Personal Data Policy
Kellfri AB (‘Kellfri‘ or ‘the Company‘) is the Personal Data Controller for processing personal data in connection with the provision of services and products related to purchases, service matters and other contact with Kellfri. The Company is also the Personal Data Controller for anyone who enters into a business cooperation with the Company or applies for a job with Kellfri. Kellfri also processes personal data supplied in connection with visits to Kellfri’s website.
The purpose of this Personal Data Policy is for you as a business partner, supplier, customer, user of Kellfri’s website or job applicant to feel confident that the Company, as a Personal Data Controller, processes personal data in compliance with applicable privacy legislation, including the General Data Protection Regulation (the European Parliament’s and Council’s regulation 2016/679 of 27 April 2016, hereafter referred to as ‘the GDPR‘).
2. Personal Data Controller
Personal Data Controller Kellfri AB
Corporate identity number: 556471-9101
Address: Munkatorpsgatan 6, 532 37 Skara, Sweden
Telephone: +46 511 24250
3. What personal data does the Company process?
The categories of personal data Kellfri may process concerning you as a customer are:
Contact details such as
- Email address
- Telephone number
Personal data such as
- ID number
- National ID
Payment information such as
- Account details
- Customer number
- Product information
The categories of personal data Kellfri may process concerning you as a business partner are:
Contact details such as
- Name of business partner’s employee
- Business address of business partner’s employee
- Employee’s email address
- Business telephone number of business partner’s employee
The categories of personal data Kellfri may process concerning you as a job applicant are:
Contact details such as
- Email address
Employment data such as
The categories of personal data Kellfri may process concerning you as a visitor to our website are:
Website information such as
- IP address
- Information about your use of Kellfri’s website (see information about cookies)
4. How do we collect personal data, and for what purposes?
Kellfri gains access to the categories of personal data listed above in various ways, including:
- Data you supply to us directly
- Data registered when you visit our website, webshop, Facebook page or other social media
- Data we obtain from public records
- Data we obtain when you engage one of our employees
- Data we obtain when you register for our events or trainings
- Data we obtain when you subscribe to our newsletter or other mailings
- Data we obtain when you reply to questionnaires and surveys
- Data we obtain when you apply for employment with us, visit us or contact us in any other way.
Kellfri processes its customers’ personal data mainly in order to:
- Fulfil our commitments to you as our customer, such as processing purchases, creating invoices and providing support.
- Enable general customer relations management and customer service, such as answering queries and correcting erroneous information.
- Disseminate information and target marketing regarding Kellfri’s and selected partners’ products and services by mail, email, SMS/MMS messages and telephone.
- Manage customer relations and provide services.
- Provide you with relevant information and tailored offers in newsletters and online.
- Determine which payment methods we can offer you, for example by making credit checks.
- Improve our customer offer, for example by developing services, products and functionality.
- Prevent fraud and carry out risk management.
- Comply with applicable legislation, such as accounting laws.
- The data may also form the basis for marketing and customer analyses, market research, statistics, business monitoring and business and method development related to product and service purchases.
Kellfri processes personal data relating to business partners mainly in order to:
- Order products or services (and to manage payment and delivery)
- Manage cooperation
- Organise future events and cooperations
Kellfri processes personal data relating to job applicants mainly in order to:
- Evaluate and register candidates
- Book interviews
- Manage contact with applicants
- Where applicable, enter into employment agreements
5. What legal basis does the Company have for processing your personal data?
Kellfri bases its processing of your personal data as described above on certain legal grounds. These are described in this section.
The Company processes customers’ personal data for purposes including enabling us to fulfil our agreement with you as our customer, such as making bookings and purchases, and to fulfil our commitments to you as an Account Holder, such as simplified administration and order history tracking. With the support of this legal basis, we also process data relating to you as an Account Holder, such as monitoring your purchases, your browsing behaviours on our website, your interaction with Kellfri and your interest in our offers and products, in order to fulfil our commitment to providing you with personalised offers.
Part of the personal data processing we do is based on a so-called balance of interests. This applies, for example, to the processing we do in order to enable us to make a limited segmentation of customers, for example on the basis of total purchase amounts. Kellfri does not process sensitive personal data, nor does it conduct profiling, on the basis of a balance of interests.
In certain cases, Kellfri may be legally obliged to process your personal data. An example of such a case is processing personal data to meet the requirements of accounting law.
Kellfri also processes personal data with the support of your consent as a legal basis. This applies, for example, to the processing we do in order to enable us to send you offers concerning products and services by email. For further information about the Company’s personal data processing with the support of your consent, see section 10 below.
The Company processes personal data related to business partners for purposes including enabling us to fulfil our agreement with you as a business partner or supplier, such as placing orders, fulfilling our commitments to you and managing the Company’s administration and order history.
In certain cases, Kellfri may be legally obliged to process personal data related to business partners. An example of such a case is processing personal data to meet the requirements of accounting law.
The Company processes personal data related to job applicants in order to be able to enter into any potential employment agreement with you as one of our employees.
6. How long does the Company store personal data?
Personal data necessary for fulfilling agreements or entering into agreements (for example to supply products) is deleted by the Company after the Company has fulfilled its obligations under the terms of the agreement and satisfied your interests that follow from applicable legislation (such as the right to complain and warranty obligations).
However, personal data necessary in order for us to be able to fulfil contractual obligations to our business partners and legal obligations (such as accounting legislation) will be stored as long as it is required to enable us to fulfil the obligations in question.
Personal data the Company processes on the basis of a balance of interests as a legal ground are stored for the period during which the Company has a legitimate and justified interest in such personal data processing.
Personal data the Company processes with the support of consent as a legal ground is stored for the period during which you consent to the processing, and deleted after your consent has been withdrawn. For further information about personal data processing with the support of consent, see section 10 below.
7. Who may we share your personal data with?
a) Third parties
Kellfri follows applicable legislation, including the GDPR, concerning protection of the personal data we gain access to in connection with business cooperation, and which is processed in our operations or by the third party we are cooperating with. Such a third party may be a company in the Kellfri group, a haulier, a supplier of payment management services or various IT services. If you, as a customer, apply for credit on the purchase of a product or service, your data may be disclosed to companies providing credit checks.
A third party to which Kellfri discloses data or in any other way provides information about a customer, or other category of registered person whose personal data Kellfri processes, will only use the information for the purposes stated above and within the framework of the legal grounds mentioned above.
Personal data may also be disclosed by Kellfri if this is required for compliance with applicable legislation or authority requirements, or to protect Kellfri’s legal interests, or to discover, prevent or draw attention to fraud or other security or technical issues.
b) Transfer of data to third countries
The Company always strives to ensure that your personal data is processed inside the EU/EEA, but if data is transmitted outside the EU/EEA the Company will always respect applicable binding regulations (including the GDPR) concerning transfer to third countries.
The Company always strives to ensure that your personal data is processed inside the EU/EEA. Kellfri may transfer your personal data to a country outside the EU/EEA if a Kellfri AB supplier or partner is located there. If personal data is transferred to a country outside the EU/EEA, Kellfri will take measures to ensure that the personal data continues to be protected, and will take the measures required for legal transfer of personal data to countries outside the EU/EEA.
The Company will not sell your personal data to a third party without your consent.
If we disclose personal data to a third party, we draw up a personal data assistant agreement or similar, in order to ensure that the personal data is processed in a satisfactory manner.
8. Security measures
Kellfri takes all the technical and organisational measures necessary to ensure that personal data is protected against unauthorised and illegal processing and against unintentional loss, destruction or damage. Established procedures and policies ensure that our employees are aware of how personal data should be processed in our operations.
Below is a summary of all the rights a registered person has under the terms of the Data Protection Regulation:
- The right to have access to your personal data. You can request a copy of the data you would like to have, and verify the information we have about you. A copy can be requested at no cost.
- The right to correction of erroneous or incomplete personal data.
- The right to have your data deleted in certain cases, e.g. if your personal data is no longer required for the purposes for which it was collected.
- The right to limitation of your personal data in certain cases, e.g. if you have objected to processing of your personal data which takes place after balance of interests, for the period during which it is being established whether the Company’s reasons weigh more heavily than your interests, rights and freedoms.
- The right to obtain personal data and transfer it to another personal data processor in certain cases (data portability).
- You have the right to object to the processing of your personal data on the basis of a balance of interests. In such cases, continued processing of your personal data is dependent on the Company being able to demonstrate pressing, justified reasons that weigh more heavily than your interests, rights and freedoms. Processing of the data may also continue for the establishment, pursuit or defence of legal claims.
- You have the right to lodge a complaint concerning the processing to the Swedish Data Protection Authority or other competent supervisory authority in the EU.
Note that in certain cases Kellfri cannot remove your personal data without simultaneously concluding our business cooperation. As pointed out above, we may in some cases be required to retain part of your personal data after you have requested its removal, in order to fulfil our legal or contractual obligations. We may also be permitted by applicable legislation to retain certain personal data in order to satisfy our business requirements (balance of interests).
10. Withdrawal of consent
You may at any time withdraw your consent to the Company’s processing of your personal data for the dispatch of Kellfri’s newsletter and for marketing purposes by sending an email notification or by visiting us at the addresses given in section 2 above.
These remain during several visits to the website. Persistent cookies enable Kellfri to identify anonymous repeated visitors to the website. Persistent cookies create a file with specific information such as how the user entered the website, which pages the user visits, how the user navigates the website and which options the user clicks into. This helps us to improve the website. For persistent cookies and methods of analysing them, we use Google Analytics. Please note that Kellfri does not collect any personal information that directly identifies your name or address.
Sessions cookies are removed automatically after each visit, and make it easier for you to perform activities on the website by, for example, remembering field entries in forms that recur during your use of the website. Sessions cookies disappear immediately when you close your browser session.
Third party cookies
When a user visits a website which contains embedded content (e.g. Facebook), cookies from these websites may be stored. Kellfri has no control over these cookies. Please visit the particular third party websites to manage your settings connected with third party cookies.
The following third party cookies are used on the website: Criteo
How do you avoid cookies?
If you wish to use the entire Kellfri website, we recommend that cookies are installed. If you disable a cookie that has been installed, you can probably continue to surf on the website, but certain functions may then have been disabled.
You can easily remove cookies from your computer, tablet or mobile by going into your web browser (e.g. Safari, Google Chrome or Internet Explorer). Instructions on what to do in order to remove cookies can be found under the ‘Help’ option in the web browser.
Bear in mind that if you choose to remove cookies in your web browser, this decision will only apply to the web browser you are using. You will need to follow the same procedure for all other web browsers you use. Bear in mind, too, that if there are separate user accounts for a computer, tablet or mobile in a household, you can tailor your cookie settings for each account.