PRIVACY POLICY NinaSTHLM


1. Introduction

NinaSTHLM means NinaSTHLM a trademark owned by Travers AB

NinaSTHLM process personal data of customers upon their registration at NinaSTHLM’s website http://www.ninasthlm.com. According to the Swedish Personal Data Act (1998:204) and equivalent legislation in other jurisdictions, the processing of personal data is restricted and may only be made in accordance with applicable personal data law.

1.2 In order to ensure that NinaSTHLM acts in accordance with applicable personal data law, the following privacy policy has been adopted (the “Privacy Policy”). All employees of NinaSTHLM shall observe this Privacy Policy when processing personal data.

2. Definitions

2.1 “personal data” means name, date of birth, address, e-mail address, telephone number and other personal information of the customers.

2.2 “processing” personal data means every action taken as regards such information, e.g. collecting, registration, storage, usage, disclosure, transfer etc. of the information when such activities are made wholly or partially by electronic means.

2.3 “registered person” means the customer whose personal information is being processed by NinaSTHLM.

2.4 “sensitive data” means personal data that discloses race or ethnical origin, political opinion, religion, membership in trade union, or relating to health or sexual life.

2.5 “unstructured material” means text, images, e-mail etc. which is not included or intended to be included in a document or client relationship management system or any other database.

3. What Personal Data is processed?

3.1 With regard to customers, NinaSTHLM mainly processes name, telephone number, address and e-mail address of the customer. This information is used for the purpose of (i) delivering NinaSTHLM’s products, (ii) keeping a customer database with contact details of the customers, and (iii) marketing activities.

4. General Requirements on Processing of Personal Data

4.1 If the personal data constitutes unstructured material it may be processed freely except that the processing may not be made in a manner that may be considered to violate the integrity of the registered person.

4.2 When personal data is part of a document or client relationship management system or any other database, the processing of the information must be made in accordance with the provisions of applicable personal data law. This means e.g. that personal data:

5. Access to the Personal Data

5.1 NinaSTHLM will not sell, rent or lease any of the gathered personal data except as when explicitly stated in this Privacy Policy. NinaSTHLM shares personal data with a company managing the credit card payments, the webhosting company.

6. Sensitive Data

6.1 Sensitive data may not be processed unless the individual has given his/her explicit consent or when processing is necessary to fulfil the obligations or exercise rights under applicable law.

7. Children’s Personal Data

7.1 NinaSTHLM does not knowingly gather any personal data from children under the age of 18 years and does not aim its website at children under the age of 18 years. NinaSTHLM advises parents and custodians to take an active interest in children’s activities and interests online.

8. Transfer of Personal Data to a Third Country

8.1 Personal data may not be transferred to a country outside of the EU unless specific measures have been taken to ensure that the recipient of the personal data takes appropriate measures to ensure an adequate level of protection of the information.

9. Guidelines for NinaSTHLM’s Employees

9.1 Unless processing of personal data is made as necessary to invoke NinaSTHLM’s rights or perform NinaSTHLM’s obligations under an agreement, NinaSTHLM’s employees should consult with the office of General Counsel before they (a) process the personal data; or (b) transfer the personal data to a third country/outside of the EU.

10. Information to the Registered Person

10.1 A registered person is always entitled to get information about the processing. If data is gathered from the person him/herself, information shall be given as to how the information is processed etc. at the time of gathering the information. In addition, the registered person may annually request, free of charge, information about what information about him/her is being processed and how.

10.2 To protect the registered person’s personal integrity, NinaSTHLM commits itself to conduct reasonable efforts to verify the registered person’s identity by means of password before the registered person is granted access to its personal information. To review and change the personal information submitted to NinaSTHLM the registered person may enter the website where the personal information was submitted or contact NinaSTHLM on the address provided in Section 18 below.

11. Rectification

11.1 Erroneous information must, if the registered person so requests, be rectified, blocked or erased as soon as practicably possible.

12. Purging of Personal Data

12.1 Personal data may not be kept longer than necessary for the purpose for which it was gathered. This means that personal data must be reviewed regularly and obsolete personal data must be purged from the systems and databases where the information is kept. For example, obsolete personal data can be personal data that NinaSTHLM no longer has use of for the relevant agreement or in respect of which the purpose of the processing has lost significance.

13. Security

13.1 An employee processing personal data must do so in accordance with this Privacy Policy, applicable law and such other policies and instructions as NinaSTHLM may have adopted from time to time. NinaSTHLM is committed to ensuring that any subcontractors or other external parties that are provided access to the personal data, enter into an agreement which in material aspects contains the same provisions as this Privacy Policy, unless when provision of such information is required by applicable law, regulations or court rulings.

13.2 NinaSTHLM has implemented technical and organizational safety measures which NinaSTHLM believes are sufficient to protect the personal data being processed.

13.3 NinaSTHLM uses a payment provider which uses SSL encryption protocol (Secure Sockets Layer) when gathering and transferring sensitive information such as credit card information. SSL encryption protocol makes the information illegible to everyone but the payment provider. This safety function is activated when the unbroken key symbol or a closed lock (depending on the web browser) is visible at the bottom of the web browser window.

14. Use of Cookies Statement

14.1 NinaSTHLM provides information on its use of cookies in the “Use of Cookies Statement” below.

15. Education

15.1 All employees or other persons that are processing personal data shall attend NinaSTHLM’s internal education or the equivalent thereof in order to fully understand the obligations of NinaSTHLM with regard to processing of personal data. Such education is held for new employees and when needed to keep employees up-to-date with requirements on processing of personal data.

16. Links to External Websites

16.1 This website may contain links to websites maintained by other legal entities than NinaSTHLM (“External Websites”). These External Websites are not under the control of NinaSTHLM and NinaSTHLM is not responsible for the contents or privacy policies of any External Websites, including, without limitation, any link contained on an External Website, or any changes or updates to an External Website. NinaSTHLM is providing links to External Websites only as a convenience, and the inclusion of such External Websites are not an endorsement by NinaSTHLM in favour of any company offering internet services, products or services on the External Websites.

17. Changes to this Privacy Policy

17.1 Should the terms and conditions of this Privacy Policy change, NinaSTHLM will publicize the changed policy on this website with information on the date of the change. Should NinaSTHLM conduct any material change of this Privacy Policy NinaSTHLM may also choose to inform the registered persons by other means such as e-mail or by posting a notice on NinaSTHLM’s website http://www.ninasthlm.com.

18. How to Contact NinaSTHLM

18.1 Comments or questions concerning this Privacy Policy or questions regarding NinaSTHLM’s processing of personal data may be sent to the following address:

NinaSTHLM
Att: Customer Service
Stockholmsvägen 60A
SE - 181 42 Lidingö, Sweden
E-mail: info@ninasthlm.com


USE OF COOKIES STATEMENT

The website contains two different types of cookies; persistent cookies, which are text files sent from NinaSTHLM and stored onto the hard drive of your computer, and temporary cookies, which are temporarily stored until you close your web browser. Cookies are used to optimize the website’s functions and to adjust it to your demands. The website’s functionality is in part dependant on the use of temporary cookies.

Temporary cookies are used when you navigate on the website and in the online store. Persistent cookies are used when you log on to your account. Your computer then remembers information for the next session.

Temporary cookies are necessary to navigate the website, but would you like to avoid them, you may configure your web browser so that cookie files are not downloaded onto your computer. More information on how to do this may be available in your web browser’s help section.