ADLIGO USER PRIVACY NOTICE
- INTRODUCTION Adligo AB, reg. no. 559356-3702 (”Adligo”, ”we”, ”us” or ”our”) is processing your personal data when you create a user account on Adligo’s employee caring service (the “Service”). Please note that the organisation in which you are employed or engaged by will be the controller for most of the processing of personal data taking place within the Service, and Adligo will act as processor (subject to a data processing agreement between Adligo and your employer). However, with respect to the processing activities described in this privacy notice, Adligo will be the controller. We may at our own discretion update this privacy notice at any given time (see at the end the date this notice was last updated). If material changes are made, we will provide notice on this website prior to the change becoming effective. Throughout this privacy notice the term ”processing” is used to cover all activities involving your personal data, including e.g. collecting, handling, storing, sharing, accessing, using, transferring and disposing of your personal data. The term ”personal data” refers to any information relating to an identified or identifiable natural person. It is of utmost importance to Adligo that you are confident that your personal data are processed securely and with high standards of care. Please read this privacy notice carefully and do not hesitate to contact us (on the contact details below) if you have any questions or concerns.
- HOW DO WE COLLECT YOUR PERSONAL DATA? The data is collected either directly from you or from your employer in conjunction with the creation of your user account.
- PURPOSES OF THE PROCESSING OF YOUR PERSONAL DATA Below follows a description of the purposes of our processing of your personal data, including the categories of personal data processed for each purpose and the legal basis thereof.
Purpose
Description
Categories of personal data
Legal basis
Create and manage your useraccount
We will process your personal
data when your user account is
created and in order to
manage your user account,
e.g. ensure that your user
account is available and
maintaining the user account.
Several personal data items
(other than those listed below)
will be contained within the
user account, however most of
which will be processed by
Adligo as processor on behalf of the organisation you are
employed in or engaged by.
- Credentials
- Information
contained in
user logs
Legitimate interest. The processing is necessary to satisfy our legitimate interest
to ensure that the user accounts can be created and are adequately
maintained.
Develop and
enhance our Services
Based on your usage of our
Services, we will produce
statistics that we will analyse in order to improve, develop and enhance our Services. The
analysis will be carried out on
the basis of aggregated
statistical information, but the
creation of the statistics will
include processing of your
usage data.
- Usage data,
e.g.
information
contained in
user logs.
Legitimate interest. The processing is necessary in order to fulfil our legitimate interest to be able to continuously improve our Services and provide new and relevant service offerings to our
customers.
Establish, exercise
and defend legal claims
For the purposes of establishing, exercising and
defending legal claims (for
example in connection with a
dispute or legal process) we
may process your personal
data. Please note that this is
only in the unlikely event that a legal claim would arise within the scope of your usage of the Services.
- User account
data - Usage data,
e.g.
information
contained in
user logs.
Legitimate interest. The processing is necessary in order to fulfil our legitimate interest to establish, exercise or defend the legal claim, for example in connection with a dispute or legal process.
4 WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
4.1.1 General
Where necessary in order to achieve the purposes set out in this Section 3, we share your
personal data with other entities. Please note however that we, regardless of the recipients’
capacity, only will share your personal data with entrusted actors and only to the extent
necessary.
4.1.2 Data processors acting on behalf of us
In order to fulfil the purposes of the processing of your personal data and to be able run our
business, we transfer personal data to external parties such as third-party service providers that
we have engaged, as well as other partners. Within the scope of our Services, we use Amazon
Web Services, Inc. as a processor that will process your personal data. The personal data will
be stored at their data centres in Stockholm.
4.1.3 Recipients that act as data controllers
We will rarely share your personal data with any third party that acts as data controller. If it would
be necessary in order to establish, defend or exercise a legal claim, personal data would be
shared with courts, external advisors and counterparties. Other than this unlikely scenario, we
will not share your personal data with any third party that will process your data as data
controller.
5 FOR HOW LONG TO WE PROCESS YOUR PERSONAL DATA?
Your personal data will be processed for as long as you have a user account, which is for as
long as your employer is an active customer of Adligo or until you cease to be employed by your
employer.
6 APPROPRIATE SAFEGUARDS FOR TRANSFERS OF PERSONAL DATA OUTSIDE OF
THE EU/EEA
We may transfer or disclose personal data to recipients located outside the EU/EEA (third
country), mainly in situations where we are using third-party data processors that will process
data in a third country. Below follows detailed information about our transfers or disclosures of
personal data outside the EU/EEA.
Recipient
Third country
Safeguards
Amazon Web Services, Inc.
USA (however data will be
stored in Sweden, so
transfer of data will only
occur in exceptional
circumstances)
The European Commission’s
Standard Contractual
Clauses.
When we transfer or disclose your personal data to a recipient in a country outside of the EU/EEA, we will always ensure that appropriate safeguards have been taken (such as the EU Commission’s standard contract clauses, including other supplementary safeguards as
necessary in each case) to protect the personal data. Further, we are regularly carrying out risk assessments to assess what supplementary measures that needs to be taken to protect the
personal data subject to the transfer or disclosure.
You are entitled to request to receive a copy of any documentation demonstrating that appropriate safeguards have been taken in order to protect your personal data during a transfer to a third country.
If you would like further details about the processing of your personal data and whether your
personal data is transferred to a third country, please contact us on the contact details as set
out below under Section 8.
7 YOUR RIGHTS
Under applicable data protection laws, you have certain rights in relation to the processing of
your personal data. We process your personal data to the extent necessary in order to fulfil your rights. Please submit requests for exercising your rights by contacting us on the contact details
set out in Section 8 below.
You have, under certain circumstances, the right to exercise the following rights:
Access
You may request confirmation whether or not personal data is processed and, if that is the case,
access your personal data and additional information such as the purposes of the processing.
You are also entitled to receive a copy of the personal data undergoing processing. If the request
is made by electronic means the information will be provided in a commonly used electronic
format if you do not request otherwise.
Object to certain processing
You have the right to object to the processing of your personal data based on a legitimate
interest for reasons which concerns your particular situation. In such a situation, we will stop
using your personal data where the processing is based on a legitimate interest, unless we can
show that the interest overrides your privacy interest or that the use of your personal data is
necessary in order to manage or defend legal claims.
Rectification
You have at any time the right to have inaccurate personal data rectified, as well as, taking into
account the purposes of processing, the right to have incomplete personal data completed which
relates to you.
Erasure
You may have your personal data erased under certain circumstances, such as when your
personal data is no longer needed for the purposes for which it was collected. However, we
cannot delete your personal data if we e.g. are obligated under law to keep the data.
Restriction of processing
You may ask us to restrict the processing of your personal data to only comprise storage of your
personal data under certain circumstances, such as when the processing is unlawful, but you
do not want your personal data erased. If the processing of your personal data has been
restricted we may only, besides storing the data, process your personal data with your consent,
or in order to establish, exercise or defend legal claims or to defend rights of others.
Complaints to the supervisory authority
You acknowledge that you always have the right to lodge complaints pertaining to the
processing of your personal data to the Swedish Authority for Privacy Protection (Sw.
Integritetsskyddsmyndigheten).
8 CONTACT DETAILS
If you have any questions or concerns regarding the processing of your personal data, please
contact us on the below contact details:
Adligo AB
Katarinavägen 15, 102 61 Stockholm
Email: hello@adligo.io
Last updated: 16 January 2022