1. Purpose and legal grounds for personal data processing
Doggy AB (”Doggy”), corporate registration number 556055-5129, is the personal data controller in relation to personal data that is processed. This means that Doggy is responsible for how your personal data is collected, processed, and, when the purpose of the processing has ceased, thinned.
Your privacy is important to us at Doggy and we want your personal data to be protected. Doggy processes your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (”GDPR”) and other applicable privacy laws.
“Personal data” means all kinds of information that can, directly or indirectly, be used to identify a physical, living person.
2. Personal data that we process
Doggy processes personal data that we obtain in connection with providing services, assignments or supply of goods in connection with our business or to comply with applicable legislation.
You are not required by law to provide your personal data, but you must do so in order to conclude an agreement with Doggy or to use Doggy’s products, services, offers etc. If you do not provide your personal data to us, we cannot fulfil our agreement with you or our obligations in relation to you. We also cannot send our newsletter, special offers or invitations.
Doggy processes personal data when you conclude an agreement with us and/or order our products. Personal data that may be collected includes, for example:
- Given name and surname
- E-mail address
- Phone number
- Personal identity number
- Customer number
- Invoicing and account details
- Other business-related information which you, your representative or counterparties give us
- Credit information
Doggy also processes personal data in connection with membership in our Breeder Clubs. Personal data that may be collected includes, for example:
(i) Given name and surname
(ii) Phone number
(iii) E-mail address
In the context of Doggy’s business, occasional processing of special categories of personal data (so-called sensitive personal data) and violations of law may take place if relevant in relation to the performance of the service/assignment.
Doggy also processes personal data relating to employees and contractors of suppliers in connection with the business relationship between Doggy and your employer or client or as provided by you in the context of the business relationship. Personal data that may be collected includes, for example:
- Given name and surname
- Phone number
- E-mail address
Furthermore, Doggy processes personal data that you provide to us voluntarily such as when you communicate with us via e-mail or other channels, ask us to send our newsletter or offers or when you sign up for events, training, or competitions. Personal data that may be collected includes, for example:
- Given name and surname
- E-mail address
- Phone number
Since Doggy has business relationships with natural persons and when natural persons apply to Doggy’s Breeder Club or subscribe to our newsletter, their private phone number, private e-mail address and private address may be processed.
The data your provide may be completed with information collected from public websites, public databases or payment databases such as the Swedish Companies Registration Office, InfoTorg, UC or SPAR, to ensure the accuracy of the personal data or to check your creditworthiness.
3. Purposes and legal grounds of personal data processing
Doggy only processes personal data if there is an established purpose and legal grounds for the processing.
Doggy processes personal data to prepare, manage and perform agreements with sellers, purchasers, suppliers, etc. and to perform Doggy’s obligations in relation to its customers, suppliers etc. This is done to protect your and Doggy’s interests and for accounting and invoicing purposes. The processing is based on Doggy’s obligation to perform the agreement with you and Doggy’s legitimate interest in being able to deliver its products and services.
Occasional processing of special categories of personal data (so-called sensitive personal data) and/or violations of law may take place if necessary to establish, submit or defend a legal claim.
Personal identity numbers, whose protection is particularly important in the context of GDPR, are processed subject to a consent or agreement or where obviously justified having regard to the purpose and importance of certain identification.
Doggy also processes personal data for purposes of administration of membership in our Breeder Clubs and to give you as a member special offers and information. The processing is based on performance of agreements according to the membership terms and on Doggy’s legitimate interest in offering its goods, services and knowledge and your wishes/legitimate interests in taking part of these.
Personal data processing also takes place to perform Doggy’s legal obligations according to court judgments or regulatory decisions or according to the law, such as the Accounting Act (1999:1078).
Personal data of contact persons of a legal person with whom Doggy has a business relationship are processed based on the agreement with the supplier/contractor for the purposes of invoicing, payment and administration of the contractual relationship, management or deliveries and communication. As a contact person of a supplier, you can only expect such processing of your personal data, and Doggy has a legitimate interest in being able to manage agreements and fulfil our obligations toward our suppliers. In applicable cases, Doggy also processes personal data of a supplier’s employee or contractor based on our legal obligations under, for example, the Accounting Act (1999:1078). This is done for accounting purposes for example regarding invoicing or payment for your services or products.
The information may also be used for business development, market analysis, statistics and risk management. The processing, which is necessary for its purpose, is done based on Doggy’s legitimate interest in developing the business and to identify and manage potential risk.
The data processing for purposes of communicating with you, which includes sending of offers, our newsletter, invitations to events/gatherings and to keep our contact register updated, takes place based on Doggy’s legitimate interest in maintaining customer and business relationships, communication with you and running our business.
4. Access to personal data
Only the staff at Doggy who need access to the personal data to fulfil the purposes listed above have access to the data.
Doggy may, if necessary to, for example, conclude an agreement with you, carry out a service requested by you or, if required according to applicable law, share your personal data with other companies within the group.
Your personal data will not be disclosed to external parties except in the following cases:
- where specifically agreed between you and Doggy,
- where it is necessary, in the context of a specific service, to protect your rights,
- if necessary to perform a statutory obligation or to comply with a regulatory decision or a court judgement,
- in case we hire external service suppliers who carry out assignments on our behalf, such as payment intermediaries, data storage services or to update and support Doggy’s IT structure.
Doggy may disclose your personal data to group companies and other affiliated parties and to potential owners, shareholders and their advisors and other advisors in connection with a sale of shares and/or assets in the company, a stock exchange listing or other reorganisation. Personal data will only be disclosed to the extent necessary and provided there are legal grounds for Doggy’s disclosure. The disclosure is based on Doggy’s legitimate interest in assigning and restructuring its business, which outweighs your interest in protecting your personal data. Disclosure to external parties will only be made to parties who have entered into a confidentiality agreement or have an equivalent statutory confidentiality obligation. If the processing of your personal data changes after the implementation of any of the above measures, you will be informed in accordance with the rules in GDPR.
5. Transfer to third country
As a general rule, your personal data will not be transferred to countries outside the EU/EEA.
In case of such a transfer, it will be made in accordance with applicable data protection legislation and will require that the relevant country has an adequate level of protection or that there is other sufficient protection entailing that the transfer is made in accordance with applicable legislation, for example by using the EU Commission's standard contract clauses.
The UK is not included in the EU/EEA as of 31 December 2020. Subsequently, the EU Commission must decide whether the country has an adequate level of protection, and, if not, Doggy will take other appropriate protective measures.
6. Storage periods
Personal data will be stored in accordance with Doggy’s legal obligations.
Doggy will not save your personal data longer than required having regard to the purpose of the processing. This means that we systematically carry out thinning, erasure or deidentification of your personal data when they are no longer relevant for the purpose for which they were collected.
However, Doggy may save personal data, for which the purpose has ceased, for a longer period if required by law or in accordance with a court or regulatory decision. Doggy may also save personal data longer having regard to performance of an agreement or in connection with a dispute.
Personal data provided to us voluntarily such as when you communicate with us via e-mail or other channels, ask us to send our newsletter or offers or when you sign up for events, training, or competitions will be saved as long as you have a business relationship with Doggy. If you no longer wish to receive our newsletter, offers or invitations, you may notify us at the email address firstname.lastname@example.org, following which your data will be erased immediately.
Should Doggy cease to exist, e.g. in connection with a liquidation or bankruptcy, your personal data will be erased provided they do not need to be saved to fulfil obligations according to applicable laws, regulations and regulatory decisions.
Doggy also collects data with the help of cookies installed when you visit our websites, www.doggyab.se, www.campaign.bozita.se, www.bozita.se, www.doggy.se and www.mjau.se. We process the information created by the website’s cookies such as your IP address, how you found the websites, the duration of your visit, the selections you make on our websites and the number of page views.
The purpose of the processing is to facilitate the use of the page and statistics for visitors. We process the data based on balancing your legitimate interests against those of Doggy. Doggy’s legitimate interests in processing your personal data are to provide you with a good user-experience of our website and our commercial interest in receiving information regarding the visitors on or websites.
If you do not want to allow cookies to be stored on your computer, you can change the browser settings on your computer, as well as delete cookies that are stored on your storage medium. Most browsers automatically accept cookies, but it is also possible to decline cookies or choose to display a warning before they are saved. If you decline cookies, Doggy’s websites may not function correctly.
Doggy uses the statistics tool Google Analytics. Google LLC and its subsidiary companies are personal data controller in relation to their processing of your personal data. More information about Google Analytics and Google’s processing of your personal data is available here.
Personal data that we process in connection with a recruitment procedure is initially processed based on a balancing of interests and generally for a duration not exceeding the duration of the recruitment procedure. Processing/storage of personal data based on legal obligations such as the Discrimination Act (2008:567) continues for two (2) years after the end of the recruitment procedure. If you have consented to the continued processing of your personal data for purposes of potential future employment, your data will be processed for this purposes until you withdraw your consent or the purposes ceases.
In connection with a recruitment procedure, Doggy will share personal data with parties who carry out processing on our behalf, such as Teamtailor AB who provide Doggy’s platform for recruitment.
More information on our personal data processing in connection with recruitment is available in our policy for this purpose, link to policy.
9. Technical and organisational security measures
It is important that your personal data is protected. We therefore take all appropriate technical and organisational security measures required to protect the personal data against unauthorised access, disclosure, amendment or destruction.
Doggy regularly reviews its policies and procedures for security and authorisation to ensure that the organisation and the systems are safe and protected.
If Doggy hires an external supplier to support the business, Doggy will ensure that the supplier applies equivalent technical and organisational security measures and only processes personal data in the manner approved by Doggy. Personal data assistant agreements, confidentiality agreements and other relevant regulatory agreements are signed by the supplier before the service is taken into use.
10. Your rights
You have a right to request information from Doggy on the personal data we process regarding you and how these are processed.
You may withdraw all or parts of your consent at any time. Doggy will then immediately cease the processing to which the withdrawal relates.
We will, at your request or at our own initiative, promptly correct or erase personal data that is out of date, incorrect, incomplete or processed in breach of the above purposes or relevant legislation. In these cases, you may also request that Doggy restrict the processing of such data.
You may also request to access your personal data in a machine readable format. This applies to personal data you have provided to Doggy, the processing is automated and based on consent or contract. If technically possible, you may also have your personal data transferred to another personal data controller.
You also have a right, in some cases, such as when the processing is based on a balancing of interests, to object to Doggy’s processing of your personal data.
You also have a right to object to Doggy’s processing of your personal data for direct marketing purposes. In case of such an objection, Doggy will immediately terminate the processing.
A request from you will be answered as soon as possible and no later than one month after your request is received by Doggy. Where needed, this duration may be extended by another two months, in which case you will be notified.
If your request is obviously unfounded or unreasonable, Doggy may be entitled to decline to grant your request or charge a reasonable fee to cover the administrative costs.
If you wish to exercise any of your rights, please submit a request to Doggy using the contact details below.
If you are dissatisfied with Doggy’s processing of your personal data, you may submit a complaint to a supervisory authority, in Sweden this is the Authority for Privacy Protection (https://www.imy.se).
11. Changes to the Policy
This Policy may, from time to time, be amended or updated. The most recent version of this Policy will always be published on Doggy’s website. Please visit our website to read any updates.
12. Contact details
If you have questions about our personal data processing, please feel free to contact us at:
447 84 Vårgårda
Phone: +46 771-64 64 00
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This Policy was adopted by Doggy AB’s Management Group on 27 May 2020