Personal data processing
Wendevel AB takes privacy seriously. Therefore, all processing of personal data takes place in accordance with the applicable data protection legislation.
Types of personal data processed
Engagements
During an engagement, we will process the personal data provided to us in conjunction with the engagement. Personal data may be collected directly from the individual concerned. In addition, we may receive information about one individual from another individual, such as a client. Furthermore, we may gather additional information containing personal data from other sources such as generally available search engines.
The personal data we process in may contain contact details such as name, title, employer, address, phone number and email, identification details such as passport details and ID number and invoicing information such as account number and tax details. We also process personal data about you or someone else that you choose to share in your correspondence with us.
Personal data in certain engagements
In certain engagements such as legal proceedings, further personal data may also be needed. Such data may comprise information regarding events and actions undertaken by a certain individual, or other information relevant to the engagement. In conjunction with legal proceedings, we may also process personal data in the form of sound or image recordings.
Administrative processes and suppliers
The same type of personal data, obtained through the same means as under “engagements” may be processed in relation to suppliers and other external parties.
The purpose of processing personal data
Engagements
We process personal data in conjunction with engagements in order to meet our commitments and safeguard the interests of our clients.
Administrative processes and suppliers
Personal data may be processed to perform administration required for the performance of the engagements and to meet legal requirements such as money laundering checks. Further, personal data may be processed for the purpose of managing and administering relationships with suppliers and other external parties as well as their representatives.
Legal basis for processing of personal data
Engagements
As for clients that are legal entities, legal basis for the processing of data regarding such clients’ representatives, business partners and consultants, witnesses, counterparties etc. is generally based on the legitimate interest in performing our engagements as well conducting our business.
The legal basis for processing personal data on clients who are private individuals is generally that it is a requirement for us to perform our engagement with the client.
In certain cases, we also have a legal obligation to process your personal data, e.g. to meet our obligations relating to accounting.
Administrative processes and suppliers
Processing of personal data relating to suppliers and external parties as well as the representatives of such parties is based on our legitimate interest in maintaining and administering our relationship as well as fulfilling our contractual obligations with such parties.
In certain cases, we also have a legal obligation to process your personal data, e.g. to meet our obligations relating to accounting.
Access to personal data
We have technical and organizational measures in place to ensure protection of the personal data we process. That is, protect such data from loss, unauthorized access etc. Only those who need to process the data for the purposes mentioned in the previous are given access to the personal data.
Personal data will never be disclosed to anyone outside Wendevel AB unless 1) necessary for us to comply with legal obligations, decision from a court of law or a public authority, 2) in conformity with an agreement with the person whose personal data we process, 3) required to promote and safeguard the rights and interests of our clients, 4) the person who the data concerns asks us to disclose the data or provides their specific consent to it, or 5) the disclosure is otherwise permitted under applicable law.
Data retention
In general, unless personal data must be saved for a longer period under applicable law or for other mandatory reasons such as obligations to maintain bookkeeping, personal data is stored no longer than needed for the purpose for which the collection of personal data was undertaken.
Engagements
Personal data acquired before and during the performance of an engagement are stored during the performance of the engagement and maintained for an additional period required to safeguard the rights and interests of the client in favor of which the engagement was performed. As a starting point, such data is kept for a minimum term of 10 years.
Administrative processes and suppliers
Personal data processed due to relationships with suppliers and other external parties is saved for the period required for us to administer and fulfill our contractual obligations and safeguard our rights and interests, or for as long as is permitted or required under applicable law.
The rights of a data subject
Wendevel AB (Reg. No. 556345-3603) is the controller for the processing of personal data described above and hence responsible for ensuring that the personal data outlined in the foregoing is processed correctly and in accordance with current data protection legislation.
Any data subject does have the right, in accordance with the applicable data protection legislation, 1) to know what personal data we process about them, 2) to request rectification of inaccurate or incomplete personal data about them, 3) to request that their personal data is erased or that the processing thereof is restricted, 4) to object specific processing of their personal data, and 5) in some circumstances, to obtain the personal data about them in machine-readable form, and transmit the data to another controller.
Should you have any questions or complaints regarding how we process personal data or which to exercise the rights described above, you are welcome to contact us by email at WN@wendevel.se. Caption any such correspondence “Data-protection inquiry”. Anyone with objections regarding how we process personal data also has the right to contact or file a complaint with the Swedish Authority for Privacy Protection, which is the supervisory authority for our processing of personal data.
