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Fundrella Privacy Policy

Information on processing of personal data

Version 2019:1
Updated on: 18 October 2019

With this information text (“Privacy Policy”), Fundrella AB (“Fundrella”) intend to fulfil Fundrellas obligations under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“Data Protection Regulation”). An important aspect of this obligations is that persons to whom the information applies are informed of how personal data is processed.

  1. CONTROLLER
    Controller: Fundrella AB
    Corporate identification nr.: 559197-9736
    Address: Bobergsgatan 59 A, 115 47 Stockholm, Sweden
    Email: support@fundrella.com
  2. GENERAL
    1. Fundrella values your integrity and takes all appropriate technical and organizational security measures required to protect your personal information from improper access, change or destruction.
    2. Personal data means any kind of information that can be directly or indirectly attributed to a natural living person. Sensitive personal data is information that discloses racial or ethnic origin, political opinions, religious or philosophical beliefs, union membership, and personal or health information. Fundrella does not process any sensitive personal data related to you. Below is a description of when your personal data is processed. If you have no answer to any question, please feel free to contact Fundrella.
    3. Fundrella reserves the right to modify this Privacy Policy at any time, with immediate effect and without prior notice.
  3. DATA SUBJECTS AND PERSONAL DATA
    1. Fundrella collects personal data, processed in accordance with this Privacy Policy, from the data subject itself when applying to become a user of Fundrella and get access to a user account. Fundrella also collects personal data from data subjects in connection with contact and inquiries via support@fundrella.com.
    2. The categories of data subjects whose personal data is processed by Fundrella, in accordance with this Privacy Policy, are 1) users of the Fundrella platform in terms of (i) representatives at Fund Management Companies and (ii) Professional Investors (together defined below as “Users”) and 2) (i) data subjects in connection with contact and inquiries via support@fundrella.com and (ii) subcontractors to Fundrella (together defined below as “Others”).
    3. The categories of personal data processed by Fundrella from the Users and Others, in accordance with this Privacy Policy, are (i) contact information such as company name, company address, name, username, title, address, e-mail address, phone number and (ii) technical information such as IP address, the type of browser being used, usage pattern through cookies and browser settings, query logs and product usage logs.
    4. Fundrella uses Google Analytics, a web analytics service provided by Google Inc, in order to improve the Fundrella platform, user experience and analyse how the Fundrella platform is used. Aside from the approximate location (IP-address), the information collected by Google Analytics is anonymous traffic data including browser information and device information. The collected information is used to provide an overview of how people are accessing and using the Fundrella Platform. For the avoidance of doubt, Fundrella will not use the Users’ IP-address to collect personal data.
  4. PROCESS OF PERSONAL DATA
    1. In connection with the provision of Fundrella’s services, Fundrella may process the personal data of Users and Others (see categories of personal data under section 3.2 above) in order to fulfill Fundrella’s obligations under the applicable agreement with the User and Others and to make mandatory controls that follow from applicable law. The legal basis for this processing is that it is necessary in order to fulfill Fundrella’s obligations pursuant to an agreement and/or applicable law.
    2. Personal data needed to fulfill contractual obligations towards Fundrella’s contracting parties (representatives at Fund Management Companies/subcontractors) will be deleted within three (3) banking days after Fundrella has fulfilled all of Fundrella’s obligations toward such contracting parties under the applicable agreement and met the counterparty's interests pursuant to applicable laws and agreements.
    3. In some cases, Fundrella may have a legal obligation to process personal data related to Fundrella’s Users and Others. This applies, for example, to the processing of personal data that Fundrella carries out in order to meet the requirements of the Swedish Accounting Act, prevent fraud and carry out risk management. Personal data processed to fulfill Fundrella’s legal obligations will be erased within seven (7) years after Fundrella has fulfilled all of Fundrella’s obligations under the applicable agreement.
    4. Part of the processing of personal data carried out by Fundrella is based on legitimate interests. This, for example, applies to the processing of data regarding potential Users and Others where the purpose is to develop new business opportunities and organize future collaborations where processing is necessary to satisfy Fundrella’s legitimate business interests. Personal data processed employing legitimate interests as legal basis, will be deleted within twelve (12) months after Fundrella has fulfilled all of Fundrella’s obligations under the applicable agreement.
  5. CONSENT
    1. After (and only) after your consent, Fundrella may send information letters to you containing information regarding your selected funds. You may at any time withdraw your consent to Fundrella processing your personal data for marketing purposes by sending an email to support@fundrella.com.
    2. After (and only) after your consent, Fundrella may share your company name (or such company’s name you represent) to Fund Management Companies regarding your choice of favourite fund selection (to be filled in while creating a user account. You may at any time withdraw your consent to Fundrella sharing your personal data for statistics and marketing purposes by sending an email to support@fundrella.com.
  6. SHARING PERSONAL DATA
    1. In order for Fundrella to be able to fulfill its commitments, Fundrella may transfer personal data to third parties. Such a third party can for instance be a service provider of IT-services or plug-ins. Third parties that Fundrella discloses personal data to will only process the personal data for the purposes mentioned in this Privacy Policy. Fundrella has entered into data processing agreements with these third parties. All third parties that Fundrella has entered into a data processing agreement with meet the requirements of applicable data protection legislation.
    2. Fundrella always seeks to process personal data within the EU/EEA but in the event of a transfer of personal data outside the EU/EEA, Fundrella will always observe applicable data protection legislation regarding transfers to third countries. Fundrella will only transfer personal data to a country outside the EU/EEA provided that (i) the third country ensures an adequate level of protection of personal data under a decision issued by the EU Commission, (ii) Fundrella ensures that appropriate security measures are in place according to applicable data protection legislation; or (iii) if any other exception exists under applicable data protection legislation.
  7. SECURITY MEASURES
    1. Fundrella takes appropriate technical and organizational measures to ensure a level of security that is appropriate in relation to the risk and to protect the personal data that Fundrella process against personal data breaches. Only the staff at Fundrella who need access to the personal data necessary to provide Fundrella’s services have been granted access. They are also obliged to observe confidentiality. In the event that a data breach occurs, Fundrella will, as soon as Fundrella becomes aware of it, notify data subjects in writing without undue delay in accordance with the provisions of applicable data protection legislation and report it to the Swedish Data Protection Authority.
  8. RIGHTS
    1. According to the Data Protection Regulation data subjects have the right to:
      1. Request to receive a confirmation from Fundrella about how Fundrella process personal data, and in such case request access to the personal data in the form of an extract from the register.
      2. Correct incorrect or incomplete personal data. Request for correction is sent to Fundrella via the e-mail address below.
      3. Have your personal data deleted in some cases, e.g. if your personal data is no longer necessary for the purposes for which they were collected.
      4. Object to processing that relies on legitimate interests, however only to the extent permitted by applicable data protection legislation.
      5. Receive and transfer personal data to another controller in some cases (data portability).
      6. Lodge complaints regarding the processing to the Swedish Data Protection Authority or other competent supervisory authority within the EU.
    2. When requesting access to your personal data, please contact Fundrella at support@fundrella.com.
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