GDPR
PRIVACY
- BACKGROUND
WOW Apartments AB, org. Nr. 556759-4204, (“WOW”) is a limited liability company that delivers temporary housing solutions, preferably to companies and private individuals. Within WOW’s business, various personal data are processed. It is of the utmost importance that all such processing be carried out in a correct manner which does not risk infringing the personal integrity of the person whose personal data is being processed. WOW shall in all cases ensure that personal data is processed in a lawful and correct manner, and that all persons who process personal data on behalf of WOW have the qualifications and knowledge required for processing such data. This personal data policy (the “Policy”) contains rules and guidelines for the processing of personal data made by WOW in the capacity of personal data controller and personal data assistant, regardless of what type of personal data it is about and whose personal data it concerns. The purpose of the policy is to increase knowledge within the WOW regarding the content of the European Parliament and Council Regulation 2016/679 of 27 April 2016 (the “Data Protection Regulation”) and to ensure that WOW fulfills its obligations under the Data Protection Regulation.
- WHAT, WHY AND HOW LONG DO WE TREAT?
2.1 General
WOW collects and processes personal data in the areas and functions listed below. In several cases when we request personal data, we do so in order to fulfill statutory or contractual requirements or requirements that are necessary to enter into an agreement with, for example, an employee, a customer or a supplier. In cases where the data subject does not provide the information we request, it may in certain cases mean that we cannot enter into an agreement or fulfill our obligations in an agreement with the data subject. Below you will find in sections 2.2, 2.3, 2.4, 2.5, 2.6 and 2.7 the areas in which WOW processes personal data. In connection with the respective area, the objectives and the legal basis for the treatment, who receive the data and the storage period, etc., are also stated.
2.2 Employees
What is the legal basis for the treatment? Employees’ personal information is collected and processed to (a) fulfill obligations under law, (b) collective agreements and / or for the conclusion and fulfillment of individual agreements. What personal data is processed and who is the recipient? Personal data processed are mainly names, social security numbers, telephone numbers, bank details, documentation for remuneration and benefits, address, information about related parties, qualifications, experience and development, absence, illness and possible rehabilitation. Those who receive the information are HR manager, managers, IT, sales manager, finance department and internal or external actors who administer wages and other benefits as well as authorities when required. For what purposes is the personal data processed? The employee’s personal data is required, among other things, for the following purposes: salary payment, commission calculation, salary audit and other remuneration and benefits, general personnel administration, time reporting, board fees, maintaining emergency and disaster planning, contacting relatives in connection with incidents / accidents concerning the employee, providing occupational health services , holidays, administering employment benefits (including pensions, life insurance and health care insurance), maintaining disease and absence documentation for calculating sick pay and participation in rehabilitation investigations in accordance with the Work Environment Act, deciding on the suitability of certain work, enabling evaluation and review of performance ( including information on performance and other assessment information and development interviews with the employee) and also more generally to ensure fulfillment of legal obligations (incl. insecure, but not limited to, income tax and social security legislation and all relevant labor law, such as to comply with the ordering rules that apply in the event of termination or to issue employer certificates). In addition, data on persons and bonuses are treated for statistical purposes intended for Statistics Sweden or the Confederation of Swedish Enterprise. How long will the data be stored? WOW never stores information beyond what is necessary for the purposes of the treatment. WOW therefore carries out regular delays among personal data and removes the information that is no longer needed. When a job ceases, there is no reason to save it for the job. personal data of employees. This includes the employee’s email account and the employee’s information on the WOW website. In such cases, grating shall take place as soon as possible after termination of employment. However, there are important exceptions to this. In order to fulfill its obligations in accordance with labor law, tax law and social security law, Corporate Housing needs to save certain information about the employee even during a period after the termination of the employment. For example, data must be saved to fulfill legal obligations regarding taxation or accounting, obligations regarding the employee’s preferential right to re-employment in law (1982: 80) on employment protection and to handle legal requirements that may be directed against WOW. It is sometimes also required that information is retained for the payment of, for example, pension or severance pay. In these exceptional cases, data are stored for 2 years and 10 years respectively (concerning accounting, taxation and limitation periods). We may also deal with data in connection with employee surveys. Such investigations are carried out in order for WOW to be able to identify deficiencies and then be able to work with and ensure a better working environment. In these cases, automated decision making, including profiling, may occur. Some of the personal data that WOW handles as a result of the employment may constitute sensitive information. These include illness or union affiliation. See more about WOW’s handling of sensitive data under 2.8 below.
2.3 Consultants
What is the legal basis for the treatment? In order to fulfill legal obligations or to be able to enter into and fulfill consultancy agreements, WOW may need to collect individual consultants’ personal data. What personal data is processed and who is the recipient? Personal data processed by WOW include name, social security number, address, e-mail address, telephone number, bank account number, bank and postal giro number, information about qualifications, documentation for calculation of fees, experience etc. and information about absence and also contact information to the individual consultant’s manager. Those who receive the information are mainly relevant managers, HR-responsible, any external actors who administer payments of fees etc. and authorities when required, etc. For what purposes is the personal data processed? The consultant’s personal information may be required, inter alia, for the following purposes: payment of consulting fees and other remuneration, general administration of consulting services, maintaining emergency and disaster planning, maintaining control systems, maintaining absenteeism documentation for consulting fees, deciding on the appropriateness of certain services and assignments, enable evaluation and review of performance and also more generally to ensure fulfillment of legal obligations. How long is the personal data stored? WOW never stores information beyond what is necessary for the purposes of the treatment. WOW therefore carries out regular thinning of stored personal data and removes the information that is no longer needed. In general, personal data should not be retained after the consulting assignment has been completed. However, it may be necessary for WOW to save the data for a longer period after the assignment has ceased to fulfill legal obligations regarding taxation, accounting or to handle legal requirements that may be directed against WOW. In these exceptional cases, the storage period is a maximum of 10 years from the termination of the consulting assignment.
2.4 Recruitment
What is the legal basis for the treatment? In order for WOW to be able to handle applications submitted by the data subjects, conduct interviews and make decisions in a recruitment procedure, WOW must process certain personal data. The basis for this treatment is balance of interests, or agreements. What personal data is processed and who is the recipient? Personal data processed by WOW include name, date of birth, address, information about experience and skills, possibly photography etc. In these cases, automated decision making, including profiling, may occur. Those who receive the information are mainly HR managers, managers and hired recruiting companies. In cases where recruitment companies handle the recruitment, personal data assistance agreements are always established with the external operator, please see below under section 3.2 on WOW’s procedures for this. For what purposes is the personal data processed? 4 In order for WOW to be able to handle applications, interviews and decision-making in a recruitment process, we collect and process personal data. How long is the personal data stored? WOW never stores information beyond what is necessary for the purposes of the treatment. Corporate housing therefore carries out regular thinning of stored personal data and removes the information that is no longer needed. However, WOW may need to store the personal data after the recruitment procedure is completed if we consider it necessary to save them in order to handle legal requirements that may be aimed at WOW. The storage period is therefore 2 years.
2.5 Customers
What is the legal basis for the treatment? Our main customer group is business travelers, ie. companies in need of temporary housing solutions for their staff and their families. Our services are also offered on a small scale to private individuals. The information below concerns the processing of personal data by our customers in general, ie both customers and individuals and representatives of our corporate customers. Please refer to section 2.7 for information on how we treat personal data originating from the relevant guests (ie private persons living in our apartments or houses). In order to be able to enter into and manage agreements with our customers, WOW deals with personal data of persons who are representatives of our customers. The legal bases for processing personal data in this way are therefore necessary to either be able to fulfill agreements or to make use of WOW’s interests. Some personal data may also be processed because WOW has a legal obligation to do so, for example personal data on invoices as a result of the accounting obligation. What personal data is processed and who is the recipient? We treat personal information regarding representatives on companies with which we have customer agreements. Personal data processed can include names, telephone numbers, e-mail, social security number and copy of ID / driver’s license. We can also process names and social security numbers for creditors linked to the customer agreements. We can also process personal data regarding preference on companies that are potential customers. Personal data processed can include names, telephone numbers, addresses and e-mails. Those who receive the information are mainly persons relevant to the agreement in the sales department, the finance department, the marketing department, managers and contract administrators. Helpdesk and technicians may also receive the information. For what purposes is the personal data processed? For those cases where there is an existing customer agreement, WOW only processes personal data that is relevant to the customer relationship and that is required for the performance of the agreement. Personal data such as the name of the representative, e-mail and telephone number are processed in order to be able to largely administer the customer agreement and to be able to hold a dialogue with the customer, when it is relevant, to be able to perform inspections / displays or to gain access to current apartments or houses. Personal data such as social security number or driver’s license are treated only if needed to administer invoicing credit rating or the like. The personal data of representatives can also be processed for the purpose of sending interesting offers and advertising to the customer company. However, the representative is entitled at any time to object to the processing of personal data for direct marketing, see point 5.4 below. For the cases WOW deals with personal data regarding representatives of potential customers, this is done in order to contact the customer in order to be able to provide the customer with interesting offers and information via telephone, e-mail or to administer the booked meetings. As stated in paragraph 5.4, the representative always has the right to object to treatment for direct marketing. How long is the personal data stored? WOW never stores information beyond what is necessary for the purposes of the treatment. WOW therefore carries out regular thinning of stored personal data and removes the information that is no longer needed after the customer relationship has ceased. However, WOW may need to store the personal data after the customer relationship has been terminated, among other things to administer any guarantees and deadlines for claims, handle legal requirements that may be directed against WOW or to market services and send offers that WOW believes may be of interest to our former. customers. Exceptionally, personal data is therefore saved for some time after the termination of the customer relationship or until the person objects to direct marketing. Personal data relating to representatives of potential customers is removed when the dialogue with the customer ceases, provided that no customer relationship has been initiated, or directly if the person objects to direct marketing. Personal data may also need to be stored more generally in order to ensure compliance with legal obligations, for example regarding accounting. If such an obligation exists, the personal data can be saved for up to 7 years.
2.6 Suppliers
What is the legal basis for the treatment? In order to be able to enter into and manage agreements with suppliers, WOW deals with personal data of persons who are representatives of the suppliers. Some personal data may also be processed because WOW has a legal obligation to do so, for example personal data on invoices as a result of the accounting obligation. What personal data is processed and who is the recipient? We treat personal data regarding representatives on supplier companies that we have or intend to enter into with. Personal data processed can include names, telephone numbers, e-mail, address and professional title. Those who receive the information are mainly WOW’s purchasing department, responsible manager, CEO, finance department and IT department. For what purposes is the personal data processed? WOW deals with the personal data in order to generally be able to administer purchase agreements, manage invoices and to be able to ask questions to the supplier WOW may have regarding the goods or services we buy. How long is the personal data stored? WOW never stores information beyond what is necessary for the purposes of the treatment. WOW therefore carries out regular thinning of stored personal data and removes the information that is no longer needed after the contractual relationship has ended. However, WOW may need to store the personal data after the contractual relationship has been terminated, among other things to administer any guarantees and deadlines, handle legal requirements that may be directed against WOW. Exceptionally, personal data is therefore saved for 2 years from the termination of the contractual relationship. Personal data may also need to be stored more generally in order to ensure compliance with legal obligations, for example regarding accounting. If such an obligation exists, the personal data can be saved for up to 10 years.
2.7 Guests
What is the legal basis for the treatment? In order to be able to sign and complete the agreements with our customers referred to in section 2.5 above and to ensure that we offer services in accordance with the customer’s needs and wishes from the individual guest who lives in our apartments, WOW must treat certain limited personal data regarding these guests. The legal bases for processing personal data in this way are therefore necessary either in order to be able to fulfill agreements or to use WOW’s interests. Some personal data may also be processed because WOW has a legal obligation to do so, for example personal data on invoices as a result of the accounting obligation. What personal data is processed and who is the recipient? The company deals personal information related to names, family members, e-mail address, telephone number, address, arrival and departure dates, keys, passports and / or ID numbers, information on special needs such as disability, home help and pets or other preferences or complaints provided by the guest us information about. Personal information that the guest gives us by participating in a voluntary guest examination can also be treated. The main recipients of the personal data are the company’s customer service and booking department, responsible managers, CFO and IT department. If applicable, we may need to share your personal information with external actors who help us with housing management, including for example. cleaning service, property management and key delivery. For what purposes is personal data processed? Personal data such as names, e-mail addresses and guest phone numbers are processed to administer the accommodation and to be able to hold a dialogue with the guests (eg key releases, questions, complaints, impressions, etc.). Personal information such as disability information, home help, pet or other information is processed when provided by the guest (or indirectly through the customer booking) to ensure that all needs and wishes are met and, consequently, to ensure the best possible experience for the guest. Personal information such as social security number, passport or ID is only processed if it is necessary to administer invoicing, credit reporting and similar activities. The personal data collected through our voluntary guest surveys is collected to optimize and improve our services. How long will the data be stored? WOW does not store personal data beyond what is necessary in relation to the purpose for which the data was processed. Therefore, WOW regularly performs caching of stored personal data and deletes information that is no longer necessary after the termination of the contract period and stay. WOW may need to store personal data for some time even after the end of the stay in the apartment provided by us, if such storage is necessary to administer any warranties and limitation periods of complaint or to handle any legal claims against WOW. Exceptionally, personal data can be stored for up to two years after the end of the guest’s stay in our apartment or house. It may also be necessary for WOW to store personal data in general, for example, to comply with legal obligations regarding accounting. If such obligations exist, the personal data may be stored for up to seven years. Some of the personal data that the company deals with current guests can be considered as sensitive personal information. Such sensitive data can, for example, be personal data related to health, which can be treated to meet the guests’ special needs. See section 2.8 below for more information on WOW’s processing of sensitive data.
2.8 Particularly about sensitive data
With sensitive information, the policy refers to personal data that reveal racial or ethnic origin, personal opinions, religious or philosophical beliefs, or membership of the trade union and the treatment of genetic data, biometric data to uniquely identify a natural person, health information, or physical information person’s sexual or sexual orientation. WOW never handles sensitive information without the consent of the data subject or without the existence of any support provided for in Article 9 of the Data Protection Regulation, for example, in order to fulfill obligations or exercise special rights in labor law, social security and social protection or when treatment is necessary to protect it If the data are already published by the data subject, if the data are already published by the data subject, if the data is necessary in view of an important public interest, if necessary, in the general interest, if it is necessary for reasons related, inter alia, to the assessment of workers’ work capacity or the provision of health care or if necessary for statistical purposes. In every processing of sensitive data, Corporate Housing always takes appropriate security measures to protect the data. Personal data is never available to more people than is necessary. This applies both when WOW acts as personal data controller and personal data assistant.
- HOW DO WE PROVIDE PERSONAL DATA?
3.1 General
When WOW collects, processes and stores personal data, this shall in any case be done in a legal, correct, transparent and appropriate manner and only to the extent that WOW considers it necessary. WOW shall consistently process personal data in a manner that avoids violating the data subject’s personal integrity. In all cases of personal data processing, WOW is very careful that personal data is protected by appropriate security measures. WOW can process personal data either by collecting and processing the data independently and for its own account or on behalf of other companies. WOW can thus act as personal data controller but also in some cases as a personal data assistant. In some cases, WOW is the joint data controller with another player. In several cases when we request personal data, we do so, as mentioned above, in order to meet statutory or contractual requirements or requirements that are necessary to enter into an agreement with an employee. If the data subject does not provide the information requested by WOW, it may in certain cases mean that we cannot enter into an agreement or fulfill our obligations in an agreement with the data subject. If the data subject feels doubtful or worried about providing a certain personal information, he / she can contact WOW (see below under Contact information), and we can provide the registered additional information.
3.2 WOW shares information with external party WOW may, from time to time, need to submit information to relevant third parties (including, but not limited to, situations where we have a legal obligation to do so). In order to ensure that your personal data is processed in a safe and secure manner, WOW has as a routine to establish agreements (assistance agreements or the like) with each external party that processes personal data on behalf of WOW. In such agreements, the subject of the treatment is always stated, the duration of the treatment, the nature and purpose, the type of personal data and categories of registered persons, as well as our obligations and rights as the data controller. Furthermore, WOW always gives documented instructions to the personal data assistant, which the personal data assistant is obliged to follow.3.3 Transfer of personal data outside the European Economic Area (“EEA”)
To administer our business and the personal data processed there in an efficient and organized manner, WOW uses a computer system provided by an external service provider. The information that WOW registers or enters into such a system will normally be stored on the service provider’s servers. These servers may be located outside the EEA, for example in the US. In order to ensure complete security and protection of the personal data that WOW deals with in this system, WOW always ensures that any data transfer outside the EEA is subject to sufficient security measures and that no transfer is made to a site not covered by the appropriate level of adequate protection. As stated in section 3.2, WOW always includes assistance agreements with its data processors.
3.4 WOW as personal data assistant
In any case where WOW is a personal data assistant, WOW must enter into a personal data support agreement with the personal data controller. It is the personal data controller who determines, for example, purposes and storage times for the personal data. When WOW is a personal data assistant, the personal data is therefore always processed in accordance with the personal data support agreement and in accordance with the personal data controller’s instructions. If Corporate housing is uncertain about the meaning of the instructions or the scope of the responsibility, WOW as a routine to request clarification from the personal data controller WOW always ensures that the personal data is protected by appropriate security measures and that access to the personal data is only given to a limited circuit within WOW’s activities that really need access to them. in their work. As stated in Chapter 5 below, the registered person has the right to, among other things, access and correction of personal data. In such cases, the data subject is recommended to contact the appropriate contact person at the personal data controller in the first instance and first, in the second instance, contact the personal data representative at WOW, see contact information in chapter 6 below.
- WHAT HAS IT REGISTERED FOR RIGHTS?
5.1 Inquiries or questions from a registered person
The items below show the rights of the data subject, with regard to personal data. If a registrar contacts an employee of WOW with inquiries or questions regarding personal data, the employee must immediately contact WOW’s data protection staff and inform the official about the registrant’s inquiries or questions. Contact details for the company’s data protection personnel can be found in section 6 below.
5.2 Right to access
The data subject has the right to turn to WOW as the personal data controller and request access to the personal data that WOW processes and also be informed about the purposes of the processing and who received the personal data. WOW, as personal data controller, shall provide the data subject with a free copy of the personal data processed. In case of extra copies, WOW may charge an administration fee.
5.3 Right to correction, deletion or limitation
The data subject has the right, without undue delay, to have his or her personal data corrected or, under certain conditions, limited or deleted. If the registrant considers that WOW processes personal data about the one that is incorrect or incomplete, the data subject may demand that these be corrected or supplemented. The data subject also has the right to have his / her data deleted, for instance if they are no longer necessary or if the treatment is based on consent and this has been revoked. If the data subject requests that the data be corrected, deleted or restricted in processing, Corporate Housing, as a personal data assistant, has a routine to inform each recipient of the personal data of the data subject’s request with reasonable effort.
5.4 The right to object
The data subject is entitled at any time to object to the processing of his personal data if the legal basis for the processing consists of a public interest or weighing of interest according to Article 6.1 (e) and (f) the Data Protection Regulation. The data subject also has the right to object at any time to the processing of his personal data if these are processed for direct marketing.
5.5 Right to data portability
The data subject has the right to obtain the personal data that he has provided to the Data Protection Officer and has the right to transfer these data to another person responsible for personal data. This applies, however, provided that it (a) is technically possible and (b) the legal basis for the treatment is consent or that the processing has been necessary for the performance of the contract. The items below show the rights of the data subject, with regard to personal data. If a registrar contacts an employee of WOW with inquiries or questions regarding personal data, the employee must immediately contact WOW’s data protection staff and inform the official about the registrant’s inquiries or questions. Contact details for the company’s data protection personnel can be found in section 6 below.
5.6 Right to withdraw consent
If the processing of personal data is based on the data subject’s consent, he or she has the right to withdraw this consent at any time. Such revocation does not affect the legality of the personal data processing before the consent was revoked.
5.7 Rights during profiling
The data subject is entitled not to be subject to decisions based solely on automated processing, including profiling, and which may have legal consequences or equivalent for the data subject. This does not, however, apply (a) if such processing is necessary for the conclusion or performance of contracts with the data subject, (b) if such processing is permitted by applicable law or (c) if the legal basis is the consent of the data subject.
5.8 Right to complain to the Data InspectorateThe data subject has the right to address complaints to the Data Inspectorate.
Contact details
Phone number: 08-657 61 00
Email address: datainspektionen@datainspektionen.se
- CONTACT DETAILS
If you have any questions about the policy or other requests regarding personal information, please contact WOW’s personal data representative.
Contact details
Name: Cecilia Hobik
Phone number: 0708 – 80 11 58
Email address: cecilia@wowapartments.se
- CHANGES TO POLICY
WOW reserves the right to change and update the Policy. In the event of material changes to the Policy or if existing information is to be processed in other ways than what is stated in the Policy, WOW will inform this in an appropriate manner.