighs the data subject’s rights not to have his or her personal data processed.
- The data subject has the right to object to the Company’s use of a weighted assessment of the Company’s and the data subject’s interests as a legal basis. More information about the data subject’s rights may be found under section 6 (The data subjects’ rights) below.
3. Duration of the processing
- The Company will store and process personal data for the duration necessary for fulfilling the purpose of the processing, however no longer than five (5) years after the personal data was first collected and/or published in the Service. 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 anonymise personal data and store such information for a longer period for the purpose of providing market statistics. No personal data will be stored or otherwise processed for a longer period of time than what is stated in section 3.1 above.
4. Categories of data subjects and personal data
- The Service does not include any names or other direct identifiers. However, the Service contains information on remuneration levels for senior executives (for example, the Board of Directors, the CEO and other individuals in the management group) in specified companies, which together with other retrievable data may be deduced to individuals. The Service thus contains indirect personal data about individuals’ salaries, shareholdings and incentive programs.
5. Recipients and transfer of the personal data
- Personal data will only be made available to companies and individuals who have a legitimate purpose to the Service, e.g. employees of listed companies who in their work need to obtain and analyse remuneration of senior executives in Nordic companies in order to establish new remuneration policies.
- Personal data may be transferred to the Company’s subcontractors and others who on the Company’s behalf perform services related to the Service.
- The Company only stores and process the personal data within the EU/EES.
6. The data subjects’ rights
- A data subject, i.e. an individual whose personal are being processed in the Service, is without cost entitled to request information about the Company’s processing of his or her personal data. Upon the data subject’s request, the Company will correct or delete incorrect personal data and if requested and found necessary limit the processing of these. The data subject also have the right to object to the Company’s processing based on the Company’s weighted assessment as a legal basis. If the Company finds that the processing is still necessary, the Company must show that its interests outweighs the data subject’s rights.
- If you as a data subject has concerns or objections about the Company’s processing of his or her 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/).