This information relates to the processing of personal data that Human Entrance AB (“Human Entrance” or “we”) obtains in conjunction with the performance of our assignments for customers, from you/your organization in capacity as business partner, from your visits to our website, from our affiliates or from a third party.
With reference to law, we refer below to the General Data Protection Regulation GDPR (Swe. Dataskyddsförordningen), and other applicable Swedish data protection legislation.
‘Personal data’ means data relating to you that can identify you.
When you register for a newsletter, a webinar/training, send a contact enquiry etc. you are asked to provide certain personal data, including but not limited to your name, IP address, telephone number(s), e-mail address and invoicing information.
Human Entrance may further collect personal data that is needed in order for Human Entrance to execute and administer services for you on behalf of your employer. Your employer can provide us with the information either through email, an order form or through our online tracking and report system Movenet. You provide us with personal data when you complete a form in Movenet or send an email to us.
Human Entrance may also collect personal data from our business partners in the form of contact details necessary to perform our services within the framework of our commercial relationships with them.
The personal data about you that may be affected is:
Personal data and contact details (name, address, email address and telephone number, demographic information and – when clearly justified considering the purpose of the processing or the importance of secure identification – personal identity (ID) number.
We may also need passport or ID-documents in originals, which might contain biometric data, if required by local authorities for the performance of our services.
User-generated information (content that you voluntarily register or publish)
It is a precondition for our processing of your personal data to be lawful that there is a legal basis for this, i.e. that it is necessary to perform a contract with you or a legal obligation to which we are subject, or that the processing is done following a balance of interests or that you have given your consent to specific processing. The following are examples of the purposes for which we process your personal data and the legal basis for the processing:
One of our primary purposes for collecting personal data is to perform and administer our services, more precisely in order to administer and fulfill our contractual obligations towards our customers which involves providing services to you or the organization in which you are employed in relation to relocation and global mobility services. In the case of contact information concerning key persons within our customers’ respective organizations the data will also be used for reporting and invoicing purposes.
Legal basis: The performance of a contract or legal obligation, or if you are a representative, employee or otherwise represent an organization that has entered into contract with us – legitimate interest. Human Entrance’s legitimate interest in the above-mentioned processing of personal data is to be able to perform contractual or legal obligations.
If we need passport or other identification document in original in order to perform our services we will request consent before handling this kind of documentation.
We may also use the personal data to adapt our services and service offering, business and method development, market analysis, statistics and risk management.
Legal basis: Legitimate interest.
We may use data about you to provide news information and marketing related to our services, both general and customer-specific, and inform you about our activities or services. We may thus use the data about you for direct marketing, unless you/your organisation have instructed us not to do this. To the extent that you do not have an active customer relationship with us and are a consumer we will only use your data for electronic direct marketing if you have consented to this.
Legal basis: Legitimate interest or consent where expressly stated.
You have an opportunity at any time to object to us using your personal data for marketing purposes by contacting us in the manner described below.
Human Entrance’s legitimate interest in the above-mentioned processing of personal data is to be able to offer you/your organization better services (by developing, analyzing our activities and communicating with our contacts) and also to provide you with offers and other relevant information.
Personal data is not kept longer than what is necessary for the purpose for which it has been collected or it is required according to law or contract.
You may revoke your consent, if given, for us using your personal data, object to our processing of your data or request that your personal data that we process be corrected and/or be deleted by contacting us with use of the contact details provided below at any time. If you have provided your personal data to us and wish to know what data we have stored, you may request information about this.
You also have a right to data portability, i.e. right to receive your personal data in a structured, commonly used machine-readable format and/or, if technically possible, transmit your personal data to another data controller.
You are entitled to object to such processing of your personal data that we do pursuant to a balance of interests. We must then, after you have specified the processing to which you are objecting, demonstrate that there are overriding interests. You are also entitled to object at any time to the processing of your personal data carried out for direct marketing.
Please note that it may be required that we retain necessary personal data in conjunction with erasure, withdrawal of consent or porting to be able to fulfil our obligations by law or contract. It may also be permitted for us according to law to retain certain personal data to satisfy our business needs.
Please notify us as soon as possible if you consider that the processing of your personal data has been dealt with incorrectly. You also have the option to make a complaint to the Swedish Data Protection Authority about our personal data processing.
Human Entrance may transfer your personal data to partners and subcontractors should this be regarded as necessary in order for Human Entrance to execute the services ordered by you or your employer or to fulfil your request for information or attending a webinar/training. Categories of receivers which your data may be transferred to are mainly , authorities (such as immigration, social security, local police and tax authorities), financial advisors, insurance companies, IT-service providers, subcontractors including our affiliates (e.g. Home Rental Nordic AB), landlords, utility companies (such as internet providers, electricity providers, cleaning companies, moving companies), language training companies/schools, your employer and local affiliates of your employer. Human Entrance will not disclose personal data to external parties unless:
(i) This has been specially agreed between our customer/you and Human Entrance and the disclosure is in your interest.
(ii) It is necessary to exercise your rights.
(iii) It is necessary for Human Entrance to be able to perform a statutory obligation, comply with decisions from public authorities or courts.
(iv) Human Entrance has engaged a service provider/subcontractor in accordance with the above to perform services on our behalf either as our data processor or as an independent controller. In the case the engaged party is acting as data processor on our behalf it will be bound to only use personal data on Human Entrance’s behalf and also to protect it and process it confidentially in a corresponding way to Human Entrance.
Your personal data may in connection with the performance of our services the above be transferred also outside the EU/EEA. Human Entrance will ensure that transfers of your personal data outside of the EU/EEA is only done to the extent permitted by law.
Human Entrance maintains security measures (including physical, electronic, and administrative measures) that are reasonable and appropriate to protect personal data from loss, destruction, misuse, and unauthorized access or disclosure. For example, we limit access to personal data to authorized employees and service providers who need to know the information in the course of their work tasks.
Please be aware that, although we endeavor to provide appropriate security measures for personal data, no security system can prevent all potential security breaches. If a security breach occurs, we will to the extent required by applicable law inform the Swedish Data Protection Authority, you and, if applicable, your employer.
Human Entrance AB, corporate identity number, 556597-6692, is the controller for the processing of your personal data as described above, unless otherwise expressly stated in conjunction with the collection of your data. If you have any questions regarding this policy or the personal data we process about you, please contact us at Human Entrance AB, Hyllie Boulevard 10 B, 215 32 Malmö, Sweden.
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