Privacy Policy

CWT Worktools AB (556774-3140) and other companies that are owned by
ALFA GROUP HOLDING AB (556502-5185)

At CWT Worktools AB we care about you and your right to privacy. We want you to feel secure when you provide us with your personal information. That is why we process your personal data in a transparent manner, and always with your privacy in focus.

In this Privacy Policy, which applies to everyone who in some way uses CWT Worktools AB’s services or products and/or in some other way has contact with us, we set out, among other things, how and why we process your personal data, as well as the rights you have in accordance with applicable personal data legislation.

You are always welcome to contact us if you have any questions regarding this Privacy Policy or other data protection issues. You will find our contact details at the end of this policy.

  1. What is personal data?

Personal data is any information that can be related, directly or indirectly, to a living natural person. Examples of personal data can include everything from personal ID numbers to email addresses, while encrypted data can also be personal data if it can be connected to natural persons.

  1. What do we mean by “processing" of personal data?

The term “processing" is wide-reaching and covers most operations that can be performed on personal data. Everything from collection and storage to adaptation or alteration, use or erasure represents “processing".

  1. When do we collect personal data about you?
    • Data that you provide to us

We collect and process personal data that you provide to us, for example when you visit our website, purchase a certain product or service, subscribe to our newsletter, contact us or use our digital channels.

    • Data that is collected when you use our services

When you use our services, we register information about your use of the services. This information covers the services you use, the webpages you visit, and your behaviour when visiting the website. This information could include details about your operating system, browser version, IP address, cookies and unique identification files.

    • Data from other sources

We collect personal data, for example email addresses, that you have provided to other companies within the group with whom you have a customer relationship. We do this to ensure that we always have up-to-date information about you, and to enable us to provide you with offers regarding our own goods and services as well as the goods and services available from other companies within the group as well as selected business partners. Examples of the types of data we collect include identity and contact details such as names, email addresses and phone numbers.

We also collect your data if your employer has entered into an agreement with us and, in doing so, has provided us with your personal data, for example in order for communication related to the agreement to be able to take place with you, or in order for the service/product to be able to be provided/delivered to you at the request of your employer.

In certain cases we may obtain information from other sources, for example business partners and other suppliers. We may also obtain and update your address details via a third party’s address updating services.

  1. Why do we process your personal data?

We need to process your personal data in order to be able to provide/deliver services and products to you.

We primarily process your data in order to:

    • Administer and provide/deliver our services and products
    • Manage customer service issues and other enquiries
    • Provide information and market products and services that may be of interest to you
    • Improve our services and products, for example by examining and evaluating customer satisfaction or the market.

Please see section 7 for more information.

  1. What are the legal grounds for our processing of your personal data?

In order to be able to process personal data, legal grounds must exist for such processing. Alfa Neon processes personal data on the following grounds;

    • When the personal data processing is necessary in order for us to be able to fulfil an agreement that we have with you - for example, to provide/deliver or administer a product or service you have purchased
    • When the personal data processing is necessary in order to fulfil a legal obligation - for example, the obligation to maintain bookkeeping in accordance with applicable legislation
    • When we have a legitimate interest in the processing of your personal data - for example, in order to be able to respond to enquiries about products or services, or to communicate with you about products and services that are similar to those you have purchased in the past
    • When the personal data processing is permitted due to the fact that you have provided your consent to the processing.

Please see section 7 for more information.

  1. How long do we save your data?

Your personal data is only processed for as long as is necessary for the purpose or purposes for which it has been collected - for example, for as long as is necessary in order for us to be able to fulfil the obligations we have as a result of an agreement with you. We may save the data longer if required to do so by law or in order to protect our legal interests - for example, if a legal process is ongoing.

Your personal data is erased or anonymised when it is no longer relevant to the purpose or purposes for which it has been collected.

Please see section 7 for more information.

  1. Summary of our personal data processing

For what purposes do we process your personal data?

What are the legal grounds for the processing?

What categories of personal data are processed?

How long is your data saved?

Managing enquiries, e.g. questions about our services/products.

Legitimate interest.

• Identity details, e.g. name
• Contact details, e.g. address, phone number and email address
• Customer interactions, e.g. notes and mailings

As long as is necessary for the management of your enquiry.

Managing the customer relationship, e.g. registering your details in our customer register, sending out notifications, communicating with you about the customer relationship, etc.

Fulfilling the terms of agreements and, in certain cases, a legitimate interest if the agreement to provide you with a service has been entered into with a legal person.

• Identity details, e.g. name
• Title and right of attestation
• Contact details, e.g. address, phone number and email address
• Customer interactions, e.g. notes and mailings.
• Details about your purchases

As long as you have a customer relationship with us, and for two years thereafter.

Administering and delivering/providing our products and services.

Fulfilling the terms of agreements. When sensitive personal data is processed, this is done with the support of your express consent, and only when it is necessary to provide services you have requested.

• Identity details, e.g. name
• Title and right of attestation
• Contact details, e.g. address, phone number and email address
• Sensitive personal data, e.g. details of your food allergies if you will be taking part in events where food is served

As long as you have a customer relationship with us, and for two years thereafter.

Managing payments for services and products you have purchased.

Fulfilling the terms of agreements and to the extent required by a legal obligation, for example the obligation to maintain bookkeeping.

• Identity details, e.g. name
• Contact details, e.g. address, phone number and email address
• Invoicing details
• Payment information
• Customer participation, e.g. the service/product you have purchased

As long as we are obligated to store the data according to applicable law, and as long as it is necessary for the agreement.

Determining, invoking and bringing legal claims, or defending ourselves against such claims.

Legitimate interest.

• Identity details, e.g. name
• Contact details, e.g. address, phone number and email address
• Invoicing details

As long as is necessary in order to satisfy our interest in determining, invoking and bringing legal claims, e.g. in accordance with statutes of limitations.

Marketing our own goods and services and/or goods and services available from our business partners or other companies within the group, with the aim of providing relevant information and offers.

Legitimate interest.

• Identity details, e.g. name
• Contact details, e.g. address, phone number and email address
• Customer segment, e.g. information about the customer segment to which you belong
• Geographical information
• IP address, device information, log information

Two years after the date you were last active with us (“active” means, for example, the last time you purchased a product or service or contacted our customer service department).

Monitoring and evaluating use of our services and products.

Legitimate interest in improving your user experience.

• Identity details, e.g. name
• Title
• Contact details, e.g. address, phone number and email address
• Customer participation, e.g. the service/product you have purchased
• User-generated data, e.g. information about your interactions on our websites

As long as is necessary for monitoring and evaluation purposes.

Performing market/customer surveys in order to evaluate our products and services. The processing is necessary in order to satisfy our legitimate interest in obtaining information about your and other customers’ assessment/perception of e.g. our services and products.

Legitimate interest.

• Identity details, e.g. name
• Title
• Contact details, e.g. address, phone number and email address
• Survey responses
• Customer segment
• Geographical information

The data is saved as long as is necessary to send out the surveys. The responses to the surveys are anonymous, and consequently the data does not represent personal data.

Lifecycle management, e.g. troubleshooting, logging, developing, testing and improving our systems and services.

Legitimate interest.

• User-generated data, e.g. information about your interactions with our systems and services
• IP address, device information, log information

Only saved for as long as is necessary for the purpose.

Administering your account.

Fulfilling the terms of agreements with you or, alternatively, a legitimate interest if the agreement to provide you with an account has been entered into with a legal person.

• Name, address, phone number and email address
• IP address, device information, log information
• Information about how you use our website and about the offers you have been interested in, the newsletters you have interacted with, and the events you have registered for
• Information about your account

As long as you have an account with us, and for one year thereafter.

Carrying out and managing recruitment processes and incoming job applications.

Legitimate interest in managing the recruitment process.

• Name, address, phone number and email address
• Other information you provide in your application, for example title, work experience, etc.

As long as the recruitment process for the position you have applied for is ongoing, and for as long as is necessary in accordance with applicable statutes of limitations under the Swedish Discrimination Act. If we want to save your details for future recruitment processes, we will request your consent.

 

  1. Profiling

If you are our customer, we look at how you use our website, the products, services and offers you have been interested in, the newsletters you have interacted with and the events you have registered for, as well as information about your purchases and information about your account. We do this in order to be able to provide you with offers and invitations to events we believe may be of interest to you.

You may object at any time to the processing of personal data for the purpose of profiling. Such an objection should be forwarded via email to ekonomi@alfaneon.se.

  1. With whom might we share your data?

We share your personal data with our sister company CWT Worktools AB, corp. ID no. 556774-3140, for communication purposes and in order to be able to provide offers regarding our own goods and services as well as goods and services available from the sister company and selected business partners. In order to be able to send relevant offers to you, companies that receive your data may also process your data. The company that receives the data is the personal data controller in relation to the processing of your personal data that it carries out for these purposes.

We may share your personal data with companies and suppliers that provide services on our behalf, for example services for managing mailings, communicating offers, providing IT systems and carrying out customer analyses. These companies may only process your personal data in accordance with our instructions, and may not use your data for their own purposes.

We may also share the personal data that is necessary in order to determine, invoke and protect Alfa Neon’s legal interests, for example by sharing data with debt collection agencies.

We may also share your personal data when required to do so by law or statutory regulation, for example if we are required to provide information to the Swedish Tax Agency for bookkeeping purposes.

  1. Where is your data processed?

As a general rule, your personal data is processed within the EU. In the event that we use a service provider who transfers your personal data to countries outside the EU/EEA, we will take measures to protect your personal data in accordance with applicable legal requirements, for example by demanding guarantees that the supplier/service provider is protecting the data in accordance with applicable data protection regulations. Please feel free to contact us if you would like more information about the protective measures we have taken.

  1. Your rights

Rectification and access to your personal data

As a data subject your have the right, at any time, to request rectification of inaccurate data or to change the personal data you have provided.

You also have the right of access to the personal data we have registered about you. You can exercise this right by requesting a register excerpt.

Withdrawal of consent with future effect

If we are processing your personal data on the legal grounds of consent, you have the right, at any time, to withdraw your consent regarding future processing.

Objection to processing

You have the right to object to any processing we carry out on the basis of legitimate interest.

You may, at any time, decline to receive mailings for marketing and communication purposes. You can de-register from a mailing by clicking on the relevant link in the email you received or, alternatively, you can make such request by contacting us (please see our contact details below).

Erasure

Under certain circumstances you have the right to request erasure of your personal data. However, this right does not apply if, for example, we are obligated by law to retain the data.

Restriction of processing

You may also have the right to request that the processing of your personal data be restricted. However, if you request restriction of the processing of your data, this could mean that we are unable to fulfil any obligations we have to you during the time the processing is restricted.

 

Data portability

If you wish to move your data from us, you also have the right to receive a copy of the personal data concerning you in a structured, machine-readable format (right to data portability). This right only applies to data that you have shared with us.

  1. Cookies

We use cookies when you visit our websites. We will be updating our cookie policies in the near future.

  1. Complaints regarding our processing of your personal data

If you are dissatisfied with the way we process your personal data, we respectfully ask that you initially contact us via email at ekonomi@alfaneon.se.

If, after contact with us, you are still dissatisfied with the way we have responded to your complaint, you may forward your complaint to the relevant competent supervisory authority, which at present is the Swedish Data Protection Authority (Datainspektionen).

  1. Contact details to the personal data controller

Alfa Neon AB, corporate ID number 556352-4908, Årstidsvägen 8, 665 35 KIL, Sweden, Tel: +46 (0)554 333 30, is the personal data controller and is thus responsible for CWT Worktools AB’s processing of your personal data.

For questions regarding data protection, or if you wish to exercise your rights as described above, the easiest way to contact us is via email at:

ekonomi@alfaneon.se

  1. Changes to this Privacy Policy

We reserve the right to make changes to our Privacy Policy. The latest version of this Privacy Policy is always available on our website. When we make changes or updates that are of material importance to our processing of personal data (for example, changes to the specified purposes of the processing), such changes/updates will be communicated to you.

 

Last updated 23/05/2018