PRIVACY POLICY

1. Introduction

Klimato AB, 559139-1759 (“Klimato” or “we” in any form) is committed to protect the personal data and safeguard the privacy of our website visitors and contact persons for our customers, suppliers and other business partners. For more information about us, see Section 13. This Privacy Policy describes how Klimato, in its capacity as a data controller, processes personal data in accordance with the General Data Protection Regulation (hereinafter referred to as the “GDPR”).

2. Scope of application

Klimato operates a website and applications offering various functionalities, products, and services. To optimise these offerings, we may collect some of your personal data. For instance, if you subscribe to our newsletter, we will request your email address to send you updates. It is important to note that Klimato will never rent, sell, or distribute your personal information in any manner.

3. Compliance with applicable laws

Klimato's internal computer systems, website (klimato.com) and applications are designed to adhere to the following national and international data protection legislation:

• • Dataskyddslag (2018:218)
  • UK Data Protection Act 2018
  • EU General Data Protection Regulation 2018 (GDPR)

By complying with these stringent data protection laws, Klimato ensures that its operations likely align with data protection and user privacy laws in various other countries and territories.

4. Cookies

At Klimato, we use cookies to enhance your online experience. Cookies are small text files that are placed on your device when you visit our website (Klimato.com) or use our applications. They serve various purposes, including improving site functionality, enhancing user experiences, and providing us with valuable insights to continuously grow and improve our services.

Our use of cookies is governed by our dedicated Cookie Policy, which provides you with comprehensive information about how we use cookies, the types of cookies we use, and how you can manage your cookie preferences.

5. Categories of personal data, processing purposes and legal bases

In this Section 5 we have set out the categories of personal data that we may process, the purposes for which we may process personal data, the legal bases of the processing and the retention period for the personal data.

5.1 Ongoing business partners

If you represent an organization that we do business with, we may process the following personal data in order to facilitate our business relationship with the organization which you represent, i.e. name and contact details such as e-mail address, full name, title, telephone number, which organization you represent as well as correspondence. We may process personal data included in your personal profile on our website which may include your name, address, telephone number, email address, title, which organization you represent as well as correspondence. The profile data may be processed for the purpose of enabling and monitoring your use of our website and applications.

We may also process correspondence data, i.e. information relating to our customer relationships, including information contained in or relating to any communication that you send to us. The source of the customer relationship data is you or your employer. The personal data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.

Our legal basis for processing of the personal data is our legitimate interests to conduct our business and the proper management of our customer relationships. We will retain the personal data for as long as we have a business relationship. After that we may retain your personal information for a maximum of 36 months, following the end of our business relationship.

5.2 Potential business partners

If you represent an organization that we consider to do business with, we process personal data in order to facilitate our potential business relationship with the organization which you represent, i.e. name and contact details such as e-mail address, full name, title, telephone number, which organization you represent as well as correspondence. Our legal basis for processing of the personal data is our legitimate interests to conduct our business.

We may also process information contained in any enquiry you submit to us regarding goods and/or services for the purpose of offering, marketing and selling relevant goods and/or services to you based on your enquiry. Our legal basis for processing of the personal data is in this case legitimate interest or consent. We will retain the data for a maximum of 36 months, following our latest contact. Where the contacts have led to a business relationship, the personal data will be processed as described in the previous section, Ongoing business partners.

5.3 Customer support

In order to provide customer support, we process personal data regarding organizational belonging, name, email address, phone number, location data, correspondence, matter number and information about the relevant enquiry. The correspondence data may be processed for the purposes of communicating with you and record-keeping. Our legal basis for processing personal data is our legitimate interests to conduct our business and to communicate with the person that has reached out to our customer support. We will retain the data for a maximum of 12 months following the termination of the relevant service agreement.

5.4 Correspondence with other individuals

Occasionally, we engage in correspondence with individuals in other matters than those accounted for above. This may be the case where individuals have general questions about our services. Such correspondence may include communication content and metadata associated with the communication, e.g. metadata associated with communication generated using the website contact forms. Our legal basis for processing personal data in this respect is our legitimate interests to conduct our business, including to respond to such queries. We will retain the data for a maximum of 36 months, following the latest contact with you.

5.5 Newsletters and marketing emails

We process your name, contact information, organizational belonging and title and email address in order to provide you with marketing and product information in email notifications and/or newsletters. Our legal basis for doing so is consent. Your consent can be withdrawn at any time by opting-out by following the instructions in the email. We will retain the data and process it for the purposes of delivering newsletters until you opt-out or withdraw your consent.

5.6 Media and marketing content

We may publish material on our website or social media (Facebook, LinkedIn, YouTube and Instagram) containing personal data to inform about our company and services. Our legal basis for doing so is our legitimate interests to inform about our business for marketing purposes. The social media providers each inform about their privacy practices and we encourage you to inform yourself thereof. The data will be retained as long as it may be relevant to fulfil the purpose. In case of any questions, please refer to Section 13.

5.7 Handling data subjects rights

We will process email address, name, correspondence and data about the request. Our legal basis for processing personal data is compliance with a legal obligation. The data will be retained as long as it may be relevant and for a maximum of 36 months.

5.8 Other processing purposes

In addition to the specific purposes for which we may process your personal data set out in this Section 5, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. Furthermore, we may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

We may also process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others. We will retain personal data for these purposes in accordance with the second paragraph of Section 6. below.

6. Retention

Your personal data will be retained for the different purposes as specified for each section above. In addition to retention for the foregoing purposes, we may also retain your personal data in order to comply with applicable laws, such as bookkeeping laws, or if we need your personal data to establish, exercise or defend legal claims.

In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, the period of retention of all personal data categories will be determined based on the necessity of storing that data for longer than necessary.
Where the data is only stored, it will be archived with appropriately limited access rights.

7. Consent and opt-out

We respect your preferences, and you have the right to unsubscribe from marketing and sales emails at any time. You can manage your email preferences by utilising the “manage preferences” link found at the bottom of marketing and sales related emails.

However, please note that the option to opt out does not extend to essential transactional emails, policy updates and customer service emails as the legal bases for these processing activities is your agreement with us, and our contractual obligation to fulfil our service commitments under the agreement, and/or our legitimate interest to provide you with a seamless user experience. These communications are integral to the proper functioning of our services, are tailored exclusively for our customers, and serve to fulfil our contractual commitments.

8. Who we share your personal data with

Klimato may engage external service providers, who act as data processors of Klimato, to provide certain services to Klimato, such as website or application service providers, marketing service providers or IT- and cloud service providers. In this case, the external service providers may have access to, store and/or may process your personal data in compliance with the legal basis of legitimate interest. We request those external service providers to implement and apply security safeguards to ensure the privacy and security of your personal data. The recipients will only gain access to your personal data to the extent necessary for them to fulfil their mission and they may not share or use the data for other purposes. An example of such service providers are Amazon Web Services (AWS) and MongoDB Atlas, which Klimato uses for cloud database storing and application hosting.

We may also disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and the legal bases, set out in this policy. Your personal data may also be shared with our business partners for marketing purposes, to the extent you have provided your consent.

In addition to the foregoing, Klimato may transfer – in compliance with applicable data protection law – personal data to law enforcement agencies, governmental authorities, legal counsels, insurers, external consultants, or business partners. In case of a corporate merger or acquisition, personal data may be transferred to the third parties involved in the merger or acquisition, including potential buyers, investors and professional advisers.

9. International transfers of Personal Data

Personal Data may be transferred to and processed by recipients which are located inside or outside the European Economic Area (“EEA”). The countries include those listed at the European Commission website which provide an adequate level of data protection from a European data protection law perspective. Other recipients might be located in other countries which do not adduce an adequate level of protection from a European data protection law perspective. Klimato will take all necessary measures to ensure that transfers out of the EEA are adequately protected as required by applicable data protection law. With respect to transfers to countries not providing an adequate level of data protection, we base the transfer on appropriate safeguards, such as standard data protection clauses adopted by the European Commission or by a supervisory authority, approved code of conducts together with binding and enforceable commitments of the recipient, or approved certification mechanisms together with binding and enforceable commitments of the recipient.

10. Data subjects rights

You have a number of rights in connection with the processing of your personal data, subject to certain conditions set out in the GDPR and local data protection laws, including the right to:

Request access to your personal data (“data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request the rectification of the personal data that we process about you. This enables you to have incomplete or inaccurate data we hold about you corrected.

Request the deletion of your personal data. This enables you to ask us to delete or remove personal data where there is no overriding reason for us to retain it.

Ask us to stop processing personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.

Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal data to another party.

If you have given your consent for processing of your personal data and that consent has served as a legal basis for processing, you can withdraw this consent at any time with future effect by contacting us as stated in Section 13 - ‘Contact information’.

In case of complaints you may contact our Data Protection Officer at dpo@klimato.com and you also have the right to lodge a complaint with the competent data protection supervisory authority in particular in the EU Member State of your habitual residence, place of work or of an alleged infringement of the GDPR. In Sweden, this is the Swedish Authority for Privacy Protection (www.imy.se).

11. Data breaches

Klimato will report any unlawful data breach on its applications or its website’s database or the database(s) of any of our third-party data processors to any and all relevant persons and authorities within 72 hours if it is clear that personal data stored in an identifiable manner has been disclosed or taken or is likely to be disclosed or taken.

12. Changes to the Privacy Policy

Klimato reserves the right to change this Privacy Policy at any time. We will give you reasonable notice of any significant changes to the Privacy Policy, where appropriate. If so, we will notify you by a message or by email. You will also find the date of the latest change to the Privacy Policy on this website.

13. Contact information

This website is owned and operated by the company Klimato AB. We are registered in Sweden under registration number 559139-1759, and our registered office is at Klimato AB, Östgötagatan 12, 116 25 Stockholm. If you have concerns or questions regarding this Privacy Policy, please contact us by email, using the email address dpo@klimato.com.