PRIVACY POLICY

 

1                 Background

You should always feel secure when you provide personal data to Cibes Lift Group AB and its subsidiaries (”Cibes” or the ”Company”). This privacy policy describes how Cibes secure that your personal data is processed in accordance with applicable legislation. Your right to privacy and that you continue to trust us is of great importance to us.

In this privacy policy we describe how Cibes processes and uses your personal data when you are a customer, applying for a job position, visiting our website (www.cibeslift.com) or using our application, or when you are representing a company which is a customer, potential customer, distributor or partner to Cibes. This privacy policy also describes your rights and how you may exercise such rights.

If you have questions regarding Cibes’ privacy policy, please do not hesitate to contact the Company by sending an e-mail to gdpr@cibesliftgroup.com.

2                 controller

Cibes Lift Group AB, Swedish registration number 556343-1484, Utmarksvägen 13, SE-802 91 Gävle, Sweden, is the controller regarding your personal data and is therefore responsible for your personal data being processed in a correct and safe manner in accordance with applicable law. You can find the Company contact information in the section ”Contact” below.

Cibes has appointed a group of people as responsible for data protection (“Data protection group”), with the responsibility to monitor Cibes’ processing of personal data and assure that the processing is in accordance with applicable data protection legislation. You can contact the Data protection group via the mail-address gdpr@cibesliftgroup.com.

3                 what personal data does Cibes process?

Personal data means all types of information which can, directly or indirectly, be used to identify a living physical person. Your personal data is information about you. Examples of personal data are names, contact data, pictures of you and IP-addresses.

Processing means all types of actions made with personal data, such as collecting, storing, using, processing and transferring personal data.

 

Customers (private customers and sole proprietorships):
Cibes collects and stores the following information about you as a customer:

·      Personal and contact information, such as name, personal identification number or company registration number, postal address, phone number, email address, title etc.

·      Information that you as a customer provides Cibes with via email, through your activity on our social media, or through other communication channels.

·      Information from customer surveys and customer evaluations.

·      Payment and purchase history.

·      Payment information, such as bank information, account number, IBAN, SWIFT etc.

·      Login and other access rights, such as user name and password to Cibes’ order system.

·      Information from warranty matter.

·      Information that you as a customer provide Cibes during a service or customer support matter.

·      In applicable cases, in connection with company events and meetings; food preferences, allergies and/or any disabilities.

·      In applicable cases, data from surveillance cameras installed in connection with and within Cibes’ premises.

 

Company representatives for i.e. customers and partners:

Cibes collects and stores the following information about you as a representative for a company/organisation:

·         Personal and contact information, such as name, postal address, phone number, email address, title, position, employer etc.

·         Information that you as a customer provides Cibes with via email, through your activity on our social media, or through other communication channels.

·         Login and other access rights, such as user name and password to Cibes’ order system.

·         In applicable cases, birthdate, nationality, picture and ID.

·         In applicable cases, in connection with company events and meetings; food preferences, allergies and/or any disabilities.

·         In applicable cases, data from surveillance cameras installed in connection with and within Cibes’ premises.

Your personal data is usually collected from the company/organisation that you represent, but in some cases directly from you, e.g. through e-mail correspondence or other communication, in connection with you attending our company events or meetings and when you are active on our social media. Cibes may also collect personal data of you from another Cibes group company or Cibes’ other partners. Moreover, and if necessary, the Company uses external information services in order to collect supplementary information such as title and contact information.

 

Potential customers and company representatives for potential customers:
Cibes may collect and store the following information about you as a potential customer, or as a representative for a company/organisation that is a potential customer:

·         Personal and contact information, such as name, postal address, phone number, email address, title, position, employer etc.

 

Visitors of Cibes’ website and users of Cibes’ application:
Cibes collects the following information about you that visit our website and uses our application:

·      Technical information such IP-address, MAC-address, URL, unique device ID, network and computer performance, browser type, language- and identification settings, general geographical location, operating system and other data from cookies.

 

Recruitment (job applicants):
Cibes collects the following information about you that applies for positions within the Company:

·         Personal and contact information, such as name, postal address, email address, phone number, title, position, employer, etc.

·         Personal data from CV and cover letter.

·         In applicable cases, a profile picture.

·         Other personal data you choose to provide us with during the recruitment process.

·         In applicable cases, for instance when visiting Cibes for an interview, data from surveillance cameras installed in connection with and within Cibes’ premises.

Your personal data is collected directly from you or from the recruitment agency that you apply through.

4                 Cibes’ processing of your personal data

The purposes for which we process your personal data, the legal basis we have for each processing and for how long we store your personal data is presented in the tables below.

Cibes will not store your personal data for a longer period than necessary in order to fulfil the purposes for which the personal data was collected, or for as long as Cibes is obligated to store your personal data in accordance with law, or to safeguard Cibes’ legal interests, e.g. if there is an ongoing legal process. Your personal data will thereafter be deleted. For more details, please see the tables below, or contact Cibes. Contact information is found in the section ”Contact” below.

 

 

Customers (private customers and sole proprietorships):

 

Purpose

 

Legal basis

 

Storage period

In order to be able to administrate your customer relationship with Cibes and to keep contact for delivery of product and services, performing of services of existing products from Cibes.

Personal identification number is stored only for proper identification.

In order to fulfil the agreement with the customer. The data is stored for as long as we have a business relationship and any obligations under the agreement is outstanding.
In order to comply with legal obligations, such as safety requirements and accounting requirements. The processing is necessary for the Company’s compliance with legal obligations. Some personal data will, for the purpose of complying with relevant accounting law, be stored for seven years, counted from the end of the calendar year when the financial year, to which the data belonged, ended.

The data is stored only for as long as Cibes is obligated by law to store your personal data.

In order to enable marketing and communication of Cibes’ progress in developing products, such as through sending out newsletters and other marketing material, invitations to events and meetings etc. The processing is necessary for the purposes of Cibes’ legitimate interest of marketing its business and its products to its customers (legitimate interest). The data is stored for as long as we have a business relationship or until you opt out.
Enable customer surveys and other market surveys regarding Cibes’ products and the customer’s purchase experience. The processing is necessary for the purposes of Cibes’ legitimate interest to evaluate and develop its products, marketing and trademark. (legitimate interest). The data is stored for as long as we have a business relationship.
To enable customers to make their payments and to analyse purchase history in order to offer customers the correct products and marketing, and in order to follow up Cibes’ salespersons’ performance, sales and need of development of their work skills.

 

In order to fulfil the agreement to the customer.

The processing is necessary for the purposes of Cibes’ interest of marketing its business and its products to the customers, regarding customers purchase history, and to follow up Cibes’ salespersons’ performance and offer to develop their work skills (legitimate interest).

The data is stored for as long as we have a business relationship and any obligations under the agreement is outstanding.
To enable customer to make their payments after purchasing products and services from Cibes. In order to fulfil the agreement with the customer. The data is stored for as long as we have a business relationship and any obligations under the agreement is outstanding.
In order to track the customer’s order in the order system, and to communicate with the customer regarding delivery of products etc. In order to fulfil the agreement with the customer. The data is stored for as long as we have a business relationship and any obligations under the agreement is outstanding.
In order to handle customers’ complaints and warranty matters.

In order to offer customers relevant service and support.

In order to fulfil the agreement with the customer.

The processing is necessary for the purposes of Cibes’ legitimate interest of offering their customers correct and requested service and support (legitimate interest).

The data is stored for as long as we have a business relationship and any obligations under the agreement is outstanding.

The data is stored only for as long as Cibes is obligated to store your personal data in accordance with law, or to safeguard Cibes’ legal interests, e.g. if there is an ongoing legal process.

To avoid and investigate break ins in Cibes’ premises. The processing is necessary for Cibes’ legitimate interest to enable proper investigation of criminal activities in the event of break ins or other situations in the Company’s premises and to ensure the physical security in its premises as well as a safe and secure environment for its employees and visitors (legitimate interest) Images and video from surveillance cameras will be stored for up to one month, and will then be deleted.

 

 

Company representatives for customers and partners:

 

Purpose

 

Legal basis

 

Storage period

In order to administrate the customer relationship and maintain contact with a representative for the company regarding delivery of Cibes’ products, performance of services etc. The processing is necessary for the performance of the agreement with the customer or partner, that you represent.

The processing is necessary for the purposes of Cibes’ legitimate interest in the performance of the agreement with the customer or partner, and to administrate the relationship between you, or the company/organisation you represent and Cibes (legitimate interest).

As long as we have a business relationship with you or the company that you represent.

Contact information to company representatives is stored during the period of time that the storage of data is necessary to in order to maintain the relationship with the company/organisation. The data will be deleted after Cibes has been informed that the personal data is no longer necessary or relevant for the purpose, or when the representatives so demands.

In order to comply with legal obligations, such as safety requirements and accounting requirements. The processing is necessary for the Company’s compliance with legal obligations. Some personal data will, in purpose of complying with relevant accounting law, be stored for seven years, counted from the end of the calendar year when the financial year, to which the data belonged, terminated.

The data is only stored for as long as Cibes is obligated to store your personal data in accordance with law.

Enable marketing and communication regarding Cibes’ trademark and products, to send marketing and invitations to events and meetings etc. The processing is necessary for the purposes of Cibes’ legitimate interest of marketing its business and its products to the company/organisation that you represent (legitimate interest). The data is stored for as long as we have a business relationship or until you choose to opt out.

 

In order to track the order in the order system, and to to communicate with customer regarding delivery of products etc. The processing is necessary for the performance of the agreement with the customer or partner that you represent. As long as we have a business relationship with you or the company you represent.

 

 

Potential customers, and company representatives for potential customers:

 

Purpose

 

Legal basis

 

Storage period

To enable marketing and communication regarding Cibes’ trademark and products, and to send marketing material and invitations to events and meetings etc. The processing is necessary for the purposes of Cibes’ legitimate interest of marketing its business and its products to you as a potential customer or to the company/organisation that you represent (legitimate interest). The data is stored for up to a month. The data may be stored for a longer period if a customer relationship arises.

 

 

Website and application visitors:

 

Purpose

 

Legal basis

 

 

Storage period

To ensure the functionality of the website and application.

In order to develop Cibes’ website and application and to make it more user friendly based on the use of our website (www.cibeslift.com) and application.

 

The processing is necessary for the purposes of the Company’s legitimate interest of improving, streamlining, simplifying and developing its website and application, and for the purpose of attracting more customers and partners, as well as publishing information regarding progress of Cibes’ business and product development (legitimate interest). Your IP-address is stored for as long as you have our application installed.

Session cookies are stored for as long as the browser is open. Other cookies are stored a maximum of 24 months.

 

 

Recruitment (job applicants):

 

Purpose

 

Legal basis

 

Storage period

In order to, in connection with recruitment, be able to determine who is best suited for a certain job position, and to make sure that the person in question has the right competence. The processing is necessary for the purposes of the Company’s legitimate interest of employing the right personnel and to ensure that competent persons work for the Company (legitimate interest).

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Cibes will store your personal data concerning the application and recruitment process during the year of the latest activity.

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5                 HOW Does Cibes PROTECT YOUR DATA?

We use a range of technical and organizational measures to protect your data from unauthorized access, use, loss, change or deletion in accordance with applicable data protection legislation. Such actions include, but are not limited to, physical controls, encryption, access restrictions, security policies, etc.

6                 transfer of personal data to third partIES and third countrIES

Cibes will not transfer personal data to any third party, unless the Company is required to do so by means of a legal obligation, or when necessary for Cibes to fulfil its commitment to you and its customers and partners. Your personal data will not be sold to any third party for marketing purposes. The table below sets out situations when your personal data may be transferred to a third party.

Third party Reason for transferring personal data to a third party
Other companies within the company group of Cibes Key functions such as but not limited to, IT, visa management and marketing are jointly managed within the Cibes group of companies, which means that personal data may be transferred to other companies within the group.
Suppliers of cloud services Cibes stores some information in cloud services, consequently some of your personal data can be transferred to suppliers of such services.
Suppliers, distributors, installation companies and other partners Cibes may transfer your personal information to suppliers, distributors, installation companies and other business partners of Cibes. Such transfer will occur only if the suppliers, resellers, installation companies or partners need your personal data in order to fulfil their services for Cibes.
Authorities Personal data could be transferred to authorities (also to foreign authorities) when it is needed in order to comply with legal obligations.
Company transfer Should Cibes intend to transfer all or part of Cibes’ business, personal data may be disclosed to a potential buyer.

Cibes strive to process your personal data within the EU/EEA. Cibes will not transfer your personal data to any country outside the EU/EEA save as stated below. If personal data is transferred to a country outside the EU/EEA, Cibes will take necessary actions to ensure that the personal data continues to be protected and will also take the necessary actions to enable a legal transfer of such personal data to a country outside the EU/EEA.

Cibes uses suppliers of software for product development and internal organisation, suppliers of marketing services, and suppliers of cloud services, such as Google and Amazon, which have servers located in USA. Due to Cibes’ use of these suppliers’ services and software, your personal data may be transferred to USA. The personal data that Cibes collects when you use Cibes’ website or application may be transferred to Google in USA, through Google Analytics and Google AdWords. Cibes has secured that your rights are protected in case of transferring of your personal data to USA through the above-mentioned suppliers’ adherence to the EU-US Privacy Shield. More information is available at www.privacyshield.gov.

7                 Social MEdia

Regarding personal data that is processed on social media, such as Facebook, Instagram and LinkedIn, we refer to the privacy policies of each social media for information on how such companies processes personal data. Cibes purpose of its processing of personal data on social media is to enable representatives for customers, potential customers and partners to interact and contact Cibes through such social media. This is aimed to contribute to a good relationship between Cibes and its customers and partners as well as to make Cibes’ customer service easily accessible through several channels. The processing is necessary for the purposes of Cibes’ legitimate interest of marketing its trademark and its products to customers, potential customers, and to partners (legitimate interest).

8                 your rights

Provided that Cibes is the data controller, you have the right to, at any time, without charge, receive an excerpt of Cibes’ processing of your personal data, the purposes for such processing and information on the sources of the personal data as well as information on the recipients, if any, or expected recipients of the personal data.

You also have the right to in said excerpt be informed of the anticipated period of time during which the data will be kept or the criteria to determine such period of time. The request to be provided with such excerpt shall be in writing and be sent to Cibes using the contact details set out below under the heading “Contact”.

You are entitled to data portability, i.e. a right to under certain circumstances receive your personal data in a structured, accessible and machine-readable format, which can be transferred to another user or data processor.

Cibes will, upon your request as well as on its own initiative, correct, anonymize, delete or supplement information that is found to be incorrect, incomplete or misleading. In certain situations, Cibes has an obligation to process your personal data even if you have requested that the data shall be deleted.

In certain circumstances, you have the right to request restriction of processing of your personal data (e.g. if you contest the accuracy of the personal data or the lawfulness of the processing) as well as a right to object to the processing under the circumstances set out in applicable data protection legislation.

Should you want to exercise any of the rights described above or if you have any questions in respect of personal data processed by Cibes or about this privacy policy, please do not hesitate to contact Cibes (contact details are set out under the heading “Contact” below).

Should you be dissatisfied with our processing of your personal data, please let us know, and we will do our best to respond to your complaints. Your integrity is very important to Cibes and Cibes always strives to protecting your personal data in a relevant and secure manner. However, should Cibes in your opinion fail to meet this ambition, you also have a right to submit a complaint with the Swedish Data Protection Authority (Sw. Datainspektionen, which will be changing name to Dataskyddsmyndigheten during 2018).

9                 Cookies

Cibes uses cookies and similar techniques to provide certain functions at the website www.cibeslift.com and to improve our website and to deliver a better and more personal service. The information is stored as a file containing encrypted login-data. The information is used for automatic log in and to store settings that you have changed on the website.

10              links to other websites

On Cibes’ website, www.cibeslift.com, there may be links to external websites that Cibes has no control over. These websites are not covered by this privacy policy. Cibes is not responsible for the contents of the websites linked from www.cibeslift.com.

11              contact

If you have questions regarding how Cibes processes your personal data, or if you want to exercise any of your rights according to this privacy policy, please contact Cibes on gdpr@cibesliftgroup.com or by letter to Cibes Lift Group AB, Utmarksvägen 13, SE-802 91 Gävle, Sweden.

12              changes to this privacy policy

Cibes reserves the right to make changes to this privacy policy at any time. When changing this privacy policy, Cibes will publish the revised privacy policy at www.cibeslift.com with information on when the changes will enter into force. Cibes will also, in the best way possible, inform its customers and partners of changed made to this privacy policy.