Privacy policy

Updated on April 28, 2021

We at Advisible AB (“Advisible”, “we” or “us”) are committed to protect the privacy of our customers (the “Customers”, “you”) and strive to provide a safe user experience of our services that are provided through advisible.com and other domains operated by Advisible (including any thereto related domains and subdomains), (the “Platform”). This privacy policy describes how your personal information is collected, used, shared, and secured, as well as your rights and how to enforce them.

Advisible is responsible for the processing of your personal data as described herein, as a data controller. Please do not hesitate to reach out to us if you have any questions or comments regarding your personal data or this privacy policy. You may contact us https://www.advisible.com/contact.

Advisible AB
Box 6075
102 32 Stockholm
Sweden

1 PERSONAL DATA THAT WE PROCESS, HOW WE DO IT AND OUR LEGAL GROUNDS FOR PROCESSING IT

We process your personal data for the following purposes and based on the following legal basis:

To communicate with you.Your contact details (name and email address) and information contained in your communication with us will be used to communicate with you. This processing can either be necessary for us under our contract with you (or, if applicable, your employer) or for our legitimate interest in effective communication with you.

To market our services.Your contact details will be used to send newsletters and other information about our services to you. This processing is based on our legitimate interest of being able to market our services, as you have shown an interest in our services. Feel free to follow the unsubscribe instructions contained in the email received from us or contact us directly if you no longer wish to receive such information.

To register your account.Your contact details (email address) will be used to register your account. This processing is necessary to enter into a contractual relationship with you (and, if applicable, your employer) regarding the Platform and to pursue our legitimate interests, such as our interest in simplifying the registration process for our Customers and administering our contractual relationship.

To provide our Platform to you.We will process your personal data to manage your account and to provide you with access to the Platform. For example, your personal data is used to verify your identity when signing in, and technical data to ensure that the Platform is presented in the best way for you. This is necessary for us to fulfil the agreement we have entered into regarding our provision of the Platform, i.e. the Terms of Service, and our legitimate interest of upholding our commitments towards you (and, if applicable, your employer) as set out in the Terms of Service.

To develop and improve our Platform.We use technical data, and other aggregated and non-personal information to develop and improve our Platform and services, including troubleshooting, data analysis, research, statistical purposes and testing (such as beta testing and evaluation of new features, in line with the fundamental nature of our platform). For example, we may collect and evaluate technical data about your use of our Platform for analytical purposes, to understand how the Platform is used in order to make it more intuitive. This processing is partly necessary to provide our service to you but mainly to pursue our legitimate interests of improving our Platform, services and their features.

To administer our agreements.Advisible will process your personal data when we enter into an agreement with you (or, if applicable, your employer) and during the term of such agreement. This is necessary for us to be able to enter into and fulfil agreements with you (or, if applicable your employer) and for our legitimate interest in being able to enter into and fulfil different types of agreements and to have a contact person in connection with such agreements.

For billing purposes.If you (or, if applicable, your employer) have ordered services from us, your personal data may be used for billing purposes. This includes your contact details (email address), choice of payment method and your name as the invoice reference of your employer. This processing is necessary and based on our legitimate interest of being able to bill.

To conduct customer surveys.Your contact information may be used to conduct customer surveys, for example regarding Advisible and our Platform. Participation is voluntary. This processing is necessary to pursue legitimate interests, such as our interest in developing and improving our business and services.

To fulfil our legal obligations.We are obligated to follow Swedish law. This means that your personal data will be processed to the extent necessary for us to fulfil our legal obligations, for example with regard to tax and bookkeeping rules.

To protect our legitimate business interests and legal rights. We will use information about you such as our previous communication, invoices and agreements, where we believe it is necessary to protect and enforce our legal rights, interests and the interests of others, for example in connection with legal claims, compliance, regulatory and audit functions.

In connection with a merger or acquisition.In connection with, due to strategical or business-oriented reasons, a potential merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company, the personal data we retain about you may be processed, shared or transferred, to parties involved in the process. This processing is based on our legitimate interest of being able to develop our business.

With your consent.Your personal data may be used for other purposes than stated above if you ask us to or you give us your consent. For example, if you are one of our customers, we might contact you asking for your consent to publish a customer review by you for the purpose of marketing our services.

2 HOW WE GATHER YOUR PERSONAL DATA

Information you give to us.Most of the information we process about you is received from you. You may directly or indirectly give us information about yourself in different ways, for example when you contact us for account creation services or otherwise in your communication with us. You can always choose not to provide us with certain information. However, some personal data is necessary in order for us to provide you with our services. Not providing such personal data may prevent us from performing the services you expect from us.

Information we collect about you.We may also, if applicable, responsibly and with your privacy in mind, obtain personal data about you from your employer, the website of your employer or other external public sources.

When you visit our website, we will collect technical data regarding your device from cookies and similar technologies. For more information about cookies, read our Cookie Policy.

3 HOW WE SHARE YOUR PERSONAL DATA

Sometimes, we need to share your personal information with other trusted individuals and companies. Your personal information may be shared with:

Our employees and consultants.Your personal data will, when appropriate, be shared with some of our employees and consultants. However, we will restrict access to those of our employees and consultants who need it to perform their jobs, for example to provide you with customer support. Our employees and consultants are of course subject to strict confidentiality.

Our service providers.We transfer to or share your personal data with our suppliers and subcontractors who help us provide our services to you or supply other services to us which require the processing of personal data, such as cloud-based CRM-systems and storage.

We provide personal data to third parties solely for the purpose of delivering, developing and marketing our services and to manage our daily operations. Our suppliers and subcontractors are not authorized by us to use or disclose your personal data except as necessary to perform services on our behalf or to comply with legal requirements.

Authorities and other public actors.Sometimes legal obligations may require us to share information about you, for example to respond to lawful requests from law enforcement agencies, regulatory agencies, and other public and government authorities. We may also disclose information if needed to detect and prevent fraud or in connection with a legal process, for example to enforce our agreements or to protect our rights, you or others.

4 WHERE WE PROCESS YOUR PERSONAL DATA

Advisible always strives to process and store your data within the EU/EEA. However, your data may in certain situations be transferred to, and stored at, a destination outside of the EU/EEA territory.

Please note that privacy laws in countries outside of the EU/EEA may not be the same as, and in some cases may be less protective than, privacy laws in your country. However, we always select our service providers carefully and take all the necessary steps to ensure that your personal data is processed with adequate safeguards in place in accordance with the General Data Protection Regulation 2016/679 (GDPR). These safeguards include signing the EU Commission Standard Contractual Clauses or ensuring that the service provider is established in a country which the EU Commission has deemed as having adequate privacy protection.

Please contact us for more information about the applicable safeguard in a specific case.

5 HOW LONG WE KEEP YOUR PERSONAL DATA

We keep your personal data only as long as necessary to fulfil the purposes for which it was collected. How long depends on the type of information and why we process it. We regularly review our need to keep data, taking applicable legislation into account.

Moreover, we store data to the extent we believe it is necessary to protect our legal rights, legitimate interests and the interests of others. Your data may also be stored for a longer period if required by applicable statutory retention periods.

6 YOUR RIGHTS

Right to object.You have right to object to processing based on legitimate interest. This means that we may no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests. You can always contact us for more information on the balance test that has been made.

You may also object to your personal data being processed for direct marketing purposes.

Right to access your data.You have the right to request a transcript of personal data processed by us, and additional information on how the data have been collected, processed, shared, etc. The first transcript may be requested free of charge, however if you make repeated and unreasonable requests, we may charge you with an administrative fee.

Right to transfer your data.You have the right to transfer your personal data to another controller under certain conditions.

Right to rectification.You have the right to correct inaccurate or incomplete information about yourself.

Right to erasure (right to be forgotten).You have the right to request that we delete personal data about you, for example if the data is no longer necessary in relation to the purposes for which it was collected or otherwise processed, or if there is no legal basis for processing the data.

Right to restriction.You are entitled to request that the processing of your personal data should be limited until inaccurate or incomplete information about you has been corrected, or until an objection from you have been handled.

Right to withdraw your consent.You may at any time withdraw any consent you have given us. However, please note that it will not affect any processing that has already taken place.

Right to complain.You have the right to lodge a complaint to the Supervisory Authority in the country you live or work in, if you believe that we have not complied with our obligations regarding your personal data.

In Sweden the Supervisory Authority is Datainspektionen, which also is our lead supervisory authority, and you can find more information at their website: https://www.datainspektionen.se/.

Please note that your request for restriction or erasure might affect our abilities to provide our services to you. Moreover, legal rights or obligations (such as confidentiality, accounting and tax legislation) may prevent us from disclosing or transfer all or part of your information, or from immediately deleting your information.

7 CHANGES IN THIS PRIVACY POLICY

This privacy policy may be updated periodically to reflect changes in our collection and use of your personal data. You will be informed of any significant changes (e.g. by email or on our website), but we also recommend that you review this privacy policy from time to time to ensure you are aware of any amendments.