Privacy Policy
Clever Compliance AB ("us", "we", or "our") operates https://app.ce-check.eu, https://importers.ce-check.eu, https://hub.clevercompliance.io, https://identity.clevercompliance.io,, and other services using the clevercompliance.io and ce-check.eu domains (the "Products").
This policy informs you of our processing of your Personal Data and of your rights in relation to us.
Clever Compliance AB, org.nr 559077-6935, with address Lomvägen 641, 192 58 Solletuna, Sweden, is the controller for the processing of your Personal Data described in this Privacy Policy. That means that it is our obligation to make sure that all processing of Personal Data is carried out in a safe manner and in compliance with applicable laws and regulations. You will find our contact details at the end of this document.
All our processing of your Personal Data is done in compliance with this policy and under current data protection legislation, such as the General Data Protection Regulation (EU) 2016/679 (“GDPR”). Please read this policy before you share any Personal Data with us.
Information Collection – how we collect Personal Data
We collect Personal Data directly from you in a variety of ways, both online and offline, such as
- when you, or a party for which you are a contact person, log into or otherwise use our Products
- when we enter into or perform an agreement with you, or with a party for which you are a contact person;
- when we request or engage you, or a party for which you are a contact person, for services;
- when we request or purchase products from you, or from a party for which you are a contact person;
- when we meet at a. meetings, events, seminars, or fairs;
- when you contact us through a. e-mail, letter, or telephone;
- when you sign up to receive our newsletter;
- when you interact with us in any other way.
With your consent, we will also use cookies and other tracking technology when you use our Products or website (https://ce-check.eu, https://clevercompliance.io) to optimize your experience of these. Please see the below regarding automatic data collection tools for more information about these technologies and your rights in this context.
We may collect data about you from other persons related to your employment, such as a manager or colleague.
We may combine Personal Data collected in one way (such as from our website) with Personal Data collected in another way (such as from meetings).
Automatic data collection tools
We collect data that your browser sends to us when you use our Products. This data includes information such as your computer's Internet Protocol ("IP") address, browser type, browser version, the pages of our Products that you visit, the time and date of your visit, the time spent on those pages and other statistics.
In addition, we use third party services such as Google Analytics which collects, monitors and analyzes data to increase our Products’s functionality. These third party service providers have their own privacy policies addressing how they use such information.
Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer's hard drive. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Products. More information about cookies can be found here.
The Data – What Personal Data we process
The type of Personal Data that we process about you may be:
- Identity information, such as date of birth, age and nationality;
- Contact information, such as name, company name, registration number, VAT registration number, mailing and/or billing address, phone number and e-mail address;
- Employment information, such as job title, role and position, i.e. information regarding your employment or other relationship with the party for which you are a contact person;
- Geographic information, your geographical location;
- Unique user information to our Products, such as login ID, username, password and security question;
- Device information, such as IP address, language settings, browser type, browser settings, time zone, operating system, platform, screen resolution, response time and download error;
- Traffic and usage information regarding the Products, such as which links you click and when, which functions you use and when, how you reached and left the service, session time, session ID and delivery notifications when we contact you;
- Traffic and usage information regarding our website, such as which links you click and when and the address of the website from which you arrived;
We do not process sensitive Personal Data (i.e. special categories of Personal Data) about you.
The Processing – Why and how we process your Personal Data Purposes of, and legal basis for, our processing of your Personal Data
We process Personal Data only to the extent necessary for the purposes described in this Privacy Policy. Should you choose not to provide us with certain Personal Data or limit our right to process your Personal Data, we may not be able to fulfil our obligations to you or to the party you represent. Also, you, or the party you represent, may not be able to assert your rights against us.
The data we process is mainly used to provide, perform, and improve our business and our Products, to enter into agreements and fulfil our obligations and exercise our rights arising from such agreements with you or a party for which you are a contact person.
We save your Personal Data only for the time necessary to fulfill the purposes of our processing or for as long as required by law.
We do not perform any processing that includes automated decision-making (including profiling).
The schematic view
The purposes of our processing of your Personal Data, the categories of Personal Data pertaining to the respective processing, the legal basis for the processing and how long we store your Personal Data are set out below.
| Personal Data | Purpose | Legal Basis | Storage Period |
|---|---|---|---|
Name Address Telephone number E-mail address Employment information | To provide offers on our services, e.g. to create, estimate and provide offers on our services. | If to you personally Take steps at the request of you prior to entering into a contract If to a party for which you are a contact person Our legitimate interest | Until the offer is accepted or denied. Thereafter, necessary data is stored as long as you can take legal action against us. Data is also stored as necessary for a time period required by statutory storage times. |
Name Address Telephone number Geographic Information IP address Log information | To administer, develop and deliver our Products and services, and to provide support for use of the Products. | If to you personally To fulfil the performance of a contract with you If to a party for which you are a contact person Our legitimate interest | During our contractual relationship. Thereafter, necessary data is stored as long as you can take legal action against us. Data is also stored as necessary for a time period required by statutory storage times. |
Name User name Password Geographic Information IP address Traffic and usage information | To administer your account for the Products and your access to the Products. | If to you personally To fulfil the performance of a contract with you If to a party for which you are a contact person Our legitimate interest | During our contractual relationship. Thereafter, necessary data is stored as long as you can take legal action against us. Data is also stored as necessary for a time period required by statutory storage times. |
Name User name E-mail address Telephone number IP address and other device information Geographic Information Traffic and usage information | To improve our Products, our services, and our general business development, e.g. improve the quality of our current services and website, develop new services and features, and to perform customer analyses. | Our legitimate interest | A maximum of 26 months, where the data retention period is reset on new activity. |
Name Address E-mail address Telephone number Employment information | To market and inform about our business and the Products, e.g. to communicate relevant news and information within our practice areas to you, to communicate relevant information about us and our services to you, to inform about present service offers and promote new services closely related to existing services. | If to you personally Our legitimate interest If to a party for which you are a contact person Your consent | During our contractual relationship or your consent. |
Identity information (e.g. name, personal identification number) Contact information (e.g. address, e-mail address) Employment information Information regarding our services used by you or the party you represent. | To comply with applicable legislation or other legal obligations, e.g. obligations arising from our applicable laws, regulations, or similar, such as rules on money laundering, accounting laws and tax legislation. | To comply with legal obligations | For as long as you can take legal action against us. Data is also stored as necessary for a time period required by statutory storage times under, i.a. accounting laws. |
Name Personal identification number Address Telephone number E-mail address Employment information Credit card number Expiration date of credit card Billing address Shipping information | To manage your purchase from us. To manage your payment for a purchase with us. | To fulfil the performance of a contract with you | For as long as you can take legal action against us. For a time period required by statutory storage times under, i.a. accounting laws. |
Name User name Address Telephone number E-mail address Traffic and usage information Information regarding our services used by you or the party you represent. Geographic information | To manage mergers, restructurings, transfers, or business transfers relating to any part of our business. | Our legitimate interest | For as long as necessary to use the information for the purpose specified |
Name User name E-mail address IP address and other device information Traffic and usage information Geographic information | To manage our website, e.g. to optimize your experience of our website, to ensure that relevant content is presented effectively to you and your device. | Your consent (to use of cookies) | A maximum of 26 months, where the data retention period is reset on new activity. |
Legitimate interest
As set out in the schematic view above, we may process your Personal Data because it is necessary for the purposes of our legitimate interests. Our legitimate interest corresponds to the purpose for which we perform each processing based on our interest. Before processing your Personal Data for our legitimate interests, we consider and balance any potential impact our processing of your Personal Data may have on you (both positive and negative) and your rights under the relevant data protection laws. Our legitimate interest does not automatically override your interests and we will not use your Personal Data if our interests are overridden by the impact the particular processing has on you (unless we have your consent or are otherwise required or permitted to by law). We believe that our processing does not disadvantage you in any way and we use your information only in ways you would understand and reasonably expect and which have a minimal privacy impact, or where there is a compelling justification for the processing. In all situations where we process your Personal Data based on our legitimate interests, you have a right to object to that processing. If you wish to do so, please contact us (contact details below). For more information on your rights, please see “Your rights” section below.
Disclosure of your Personal Data
We may disclose your Personal Data to chosen third parties as set out below. In the event of such data sharing or transfer, we will take all reasonable legal, technical, and organizational measures to ensure that your Personal Data is handled in a safe manner at an adequate level of security. Any third party which processes your information on our behalf is bound by a under which such third party shall follow our instructions, take all measures we find necessary, observe confidentiality and respect this Privacy Policy. We may transfer and/or disclose your data to third party countries, e.g. The U.S., with proper measures, such as the EU-US Privacy Shield, to ensure your personal data is well-protected.
We may disclose your Personal Data
- to any of our employees as reasonably necessary for the purposes set out in this policy;
- to any of our insurers, professional advisers, agents, suppliers, subcontractors or business partners as reasonably necessary for the purposes set out in this policy;
- to credit card providers, as necessary for the purpose of charging you for your purchases with us;
- in connection with any legal proceedings;
- to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and to protect the security or integrity of our Products);
- to the extent that we are required to do so by law or a court order.
If we are involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
International Processing
Our servers are located within the EU/EEA. However, your Personal Data may, in some situations, be transferred to and processed by a company which is our supplier, subcontractor, or other business partner and which has its registered office in a country outside the EU/EEA. Any such sharing and processing of Personal Data will be made in compliance with current applicable data protection legislation and we will take all reasonable legal, technical, and organizational measures to ensure that your Personal Data is processed in a safe manner at an adequate level of security.
Security
Your Personal Data is safe with us. So you may feel secure about providing us with your information, we have taken the suitable legal, technical, and organizational measures to prevent unauthorized access, use, change and deletion of your Personal Data. All our processing of your Personal Data complies with current applicable data protection legislation.
Links to third parties
Our Products may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services and we strongly advise you to review the Privacy Policy of every site you visit.
Children's Privacy
We do not knowingly collect personally identifiable information from children under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we process Personal Data of a child without verified parental consent, we shall immediately take steps to remove that information from our servers.
Your Rights
Exercise your rights
Under the current data protection legislation, you have explicit rights which protect your integrity and freedom when others process your Personal Data. Your rights in relation to us are explained below. If you wish to exercise any of your rights you can easily do that by contacting us (see contact details at the end of this document).
Right to access and to information
You have the right to obtain confirmation from us as to whether we process your Personal Data and, if we do, you have the right to access that Personal Data. We will provide one copy of your Personal Data which we process. For any further copies requested, we may charge a reasonable fee based on administrative costs. If you make the request by electronic means, and unless otherwise requested by you, the information will be provided in a commonly used electronic form.
Right to rectification
You have the right to rectification of any inaccurate Personal Data concerning you. If appropriate pursuant to the purposes of the processing, you also have the right to have any incomplete Personal Data completed.
Right to restriction of processing
Under certain circumstances we shall, upon your request, restrict our processing of your Personal Data. Restriction of processing means that your Personal Data will be marked so that future processing is limited to certain given purposes. The right to restriction applies i.a. when you have contested the accuracy of your Personal Data until we can verify the information, and when you have objected to our processing based on our legitimate interests, pending the verification whether our legitimate grounds override yours.
Right to erasure - "Right to be forgotten"
In some situations, we shall erase your Personal Data on your request, for example
- if the Personal Data is no longer necessary in relation to the purposes for which they were collected;
- if the processing is based on your consent and you withdraw that consent;
- if the processing is based on our legitimate interests and you object to the processing and there are no overriding legitimate grounds for the processing;
- if the Personal Data have been unlawfully processed, or
- if the Personal Data must be erased for compliance with a legal obligation.
Under certain circumstances, we cannot immediately erase all your Personal Data. Our continuous processing of your Personal Data can for example be necessary for us to fulfil a legal obligation, such as for bookkeeping and tax purposes, or to establish, exercise, or defend a legal claim. If so, the data will be blocked from use for any other purposes than the ones that hindered immediate erasure of the data.
Right to data portability
You have the right, under certain conditions, to receive your Personal Data which you have provided to us, in a structured, commonly used and machine-readable format, and the right to transmit that data to another controller. When exercising your right to data portability you have the right to have your Personal Data transmitted directly from us to another controller, if technically feasible.
Right to object
At any time, you have the right to object to certain processing of your Personal Data, on grounds relating to your specific situation. The right to object applies e.g. when we process your Personal Data on the basis of our legitimate interests. Where Personal Data are processed for direct marketing purposes, you have the right to object at any time to our processing of your Personal Data for such marketing.
Right to lodge a complaint
If you believe our processing of your Personal Data is not in compliance with the GDPR, you have the right to lodge a complaint with Datainspektionen, which is the supervisory authority in Sweden.
Changes to the Privacy Policy
We may update our Privacy Policy from time to time. Changes to this Privacy Policy are effective when posted on this page. We will notify you of any changes by posting the updated Privacy Policy on this page and you are advised to review our Privacy Policy periodically for any changes.