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Data privacy is of high importance for Turnpike and we want to be open and transparent with our processing of your personal data. We, therefore, have a policy setting out how your personal data will be processed and protected. Who is the controller of your personal data?
The Swedish company, TRNPK Sweden AB (“Turnpike”), is the controller and responsible for your personal data under applicable data protection law.
Where do we store your data? The data that we collect from you is stored within the European Economic Area (“EEA”) but may also be transferred to and processed in a country outside of the EEA. Any such transfer of your personal data will be carried out in compliance with applicable laws. For transfers outside the EEA, Turnpike will use Standard Contractual Clauses. Who has access to your personal data? Your personal data may be shared within Turnpike Group. We never pass on, sell or swap your data for marketing purposes to third parties outside Turnpike Group.
Turnpike Group company will only act as the personal data processor and processes the personal data on behalf of the Swedish company.
Personal data that is forwarded to third parties, is only used to provide you with our services. You will find what categories of third parties there are under each specific process below.
What is the legal ground for processing? For every specific processing of personal data we collect from you, we will inform you whether the provision of personal data is statutory or required to enter a contract and whether it is an obligation to provide the personal data, and possible consequences if you choose not to. What are your rights?
Right to access: You have the right to request information about the personal data we hold on you at any time. You can contact Turnpike which will provide you with your personal data via e-mail.
Right to portability: Whenever Turnpike processes your personal data by automated means based on your consent or based on an agreement, you have the right to get a copy of your data transferred to you or another party. This only includes the personal data you have submitted to us. Right to rectification: You have the right to request rectification of your personal data if they are incorrect, including the right to have incomplete personal data completed. Right to erasure: You have the right to erase any personal data processed by Turnpike at any time except for the following situations for exercising the right of freedom of expression and information to comply with a legal obligation for the establishment, exercise, or defense of legal claims, Your right to object to processing based on legitimate interest: You have the right to object to the processing of your personal data that is based on Turnpike's legitimate interest. Turnpike will not continue to process the personal data unless we can demonstrate a legitimate ground for the process which overrides your interest and rights or due to legal claims. Your right to object to direct marketing: You have the right to object to direct marketing, including profiling analysis made for direct marketing purposes. You can opt out of direct marketing by following the instruction in each marketing mail. Right to restriction: You have the right to request that Turnpike restricts the process of your personal data under the following circumstances: if you object to processing based on Turnpike's legitimate interest, Turnpike shall restrict all processing of such data pending the verification of the legitimate interest. if you have claimed that your personal data is incorrect, Turnpike must restrict all processing of such data pending the verification of the accuracy of the personal data. if the processing is unlawful you can oppose the erasure of personal data and instead request the restriction of the use of your personal data. if Turnpike no longer needs the personal data but it is required for you to make or defend legal claims. How can you exercise your rights?
You can contact us at firstname.lastname@example.org. Right to complain with a supervisory authority: If you consider Turnpike to process your personal data in an incorrect way you can contact us. You also have the right to turn in a complaint to a supervisory authority. Updates to our Privacy Notice: We may need to update our Privacy Notice. The latest version of the Privacy Notice is always available on our website. We will communicate any material changes to the Privacy Notice, for example, the purpose of why we use your personal data, the identity of the Controller, or your rights.
Business Relations Why do we use your personal data? We will use your personal data to evaluate potential business partners and manage existing business relations including communication, procurement, contract signing, and financial transactions. We will process your personal data to achieve the purpose of the contract.
We will also use personal data to provide business partners with access to Turnpike´s systems.
We will use personal data to manage legal requirements for financial trading information.
We will process your personal data in case of legal issues and disputes.
What types of personal data do we process? We will process the following categories of personal data: contact details such as name, e-mail address and telephone number, date of birth social security ID usernames, bank account, nationality, work-related information, such as company, department, and work role, photo, and images. Who has access to your personal data? Your personal data that is forwarded to third parties is only used for the purposes mentioned above. We share your personal data with external advisors, IT service providers, and other external service providers. What is the legal ground to process your personal data? The processing of your personal data for the following purposes are based on Turnpike’s legitimate interest: to manage business relations to provide business partners access to our systems to manage legal requirements for financial trading to manage legal issues and disputes. The processing of your personal data to achieve the purpose of the contract are necessary for the fulfillment of a contract. The processing of your personal data for financial trading information is based on legal obligations. How long do we save your data? We will keep your data for follow-up and to evaluate procurement and business partners, for the length of the agreement and time to preclude legal issues. For legal disputes, we will keep the data during the ongoing dispute and for a period of time after the dispute when the information is still relevant.
We will keep the data for financial trading information for 5 years in accordance with legal requirements.
Media and Communication Why do we use your personal data? When we create media content such as articles, interviews, videos, and pods for all our channels we will process your personal data if you appear in such content. We also use personal data to prepare, facilitate, follow up on interviews and media coverage. When we archive media material such as press clips, images and photos, campaigns, press releases, videos, and recordings to preserve the company's history your personal data will be processed if you appear in the material.
To manage different types of events, including meetings and press conferences, we will process personal data of the invited persons. Certain events may be recorded and transcribed.
We will use your personal data to send out financial reporting and other company information to recipients based on legitimate interest.
We will use your personal data to manage the use of press samples.
If you contact us for information requests we will process your personal data.
What types of personal data do we process? We will process the following categories of personal data: contact details such as name, e-mail address and telephone number, date of birth, user name, nationality, work-related information, such as company, country of employment and work role, photo and images, video and audio recording. What is the legal ground to process your personal data? The processing of your personal data for the following purposes are based on Turnpike Group’s legitimate interest: managing content, including producing, administrating, archiving, and distributing media content, managing press conferences and meetings to analyze media coverage, including social media, managing press samples to manage requests to manage events. The processing of your personal data for a teleconference is based on your consent. If you have signed up to receive company information the processing of your personal data is based on your consent. How long do we keep your data? We save your data if needed to fulfill the purpose for which it was collected to pursue our legitimate interests or until there are no longer any legal requirements or rights for us to keep the data.For the processing of personal data for purposes based on the consent, we will keep the data until you withdraw your consent.
Your right to object to processing based on legitimate interest You have the right to object to the processing of your personal data that is based on Turnpike's legitimate interest. Turnpike will not continue to process the personal data unless we can demonstrate a legitimate ground for the process which overrides your interest and rights or due to legal claims. Your right to withdraw your consent You have the right to withdraw your consent from the processing of your personal data at any time. When you do so we might not be able to provide you with the service based on the consent.
IT & Security Why do we use your personal data? We will process personal data to manage, register and resolve IT and information security incidents. We will also use personal data to handle incidents and accidents. We will also process your data to investigate a breach or non-compliance with regulations or Turnpike's policies and requirements.
We will use your personal data for camera monitoring in our facilities such as stores, offices, and warehouses for security reasons and follow-up on incidents and accidents.
In order to be compliant with payment card industry regulations, your personal data will be processed through visitor logs and audit reports for audit reasons.
We will also process your personal data related to follow-ups on incidents and accidents.
In the event of an investigation of non-compliance with our policies and whistleblowing related matters we process personal data.
What type of data do we process? We will process the following categories: contact information such as name, home address, e-mail address and telephone number, date of birth, work information such as company name and work role, employment information such as user ID number, IP number, video surveillance, footage, photo, other necessary information for investigations. Who has access to your personal data? Data that is forwarded to third parties is only used to perform the services mentioned above. We will share your personal data with security companies, auditors, and legal advisors to handle security issues and administration. We will also share your personal data with video surveillance companies for video footage. What is the legal ground to process your personal data? The processing of your personal data is based on Turnpike our legitimate interest for us to manage incidents and security breaches. How long do we save your data? We will keep your data for the time we need to prevent and/or report potential fraud and other offenses. Video footage will be saved in compliance with local legislation but for a maximum of 30 days.