Privacy Policy
Why and who?
Encube Technologies AB, registration number 559343-6909, (“Encube”, “we”, “us” or “our”) cares about privacy and protecting the personal data processed by us. This means that we care about your personal integrity and actively work to protect it.
In this privacy policy (“Policy”) we describe how and the purposes for which we process your personal data as well as what lawful basis we use and what measures we take to protect your personal data. We also provide information on how you exercise the rights you have in relation to our processing of your personal data.
We are responsible for the processing of your personal data as described in this Policy in the capacity of data controller. If you would like to know more about our processing of your personal data, you are welcome to contact us.
It is important to us that you feel comfortable with how we process your personal data, and we therefore ask you to read through this Policy, which we may update from time to time. If we make changes to the Policy, the new version will apply from the time it is published on our website.
How we collect your personal data
The personal data we process relating to you is collected directly from you or from third party data sources, such as our business partners. If you would like to know more about from which third parties we collect your personal data, you are welcome to contact us.
Encube’s processing of personal data
We have a responsibility to describe and demonstrate how we fulfil the requirements that are imposed on us when we process your personal data. This section aims to give you an understanding of what type of personal data we process and for what purposes.
We only process your personal data to the extent permitted in accordance with applicable data protection legislation. This means that we need to have a legal basis for the purposes of our processing of your personal data, which in our context generally means one of the below legal bases. If you are acting on behalf of someone else, e.g., in the capacity of a representative of an entity, our processing is carried out with reference to our legitimate interest balanced against your interests or fundamental rights or freedoms, where our legitimate interest is to conclude and perform the contract with the entity you represent.
Performance of a contract - The processing is necessary in order for us to provide you with our services or otherwise perform a contract between us or the entity you represent, or to take steps at your request prior to entering into a contract.
Performance of legal obligations - The processing is necessary to fulfil our legal obligations according to law or other statutes that we are subject to, or if we are subject to orders or decisions by courts or authorities, which require us to process your personal data.
Legitimate interests - The processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, if they are not overridden by your interests or fundamental rights or freedoms.
Consent - The processing is carried out with your prior consent, where we are responsible for clearly informing you of what processing you consent to and your right to withdraw your consent in relation to our continued processing.
To register you as a user of the Encube platform
Types of personal data
• Contact details, i.e., name, e-mail address, phone number and address
• Professional title as well as information about the entity you represent
The purposes of the processing activity
To enter into or fulfil contracts between us or the entity you represent concerning the Encube platform.
Legal basis
Contractual obligations: We need to process your personal data in order to fulfil our obligations in relation to the contract (Article 6(1)(b) of the General Data Protection Regulation).
Retention period
We process and store your personal data until the contract terminates and up to two (2) years thereafter or for a period of time to fulfil legal obligations, for example according to applicable accounting laws, whichever is longer.
Relations with suppliers, customers, users etc.
Types of personal data
• Contact details, i.e., name, e-mail address, phone number and address
• Professional title as well as information about the entity you represent
• Information which you provide to us when communicating with you
The purposes of the processing activity
To manage your account and to maintain and develop our relation with you or the entity on whose behalf you represent.
Legal basis
Legitimate interest: Our legitimate interest to engage in, maintain and develop our business relation with you or the entity you represent (Article 6(1)(f) of the General Data Protection Regulation).
Retention period
We process and keep your personal data while we have a business relation with you or the entity you represent, however for a maximum of two (2) years from the time we last were in contact because of our business relation.
Contracts with suppliers, customers, users etc.
Types of personal data
• Contact details, i.e., name, e-mail address, phone number and address
• Organisational information, such as the name and address of the company, job title, employment area, primarily place and country of work
• Contractual information, such as orders, invoices, contracts, and other agreements between you or your entity and us that may contain
• Financial information, such as payment terms, bank details and credit ratings (in the case of a sole proprietorship)
The purposes of the processing activity
To enter into or fulfil contracts between us or the entity you represent.
Legal basis
Contractual obligations: We need to process your personal data in order to enter into a contract and to fulfil our obligations in relation to the contract (Article 6(1)(b) of the General Data Protection Regulation).
Retention period
We process and store your personal data until the contract terminates and up to ten (10) years thereafter or for a period of time to fulfil legal obligations, whichever is longer.
Support
Types of personal data
• Contact details, i.e., name, e-mail address, phone number and address
• Organisational information, such as the name and address of the company, job title, employment area, primarily place and country of work
• Contractual information, such as orders, invoices, contracts, and other agreements between you or your entity and us that may contain
• Information which you provide to us when communicating with you
The purposes of the processing activity
To provide customer support in relation to our products and services.
Legal basis
Legitimate interest: Our legitimate interest in providing efficient customer support, maintaining customer relationships (Article 6(1)(f) of the General Data Protection Regulation).
Retention period
Other support matters are stored for two (2) years from the time we last were in contact because of the support matter.
For the functionality of and to improve our website and the Encube platform
Types of personal data
• IP-address
• Information about your use of our website and the Encube platform
• Other technical information which is generated upon visiting our website and the Encube platform, such as what type of device is used and web browser
The purposes of the processing activity
To maintain, facilitate and improve the functions and user experience of our website and Encube platform, create statistics, as well as support our work on detecting and counteracting flaws, breaches, and incidents. We further process the personal data for statistics and analysis purposes.
Legal basis
Legitimate interest: Our legitimate interest to gather information to maintain, facilitate and improve the functionality, user experience, and security on our website and Encube platform (Article 6(1)(f) of the General Data Protection Regulation).
Retention period
We process and keep information on how our users interact with our website and Encube platform for a period of maximum six (6) months. Cookies are deleted in accordance with our cookie policy. In most cases, the collected personal data will be aggregated and anonymised at an earlier stage, in connection to us creating statistics.
Cookies for marketing
Types of personal data
• IP address
• Browsing history
• Information about your use of our website and the Encube platform, including click-behaviour
• Other technical information which is generated upon visiting our website and the Encube platform, such as what type of device is used and web browser
The purposes of the processing activity
To market our products and services.
Legal basis
Consent: We use cookies to collect the above-mentioned personal data. When you visit our website, we ask for your informed consent to place cookies that are not functional cookies (Article 6(1)(a) of the General Data Protection Regulation). You have the right to withdraw your consent at any time. You can read more about how you change your cookie settings in our cookie banner and cookie policy.
Retention period
Cookies are deleted in accordance with our cookie information. In most cases, the collected personal data will be aggregated and anonymised at an earlier stage, in connection to us creating statistics.
Newsletter(s) and marketing material
Types of personal data
• Contact details, i.e., name, e-mail address, phone number and address
• Click-behaviour in relation to published material
• Interests (that you have provided us with)
The purposes of the processing activity
To provide you with our newsletters and marketing materials and for us to conduct analysis and statistics.
Legal basis
Consent: We will only use your personal data for sending out newsletters and marketing materials, if you have given your prior and explicit consent to this (Article 6(1)(a) of the General Data Protection Regulation).
Legitimate interests: If you however act as sole proprietorship owners or a representative of contacts of suppliers, customers and other business partners working with us, our legal basis for sending out newsletters and marketing materials is based on our legitimate interest in marketing our products and services (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: The processing of your personal data will, in connection with analysis and statistics, be based on our legitimate interests in being able to improve and develop our service (Article 6(1)(f) of the General Data Protection Regulation).
Retention period
We keep your personal data for as long as your consent to receive newsletters and marketing materials is active. You can always withdraw your consent or chose not to receive newsletters and marketing materials by clicking on the unsubscribe link at the bottom of each e-mail or by contacting us. However, withdrawing your consent does not affect the legality of the processing that preceded the withdrawal. In most cases, the collected personal data will be aggregated and anonymised at an earlier stage, in connection to us creating statistics.
Recruitment
Types of personal data
- Contact details, i.e., name, e-mail address, phone number and address
- Personal data contained in CV, personal letter, letter of recommendations, diplomas, and information provided by referees
- Information about you, including information regarding your previous jobs, activities, competencies, performance etc.
- Results of personality tests and other tests as part of the recruitment process
- Evidence of right to work and/or immigration status (to the extent required by applicable laws)
The purposes of the processing activity
Recruitment and employment process.
Legal basis
Request to enter into an employment contract with us: We may process your personal data on the basis of your request to enter into an employment contract with us (Article 6(1)(b) of the General Data Protection Regulation).
Legitimate interest: Our legitimate interest to make it possible for us to evaluate your qualifications and personal qualities in connection with decisions on recruitment (Article 6(1)(f) of the General Data Protection Regulation).
Legal obligation: We only process your evidence of right to work and/or immigration status to the extent required by applicable laws (Article 6(1)(c) of the General Data Protection Regulation).
Retention period
We store the information from the recruitment process for two (2) years after the application process is over unless otherwise required by applicable laws.
Security measures
Encube has taken technical and organisational measures to ensure that your personal data is processed securely and protected from loss, abuse and unauthorised access.
Encube has implemented organisational security measures in work methods and routines within the organisation, including:
- Internal governance documents (policies/instructions)
- Login and password management
- Information security policy
Encube has implemented technical security measures through technical solutions, including:
- Encryption
- Access control levels
- Access log
- Secure network
- VPN
- Firewall
- Back-up
- Regular security inspection
- Two-step verification
Sharing your personal data
To achieve the above purposes, we may give third parties access to your personal data based on a contractual relationship with us, this could be IT suppliers and business partners. Such suppliers and business partners will only process personal data in accordance with our instructions according to the signed data processing agreements. We may also share your personal data with government agencies and law enforcement authorities to fulfil our legal obligations or on the basis that we have a legitimate interest. In the context of our development, the corporate structure may change, e.g., by the total or partial sale of the company. In the case of a partial transfer of assets containing personal data, the processing basis for the related transfer of personal data is, as a rule, based on our legitimate interest in transferring parts of our assets and making commercial/structural changes.
We strive to process your personal data within the EU or EEA. However, we will transfer your personal data to service providers who, either themselves or by their sub-contractors, are located or have business activities in a country outside the EU or EEA. In such cases, we are responsible for ensuring that the transfer is made in accordance with applicable data protection legislation before it occurs, e.g. by ensuring that the country in which the recipient is located ensures an adequate level of data protection according to the European Commission, or by ensuring appropriate safeguards based on the use of standard contractual clauses that the European Commission has adopted and other appropriate measures to safeguard your rights and freedoms.
You may access a list of the countries that the European Commission has decided to provide an adequate level of data protection here.
You may access the European Commission’s standard contractual clauses here.
Please contact us for more information concerning which countries outside the EU/EEA to which we currently transfer personal data.
Additional retention period
Additionally, we may use personal data to handle any complaints or to defend and/or establish legal claims. We will generally process such personal data for ten (10) years from creation or for the time necessary to fulfil the purpose in the relevant case. This processing of your personal data is based on our legitimate interest of establishing and/or defending legal claims.
Your rights
You have rights in relation to us and our processing of your personal data. Below, you will find information about your rights and how you can exercise them. Please note that your rights apply to the extent that follows from applicable data protection legislation and that there may be exceptions to the rights.
We also ask you to note that we may need more information from you to confirm your identity before proceeding with your request to exercise your rights.
To exercise your rights or request information about them, you are welcome to contact us.
Right of access - You have the right to obtain a confirmation as to whether we process your personal data. If that is the case, you also have the right to receive copies of the personal data concerning you that we process as well as additional information about the processing, such as for what purposes the processing occurs, relevant categories of personal data and the recipients of such personal data.
Right to rectification - You have the right to, without undue delay, have incorrect personal data about you rectified. You may also have the right to have incomplete personal data completed.
Right to erasure - You have the right to request that we erase your personal data without undue delay in the following circumstances:
- The personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- Our processing is based on your consent, and you withdraw your consent to the relevant processing;
- You object to the processing that we carry out based on a legitimate interest, and your objection overrides our or another party’s legitimate interest of the processing;
- The processed personal data is unlawfully processed;
- The processed personal data must be erased for our compliance with one or more legal obligations.
Right to restriction - You have the right to request that we restrict the processing of your personal data in the following circumstances:
- You contest the accuracy of the personal data during a period enabling us to verify the accuracy of such data;
- The processing is unlawful, and you oppose erasure of the personal data and request restriction instead;
- The personal data is no longer needed for the purposes of the processing, but is necessary for you for the establishment, exercise or defence of legal claims;
- You have objected to the processing of the personal data which we carry out based on a legitimate interest, pending the verification whether your objection overrides our or another party’s legitimate interest to continue with the processing.
Right to object - You have a right to object to our processing of your personal data when it is based on our or another party’s legitimate interest. If you object, we must demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms in order to be allowed to continue with our processing.
Right to data portability - If our processing of your personal data is based on the performance of a contract with you or your consent, you have the right to receive the personal data you have provided us relating to you in an electronic format. You also have the right to have the personal data transferred from us directly to another data controller, where technically feasible. We ask you to observe that this right to so called data portability does not cover personal data which we process manually.
Right to withdraw consent - If our processing of your personal data is based on your consent, you always have the right to withdraw your consent at any time. A withdrawal of your consent does not affect the lawfulness of the processing that took place based on the consent before your withdrawal.
Complaints with the supervisory authority
In Sweden, the Swedish Authority for Privacy Protection (Sw. Integritetsskyddsmyndigheten) is the authority responsible for supervising the application of current data protection legislation. If you believe that we process your personal data in a wrongful manner, we encourage you to contact us so that we can review your concerns. However, you may file a complaint with the Swedish Authority for Privacy Protection at any time.
Contact details
Please contact us if you have questions about your rights or if you have any other questions about how we process your personal data:
contact@getencube.com