Privacy policy

Effective Date: 31-Aug-2023

Your privacy is important to us and we (“we”, “us”, “our”) are responsible for the personal data that you provide us with. This policy describes how we process, store and manage your personal data when you are a customer with us, when we contact you on behalf of our customers, or when you are looking to work with us.

It also describes your rights and how you can enforce them. It is important that you take note of and understand the privacy policy and feel safe in our processing of your personal data.

Responsible for processing personal data

Fortino Consulting AB (Company registration number: 559254-1006) is responsible for the processing of personal data described in this policy.

If you have any questions or want to invoke any of your rights, you can reach us at:

·       Email: [email protected]

Changes to our privacy policy

We may review and amend this privacy policy from time to time. All amendments enter into effect at the effective date indicated at the top of the page. We will inform interested parties about updates in the policy in the appropriate manner, such as via email or our website.

Legal basis for processing personal data

We process your personal data in order to provide services and/or products to you or our clients. When it comes to the processing of personal data in order to fulfill requirements such as the Accounting Act or the tax legislation, the legal basis for processing is a legal obligation.

For marketing and pre-employment purposes, the legal basis is our legitimate interest. This means that we consider that our interests in processing your personal data for these purposes listed above outweigh the privacy breach to which you are exposed as a result of the processing. This assessment has been made particularly taking into account that we believe that the processing of your personal data will be beneficial to you.

With regards to personal data in connection with job applications that have no connection with an active recruitment process or completed recruitment process, we will save your personal data for any future recruitment needs only if you have specifically agreed to this.

How we collect personal data

There are several ways that we may collect your personal data:

·       You directly provide us with personal data when you contact us

·       In connection with you becoming a customer with us, or when we work as data processors for our clients

·       Through cookies when you access our website

·       We collect personal data from another, so-called third party. A “third party” is defined as a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

Types of personal data we process

We may process the following categories of personal data:

·       Personal contact information such as name, address, e-mail, telephone number

·       Identity information such as social security number, usernames on social media

·       Financial information such as bank account numbers and other bank-related information

·       Professional information such as professional titles, employer name and address, employer website links, personal employment and education history and other relevant information submitted in CVs and cover letters.

Purposes for processing personal data

We process your personal data primarily to fulfill our obligations towards you and because we believe that processing the information is beneficial to you in your professional life. Our starting point is not to process more personal data than is needed for the purpose, and we always strive to use the least privacy-sensitive data.

Below is how we process your personal data.

Provide and fulfill agreements on services / goods

We process personal data in order to fulfill our agreements towards you. We process personal data for our administration and invoicing of the services / goods, for credit information purposes, to manage complaints and grievances, to assist you with questions about your service / product when you contact our customer service and otherwise to safeguard our rights and fulfill our obligations under our agreement with you. Personal data we manage in this processing is professional information, identity information and financial information.

Accounting

We process your personal data in order to be able to fulfill our statutory obligations, such as that of the Accounting Act’s requirements for archiving accounting material. Personal data we manage in this processing is contact information, identity information, financial information and professional information.

Marketing

We process personal data for market research, to enable marketing of goods / services to you and to enable the sending of emails and newsletters for the services / goods that may be of interest to you, to provide information about us or our clients, and/or to enable invitations to events or to contact our customers in the area of your interest. Personal data we manage in this processing is professional information.

Employment

We process your personal data in connection with you applying for vacancies, registering your interest in employment or when being employed with us. We process your personal data to assess your application and carry out the recruitment process. Personal data we manage in this processing is personal contact information, identity information, financial information and professional information.

How we share personal information

Our starting point is not to disclose the data subject’s personal data to third parties unless this is of legitimate interest to the third party, or if it is required by law. In cases where we disclose personal data to third parties, we strive to share the minimum amount of personal data that is required for fulfilling the legitimate interest of the third party. The third party is responsible for ensuring that the personal data is processed in a secure manner.

Clients

In order to fulfill the purposes of our processing of your personal data and to fulfill our contractual obligations, we may obtain personal data from our clients, or we may share personal data with our clients. We may only process personal data in accordance with the personal data processing agreement we have signed with our clients. Our clients may be obliged by law and agreement to protect your personal data.

Service providers

In order to fulfill the purposes of our processing of your personal data and to fulfill the obligations we have as a company, we share personal data with companies that provide services to us. These companies may only process personal data in accordance with the personal data processing agreement signed with us and in accordance with the instructions they receive in connection with this. They may not use your personal data for their own purposes and they are obliged by law and agreement to protect your personal data.

Authorities

We may provide necessary information to authorities if we are required by law to do so. This information may include personal data. In connection with a legal dispute, it may also be necessary to share certain personal data to other parties of the dispute.

How we store personal data

We securely store your data on servers within the European Union. We continuously develop routines and working methods to ensure that your data is managed securely. Only those people who actually need to process your personal data in order to fulfill their tasks, have access to your data.

We store your personal data for up to five (5) years after the personal information is received. Some personal data is stored for a longer period of time, for example to meet requirements from the Accounting Act and tax legislation. When the purposes of the processing are fulfilled and the storage period has expired, your personal data will be securely deleted or anonymized so that it can no longer be linked to you.

Your rights

We wish to make sure you are fully aware of all of your data protection rights. You are entitled to the following:

·       You have the right to request an extract from the register where you can see what personal data we have about you

·       You have the right to request correction if we have incorrect or incomplete personal information registered about you.

You have the right to have your personal data deleted under these conditions:

·       The information is no longer needed for the purpose for which it was collected

·       If the information is saved with your consent and you revoke the consent

·       If the processing is based on a balance of interests and there are no justified reasons that outweigh your interest

·       If the personal data has been processed illegally

·       If deletion is required to fulfill a legal obligation

·       If you object to processing for direct marketing purposes.

The right to have personal data deleted does not apply if we are obliged by law (e.g. the Accounting Act ) to store the data.

You have the right to data portability, i.e. the right to have your personal data transferred, provided that the legal basis is consent or agreement and what you can obtain is personal data concerning you, which you have provided yourself or which has been generated by your documents / activities.

You have the right to request that the processing of your personal data be restricted. However, if you request a limitation of your processing of personal data, it may mean that we cannot fulfill our possible obligations to you during the time the restriction is in force.

You have the right to object to a processing of personal data that has a balance of interests as a legal basis. In order for us to continue with data processing, we need to be able to show a compelling justified reason for the processing that outweigh your interests, rights or freedoms. Otherwise, we may only process the data to establish, exercise or defend legal claims.

You always have the right to object to your personal data being used for direct marketing. If an objection is made against direct marketing, the personal data may no longer be processed for such purposes.

If you are not satisfied with the response you have received from us, you have the right to submit a complaint to the supervisory authority.31