Privacy and marketing policy

1. General

1.1 This policy regarding integrity and marketing (“Privacy Policy”) describes how Novator Solutions AB, org. No. 556722-5551, Hammarbacken 6A, SE-191 94 Sollentuna, Sweden (“Novator Solutions”, “we”) collects, uses, discloses and stores your personal data.

1.2 The Privacy Policy applies to Novator Solutions’ processing of personal data that is collected when using our website.

1.3 You should always feel safe when you submit your personal information to us. With this Privacy Policy, we want to show how we ensure that your personal data is processed in accordance with applicable personal data legislation (GDPR).

2. Personal data

2.1 Novator Solutions is responsible for personal data for our processing of your personal data and is responsible for such processing taking place in accordance with applicable legislation.

2.2 Data Protection Officer

The site is produced by Windh & Co. Miss Hosting is hosting the site on its servers in Sweden. The Data Protection Officer does not have the right to process personal data other than to secure the service to which the Data Protection Officer has used them.

3. When do we process your personal data?

3.1 In order for you to visit our website, we must collect and process personal

information about you.

3.2 Novator Solutions collects and processes personal information about you when you use the contact forms on our website.

4. What personal information do we process about you?

4.1 For those who visit our website

The personal data Novator Solutions collects and processes about you as visitors to our website are:

• IP address and information about your use of the Novator Solutions website.

4.2 For those who fill out contact forms

The personal data Novator Solutions collects and processes about you who use contact forms on our website are:

• Name
• Phone
• E-mail
• Subject: Message

5. Why do we process information about you?

5.1 For those who visit our website

Novator Solutions processes your personal data for various purposes. For those of you who visit our website, we process your personal information with the aim of:

• Get a picture of how you as a visitor use the site.

5.2 For those who fill out contact forms

Novator Solutions processes personal data for those who fill out contact forms for the purpose of:

• Fulfill our obligations to you as a customer, such as providing support.

• Enable general customer care and customer service, such as answering questions and correct erroneous information.

• Provide information and direct marketing, by mail, e-mail, SMS / MMS and telephone regarding Novator Solutions products and services.

• Manage customer relationship and provide our services. • Follow applicable legislation, such as accounting laws.

6. The legal bases for our processing of your personal data

6.1 Novator Solutions bases the processing of your personal data on a number of legal grounds. These are described in this section.

6.2 We process, inter alia, your personal information in order to fulfill the agreement with you as a customer, as well as to fulfill our obligations to you as a customer. Based on this legal basis, we process information about you as a customer, your behavior on our website, your interaction with Novator Solutions and your interest in our services.

6.3 Part of the processing of personal data we carry out is based on a so-called balance of interests. This applies, for example, to the processing we carry out in order to be able to e-mail you about our services and to do a limited segmentation of customers, eg. based on statistics from e-mail. Novator Solutions does not process sensitive personal data with the aid of a balance of interest and does not carry out any processing that constitutes profiling with a balance of interest.

6.4 In some cases, Novator Solutions may have a legal obligation to process your personal information. This applies, for example, to the processing of personal data that we carry out in order to fulfill the requirements of the Accounting Act.

7. Compilation of our personal data processing

Purpose Legal Basis Personal Data Category Storage time

For you to visit our website.	Fulfill our commitments to you as a customer.	IP address and information about your use of the Novator Solutions website.	As long as it is needed to fulfill the purposes for which the data was collected.
To enable you to fill out the contact forms on our website.	Fulfill our commitments to you as a customer.	E-mail Phone Subject / Message	As long as it is needed to fulfill the purposes for which the data was collected.

8. Profiling

8.1 Novator Solutions can process your personal data through profiling if you are a customer. If you are a customer, information on how to use our web is analyzed.

8.2 You can at any time object to the processing of personal data through profiling. You do this by calling us or by contacting info@novatorsolutions.se. Once Novator Solutions has received your notification, we will cease processing your personal information for this purpose.

9. How long do we store information about you?

9.1 Your personal data will only be stored as long as there is a need to save it in order to fulfill the purposes for which the data was collected in accordance with this Privacy Policy. Novator Solutions may save the data longer if needed to comply with legal requirements or to safeguard Novator Solutions’ legal interests, such as whether a legal process is in progress.

9.2 Novator Solutions saves data on customers for a maximum of 24 months after the customer last integrated with Novator Solutions.

10. Who do we disclose personal information to?

10.1 We will not sell or share your personal data with third parties unless we have your permission.

11. Change of privacy policy

11.1 Novator Solutions has the right to change the Privacy Policy at any time. Novator

Solutions will notify you with changes to the Privacy Policy at reasonable notice.

12. The protection of your personal data

12.1 You should always be able to feel secure when you submit your personal information to us. Novator Solutions has therefore taken the security measures necessary to protect your personal data against unauthorized access, alteration and deletion. For example, all information about customers is stored in a database that is protected by authorization management and firewall.

13. Your rights

13.1 Novator Solutions is responsible for the processing of your personal data in accordance with applicable legislation.

13.2 At your request or on your own initiative, Novator Solutions will correct, de- identify, delete or supplement any information found to be incorrect, incomplete or misleading.

13.3 You have the right to request

a. Access to your personal data. This means that you have the right to request a record of the processing we carry out regarding your personal data. You also have the right to receive a copy of the personal data processed. You have the right, once a calendar year, by means of a written signed application, to receive a free record of which personal data is registered about you, the purposes of the processing and to which recipients the information has been or should be disclosed. You are also entitled to receive information in the register extract about where the data has been collected from if the personal data has not been collected from you, the existence of automated decision making (including profiling) and the foreseeable period during which the data will be stored or the criteria used to determine this period. Furthermore, you are entitled to receive information on your other rights in this register extract as specified in this section.

b. Correction of your personal information. At your request, we will correct as soon as possible the incorrect or incomplete information we process about you.

c. Deleting your personal information. This means that you have the right to request that your personal data be deleted if they are no longer necessary for the purpose for which they were collected. However, there may be legal requirements that we may not immediately delete your personal information in, for example, accounting and tax legislation. We will then terminate the treatment done for purposes other than following the legislation.

d. Limitation of treatment. This means that your personal data is marked so that it can only be processed for certain specific purposes. You may, among other things, request limitation when you consider that your information is incorrect and you have requested correction in accordance with point 12.3 (b). While the accuracy of the data is being investigated, their processing will be limited.

13.4 Novator Solutions will notify any recipient to whom the personal data has been disclosed in accordance with clause 10 above regarding any corrections or deletions of data and limitation on the processing of data.

13.5 You have the right to object to the processing of personal data that is carried out on the basis of a balance of interests. If you object to such treatment, we will continue the treatment only if there are legitimate reasons for the treatment that outweigh your interests.

13.6 If you do not want us to process your personal data for direct marketing, you are always entitled to object to such processing by sending an email to info@novatorsolutions.se. When we have received your objection, we will cease processing personal data for such marketing purposes.

13.7 You have the right to submit any complaints regarding the processing of your personal data to the Data Inspectorate.

14. Cookies

14.1 Cookies are used on this site. Cookies are small text files that are stored on your computer and used to track what you do on the site. There are two types of cookies; permanent cookies and session cookies.

14.1.1 Permanent cookies

A permanent cookie remains on the visitor’s computer for a specified period of time. On this site, these are used to improve the site by getting statistics on how a visitor uses the site, such as which articles are read the most and how users move in the navigation.

14.1.2 Session cookies

A session cookie is temporarily stored in the computer’s memory while a visitor is on a web page. Session cookies disappear when you close your browser. This site uses session cookies to handle information that you provide when using this site’s services.

14.2 If you do not agree to the use of cookies, you may disable cookies in your browser’s security settings. You can also set the browser so that you get a query every time the site tries to place a cookie on your computer. The browser can also delete previously stored cookies, see the browser’s help pages for more information.

14.3 The Swedish Post and Telecom Agency is the supervisory authority in the area, please read more about cookies on their website.

15. Web statistics analytics tool

15.1 This site uses Google Analytics as a tool to get an idea of how visitors use the site. The analytics tool uses cookies and the information generated by them through your use of the Website (including your IP address) will be forwarded to and stored by Google on servers in the United States. This information is used for the purpose of evaluating visitor statistics, for example to improve content, navigation and structure. Google may also transfer this information to third parties if required by law or in the event that a third party processes the information on Google’s behalf. Google will not associate IP addresses with other data held by Google.

Google Analytics uses three cookies:

“_Ga” is used to distinguish users and expires after 2 years. “_Gid” is used to distinguish users and expires after 24 hours.

“_Gat” is used to link the web page with our Google Analytics account and expires after 90 days.

15.2 If you do not want your visits to this site to appear in Google Analytics statistics, there is an add-on that you can install in your browser. You can download the extension on the Google website. You can also deny the use of cookies (see above) by selecting certain settings in the browser.

15.3 This site uses the Hotjar service as a recording service. Hotjar records a user visit to the site that cannot be tracked to an individual. We do this to gain a better understanding of how visitors interact with our website and thereby improve and optimize the site.

16. Production

16.1 The site is produced by Windh & Co and uses modern technologies and solutions.

17. Contact information

17.1 Do not hesitate to contact us if you have any questions about this Privacy Policy, the processing of your personal data or if you would like to request a copy of the register. Our contact information can be found below.

Novator Solutions AB info@novatorsolutions.se +46 8 622 6350

2019-11-05