OUR PROCESSING OF PERSONAL DATA
We value our business relations and think that it is important to communicate with you in a time efficient and swift way. Our standards regarding quality and ethics are strict and we take care not to use the personal data that we collect in a way that might offense you or that exceeds the restrictions of the law. Therefore, we hope that you too agree that there is a good reason for us toll collect and save your personal data so that we can retain our business relation. The collection, storage and use of your personal data is called processing of personal data and may, according to the new General Data Protection Regulation, only be conducted on basis of certain specific legal grounds.
The data that we save about you is used to identify you, contact you, and to fulfill any rights and obligations that we might have towards you or your company in an agreement. This data may also be used to evaluate, develop and improve our services, products and it-systems for our customs in general. We may send you information about our business, such as press releases and information about events of conferences that we arrange or partake in and contact you regarding our business relation or an agreement between us.
If you are not comfortable with us processing your personal data there is more information about what rights you have and how you may exercise them under the headline “What rights do you have in regards to your personal data” below.
WE PROCESS THE FOLLOWING PERSONAL DATA
- We save your name, address, telephone number and email-address as well as your title or your function at work. If you are a service provider providing services to us under an agreement we may also save information that relates to the engagement, such as your CV. We may also add information about you that we find in public registers or social media.
- If we have arranged an event, a conference or other social arrangement we may save photos or films from the occasion, where you might be included, and use this for documentation or for marketing of future events.
- If you’re a resident, or a lease holder of a commercial facility with a private company, in one of our properties we will also collect and process your personal security number, your flat number or the identification code of your lease engagement, and information about your bank, bank account and any credit information used in order to fulfill our legal agreement. If necessary, we will also save information about you in relation to any incoming complaints or investigations that we perform regarding breach of contract etc.
- If you are a representative of an investor, or a potential investor, in one of our investment funds, we will due to regulatory requirements in rules and regulations regarding measures against money laundering and financing of terrorism also collect and process data to understand whether you are 1) a beneficial owner of a company we are doing business with, 2) a politically exposed person that might be subject to bribery or corruption, 3) or has been sanctioned by the EU in the EU’s sanctions lists.
OUR PROCESSING,PURPOSES AND LAWFULNESS
- Contact persons for engagements, agreements or reporting;Our processing of your personal data may be related to you being named as the contact person representing your employer in a business relation with us on basis of an agreement, an assignment or to receive reports. In such a case we will use your name, telephone number, address and/or email-address to take contact with you and your company in order to fulfill our legal obligations or business interests. In these cases, we will assume that your employer has informed you or has obtained the necessary consent from you to use your personal data in this way. Thus, the processing of the personal data is necessary for the performance of the contract.
- Notice of interest;As a property owner we may from time to time offer the public or specific parties the possibility to buy a lease-hold, or to rent an apartment or a facility, in one of our properties. If you have shown an interest, for example at a viewing of a property or through some other contact with us personally, via our websites, or through a mediator, we may save your personal data to be able to get back to you if an occasion should arise to rent or buy such a facility. If you have shown an interest in participating at an event or a conference or other arrangement that we arrange or partake in we might save your personal data to be able to invite you to a future event that we think might be of interest to you. We base our right to process your personal data our on our legitimate interest to service you as requested.
- Forms;When you contact us via our websites for Areim or one of our properties we will save your contact details to be able to answer your questions or provide requested information. We base our right to process your personal data our on the legitimate interest to service you as requested.
- Lease agreements for commercial or residential facilities;If you have signed an agreement for lease of a commercial or residential property in one of our properties we will use your personal data to contact your, provide rent notices, receive rent or fees, and to information you of any activities in the property, or to uphold or fulfill our legal rights and obligations under the agreement. Thus, the processing of the personal data is necessary for the performance of the contract.
- Electronic processing and data protection;We may use personal data to improve our services, protect or enhance our IT-security and to investigate or prevent trespassing or data breaches (e.g. by using cookies or IP-addresses, please see information about cookies). We base our right to process your personal data our on the legitimate interest to service you and our other customers.
- Investigations, complaints, breaches, crimes or litigation;It might happen that personal data about you have to be processed in order ascertain or exercise responsibilities, to investigate possible breaches of contracts or crimes, or to defend our legal rights. We base our right to process your personal data our on the legitimate interest to provide services to you and our other customers.
HOW AND WHEN MAY AREIM SHARE INFORMATION ABOUT YOU TO OTHERS
Areim may share your personal data with our branch office in Finland and our sister companies Areim Advisory (property adviser in Sweden) and Infranode (investment manager with an infrastructure fund in Sweden and branch in Norway), to be able to conduct our business and fulfill our obligations to our clients. In general, we do not share your personal data with parties outside the European Union but try to keep the processing of personal data within the EU/EES area.
- Areim does not sell personal data or other information about our relations to third parties.
- Personal data processed within the IT-systems that we use to provide our services may be shared with IT-service providers outside EU/EES. This processing will in such a case be necessary to ensure our interests of providing qualitative and reliable services with secure techniques to you. We will ensure in agreements that the provider uses adequate security measures to protect your personal data.
- If you are a tenant in one of our properties, of a lease-holder, your personal data will be shared with our accounting firm, with payment service provider, with the property manager, and as necessary any maintenance providers, as well as with our administrator Newsec. In case of litigation, legal processes or other circumstance that might require outside advice, the personal data may also be shares with a legal firm, an authority or other relevant party.
- We may also share personal data with authorities acting on their own mission in accordance with laws or authority decisions, for example Finansinspektionen, Datainspektionen, the courts, the tax authority or the police.
HOW LONG DO WE SAVE PERSONAL DATA
Areim AB is a licensed alternative investment funds manager (fund management) under the supervision of Finansinspektionen. This means that all information about or business, our services, business relations, clients etc. must be archived and retained for at least five (5) years, however, even longer archiving may be necessary. When the information is no longer necessary we will delete it.
- General contact information shall be deleted when no longer needed, and at least every other year, unless it needs to be saved on basis of any of the reasons stated below.
- Notices of interest will be deleted when they are no longer applicable, or if you withdraw your notification.
- Should the personal data be collected on basis of the Know Your Customer rules in the regulations for measures against money laundering and financing of terrorism the personal data will be saved for at least five (5) years. If the individual that the data belongs to has been subject to an investigation, in which case we are prohibited to inform the individual of this, it will have to be save for ten (10) years.
- The requirement to retain information regarding our fund management may mean that we are prevented to dispose personal data on you before the five years have elapsed since collection if it is needed to fulfil rights and obligations under an agreement, or if they are subject to specific regulatory requirements.
- Information needed for accounting and book keeping shall be saved in accordance with the Accounting Act for at least seven (7) years.
- Information needed for investigations of incidents, non-compliance issues, and suspicion of criminal behavior in, or in relation to, our property may be processed as necessary for the establishment, exercise or defense of legal claims for two years, unless a legal process already underway requires a longer retention. Notifications of violations or suspicion of criminal behavior etc. may only be stored as long as Areim is in its right to act. After the end of these periods any personal data shall be deleted.
WHAT RIGHTS DO YOU HAVE IN REGARDS TO YOUR PERSONAL DATA?
Your rights include a right to know what personal data on you that we process, and you have a right to object or restrict the processing. You also have a right to correct or complete it, or in some cases to have it erased, or to be transferred to another party. And you have a right to file a complaint.
If we have obtained the personal data through your explicit consent you have a right to, at any time, withdraw that consent. We will then erase it, unless there is some other legal basis for our right to process the personal data, for example a legal agreement between us, that makes it necessary for us to keep it.
EXERCISING YOUR RIGHTS
- Should you have any questions concerning your right or wish to exercise any of them you are most welcome to contact us on email@example.com and we will help you as best we can. Please note that you must be able to identify yourself to be able to exercise your rights.
- We will process your question and/or request without undue delay and answer no later than one (1) month after we have received it and we will inform you of the measures we have taken to in relation to your question or request.
- If your request is complicated or comprehensive the time frame may be extended with up to two (2) months but in such a case, we will inform you about the delay and the reason for it.
- Should a request be unfounded or unreasonable Areim is entitled to refuse to take any action, or to levy a reasonable fee for the processing of the request.
- Should you be unsatisfied with our processing of your personal data or any request you have the right to file a complaint against Areim with Datainspektionen that is the supervisory authority for data protection rules.
HOW DO WE PROTECT YOUR PERSONAL DATA?
Areim applies both technical and organizational measures to protect your personal data against unlawful access and loss. Specific authorization and/or technical authentication is required to process and/or move personal data within Areim or to external, authorized, party.
Areim AB, org. nr 556719-4203, Norrlandsgatan 18, 114 43 Stockholm is the controller of the personal data processing as described above. This means that we are responsible for ensuring that the personal data is processed correctly and in accordance with applicable data protection laws.