Jetpak Privacy Statement

1. General

2. Data controller

3. Our processing of your personal data

4. Where we collect your personal data from

5. Automated decision making

6. For how long do we retain your personal data

7. With whom we share your personal data?

8. Where do we process your personal data?

9. Your rights

10. We protect your data

11. Cookies

12. Amendments to this privacy statement

14. Contact information

1 GENERAL

1.1 Jetpak Group AB, reg. no. 556415-6650 (“Jetpak”) respects and cares about your personal integrity. We want you to feel safe when we process your personal data. By way of this privacy statement (“Privacy Statement”), we want to inform you about how we ensure that your personal data is processed in the right way.

1.2 To be able to provide you, as a customer of ours with our services or you, as a potential customer of ours with offers of our services, we must process personal data about you. This Privacy Statement applies to you who:

- Order services from us,

- Have entered into agreement with us,

- Have been in contact with our sales personnel or customer service, or

- Have filled in the contact form or other form at our website.

2 DATA CONTROLLER

Jetpak is the data controller for the processing of your personal data and is responsible for ensuring that the processing is made in compliance with applicable law. You will find our contact details at the last page of this Privacy Statement.

3 OUR PROCESSING OF YOUR PERSONAL DATA

3.1 At Jetpak, we process your personal data to provide services and offers of our services in the best way possible.

We therefore use your personal data for the following purposes:

- Administration and fulfilment of agreement and safeguarding our legal interests in case of a dispute,

- Marketing, including customer adapted advertising,

- Method and business development,

- Sales activities and customer service,

- Administration in connection with company take-over, restructuring of Jetpak etc., and

- Fulfil our legal obligations and take measures against crime.

3.2 In the tables below, you are provided with more information about e.g. why we process your personal data, what personal data we retain to achieve the purposes of the processing and for how long we retain your personal data.

Purpose:
Administration and fulfilment of agreement and safeguarding our legal interests in case of a dispute

Personal data:
Contact details such as name, address, personal identification number (in case of a private customer), telephone number and email-address.Order and payment details such as purchase and transaction history and payment information.Login details such as user name and email address.

What we do:
We process your personal data to deliver, administrate and adapt our products and services and to provide you with customer services as a user.

In case of a dispute, e.g. regarding payment, we have the right to process your personal data for the purpose of defending, establishing or exercising a legal claim.

Legal basis:
Performance of a contract.
In case of a dispute, we are entitled to process your personal data with legitimate interest as legal basis.

Retention period:
Your personal data is retained for the duration of the contract period and up to 36 months thereafter, after which your personal data is anonymised.

Your personal data may be retained for longer if they are necessary to defend, establish or exercise a legal claim, e.g. regarding payment.

Your rights:
You have the right to object to processing of your personal data based upon a legitimate interest as legal basis. If you object to such processing, we will continue with the processing only if there is a compelling legitimate basis for the processing that outweighs your interest, fundamental rights or freedoms. Please see section 9 if you want to read more about your rights.

Purpose:
Marketing, including customer adapted advertising

What we do:
We process your personal data within the scope of our marketing efforts.

If you wish to take part of customer adapted offers and information regarding news and contests specifically addressed to you, e.g. offers regarding especially beneficial service packages, we need your consent. We send you information as a new customer where you have the possibility to subscribe to our newsletter and give your consent for email communication. You can also subscribe to our newsletter on various places on or website and in conjunction to a booking.

We will also analyse your browsing habits on our website and grade your visits and submitted forms to enable us to determine your interest level.

Legal basis:
Legitimate interest when consent is not required by law, as we assess that our interest in sending you general marketing is important for our business.

Consent when marketing our products and services by way of email, SMS, MMS and other automatic systems.

Retention period:
If you are a customer of ours:

Your personal data is retained and processed for the duration of the contract period, i.e. until your order has been delivered and paid or the agreement is terminated, and up to 36 months thereafter.

If you are not yet a customer of ours:

Your personal data is retained and processed for up to 12 months after we collected your contact details. This is preconditioned upon you not having objected to direct marketing. If you choose to become a customer of ours what is stated under the sub-heading “If you are a customer of ours” applies.

Your rights:
You always have the right to demand that we stop processing your data for direct marketing. You also always have the right to withdraw your consent when we need your consent to process your personal data. If you withdraw your consent you will no longer receive information and offers that are specifically adapted for you. You have the right to object to processing of your personal data based upon a legitimate interest as legal basis. If you object to such processing, we will continue with the processing only if there is a compelling legitimate basis for the processing that outweighs your interest, fundamental rights or freedoms. Please see section 9 if you want to read more about your rights.

Purpose:
Method and business development

Personal data:
Contact details such as name, address, telephone number and email address. Order details such as purchase and transaction history. Browsing habits and web browsing history such as what pages you have visited on our (and others) website and for how long and IP-addresses. Purchase habits such as how you use our services and your purchase habits (e.g. during which months of the year you tend to use our services).

What we do:
We process your personal data within the scope of our marketing and customer analysis, which mainly consist of statistics and customer satisfaction evaluations. The results of our analysis we then use as the basis for improving, replacing or adding new services, processes or work methods for the purpose of meet yours and other customers’ expectations and wishes. We may e.g. use your personal data to improve our customer services, offer new package solutions or adapt our website and/or app after yours and other customers’ wishes.

We also use your shipment data in order to improve our quality and efficiency.

However, we want to clarify that we always, as far as possible, try to anonymise or pseudonymise your personal data to achieve this purpose.

Legal basis:
Legitimate interest, as we assess that it is important for our business to analyse the use of our products and services for the purpose of improving, replacing or developing new services.

Retention period:
We retain and process your personal data for this purpose for the duration of the contract period, i.e. until your order has been delivered and paid or the agreement is terminated, and up to 36 months thereafter. After this period, your personal data is anonymised.

Purpose:
Sales activities

Personal data:
Contact details such as name, address, telephone number and email address. Order details such as purchase and transaction history. Browsing habits and web browsing history such as what pages you have visited on our (and others) website and for how long and IP-addresses. Communication history such as notes made in relation to telephone calls and meetings. Answers to contact forms and sales meeting questionnaires

What we do:
We use your personal data in order to have continuous communication with you as a customer and in order to provide you with services you might be interested in.

We might contact you as a prospect, based on your behaviour on our website and when you have submitted a form.

We also, as a way of continuous improvements send questionnaires about our sales persons’ abilities that you can answer if you choose to do so.

Legal basis:
Legitimate interest, as we assess that it is important for our business to be able to be in contact with our customers and improve our sales productivity.

Retention period:
If you are a customer of ours:

Your personal data is retained and processed for the duration of the contract period, i.e. until your order has been delivered and paid or the agreement is terminated, and up to 36 months thereafter.

If you are not yet a customer of ours:

Purpose:
Administration in connection with company take-over, restructuring of Jetpak etc.

Personal data:
All personal data that may exist within the scope of your agreement or contact with Jetpak and that has been accounted for in the tables above.

What we do:
If Jetpak is to be restructured, e.g. be split into several parts, or if a third party wishes to acquire Jetpak or our customer database, Jetpak will share yours and other customers’ personal data to the acquiring company. That company will in that case continue to process your personal data for the same purposes as the ones stated in this Privacy Statement, unless you receive different information in connection with the take-over.

Legal basis:
Legitimate interest, as we assess that our interest of facilitating a company take-over or restructuring overrides your interest of protection of your privacy. This is conditioned on the acquiring company being in a similar line of business as Jetpak.

Retention period:
If Jetpak ceases to exist, e.g. by way of a fusion, liquidation or bankruptcy, or if Jetpak’s customer database will be transferred to an acquiring company we will delete your personal data as long as we are not required to retain it in order to comply with legal obligations.

If Jetpak is acquired by a company or split into several parts in connection with a restructuring we will continue to store and process your personal data in accordance with the terms and conditions of this Privacy Statement, unless you receive different information in connection with the acquisition.

Purpose:
Fulfil our legal obligations and take measures against crime

Personal data:
Invoice details such as name on invoice and transaction history.

What we do:
We process your personal data to comply with our legal obligations under applicable law, e.g. in accordance with the requirements of the Accounting Act.

We will also give out your information if we receive a request from prosecutor or police.

Legal basis:
Compliance with a legal obligation.

Public interest in the purpose of preventing and taking measures against crimes.

Retention period:
Your personal data is kept for as long as necessary to comply with applicable legal obligation such as e.g. 7 years according to the Accounting Act, counted from the close of the calendar year of the financial year to which the information belonged is concluded.

Your rights:
You have the right to object to processing of your personal data based upon a public interest as legal basis. If you object to such processing, we will continue with the processing only if there is a compelling legitimate basis for the processing that outweighs your interest, fundamental rights or freedoms. Please see section 9 if you want to read more about your rights.

4 WHERE WE COLLECT YOUR PERSONAL DATA FROM

4.1 The personal data we process about you is mainly the information you have provided us with or has been provided to us by a third party in relation to the booking. When you make a booking, register a user account, order services or leave instructions, the information that is given to us contains e.g. name, personal identification number (if you are a private customer and only for the person who has made the booking), address and telephone number. When a third party makes the booking, the information that is given us is shipper or consignee information.

4.2 We may also collect your personal data when another company is outsourcing their transportation services to us.

4.3 In order for you to be able to enter into agreement with us at Jetpak and for us to provide you with our services, it is a requirement that you provide us with your personal data. If you do not provide us with personal data we are unfortunately not able to enter into agreement with you or provide you with our services.

5 AUTOMATED DECISION MAKING

5.1 Jetpak has automated processes to be able to decide whether you can pay by way of invoice when registering yourself as an invoice customer. We do a credit check that might entail that you are declined the possibility to receive invoices and instead are required to pay with a credit card. The credit check calculates whether you are suitable for invoice payment and what your credit limit is (credit rating), based on your company’s final accounts, payment defaults and ability to pay.

5.2 If you do not approve of this process you may object. In that case you are referred to our accounting department who will make a decision on whether you may pay by way of invoice following you having provided us with additional personal data.

6 FOR HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

6.1 We only retain your personal data for as long time as necessary to achieve the purposes for which they were collected in accordance with this Privacy Statement. When no longer need your personal data, we remove the data from our systems, databases and backups. In the tables above under section 3, you may read more information about for how long we retain your personal data for different purposes.

6.2 We may be required to retain your personal data for other reasons, such as to comply with legal obligations or to safeguard our legal interest, or for any other important public interest.

7 WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

7.1 Jetpak may share your personal data with third parties, such as other group companies, franchisees, IT services providers and other companies with which we cooperate to provide our services. For example, we will therefore share your personal data with Jetpak Stockholm AB, Jetpak Oslo AS and Softronic AB to fulfil our agreement with you or method and business development. We may also in certain cases be required to share your personal data with public authorities or other third parties in connection with court proceedings, corporate acquisitions or similar reasons.

7.2 We will not sell your personal data to any third party.

8 WHERE DO WE PROCESS YOUR PERSONAL DATA?

8.1 Jetpak strives for only processing your personal data within the EU/EEA. In some cases, we may transfer your personal data to a country outside of the EU/EEA. If personal data is transferred to any such country, we will ensure that your personal data is protected and that the transfer is carried out in accordance with applicable law.

8.2 When carrying out any transfer to a country that lacks an adequacy decision by the European Commission, we will use the standard contractual clauses issued by the European Commission as legal basis for the transfer. You find these here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

8.3 When carrying out transfers to recipients in the United States that have joined the Privacy Shield program, we use the Privacy Shield as legal basis for the transfer, which you find here: http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2016.207.01.0001.01.ENG&toc=OJ:L:2016:207:FULL.

9 YOUR RIGHTS

9.1 Our responsibility for your rights

9.1.1 Jetpak is in the capacity as data controller responsible for ensuring that your personal data is processed in accordance with applicable law and that your rights have an impact on the processing. You may at any time contact us to exercise your rights. You will find our contact details at the last page of this Privacy Statement.

9.1.2 Jetpak is responsible for answering your request to exercise your rights within one month from our receipt of your request or after we have identified you as the personal information owner. If your request is complicated, or if we have received a large extent of requests, we are entitled to prolong our response period with two additional months. If we assess that we cannot perform the actions you have requested, we will within one month explain why and inform you about your right to lodge a complaint with the data protection authority.

9.1.3 All information and communication, and all actions we carry out, is at no cost for you. If the action you request is manifestly unfounded or excessive, we are entitled to charge you an administrative fee to provide you with the requested information or carry out the requested action, or refuse to meet your request.

9.2 Your right to access, rectification and erasure of personal data and restriction of processing

9.2.1 You have the right to request:

a) Access to your personal data. This means that you have the right to request an abstract from our data record regarding our use of your personal data. You also have the right to request a copy of the personal information being processed at no cost. However, we may charge you a reasonable administrative fee to provide you with additional copies of the personal data. If you make your access request by electronic means such as email, we will provide you with the information in a commonly used electronic format.

b) Rectification of your personal data. We will at your request, or at our own initiative, rectify, anonymise, erase or complement personal data that you or we discover is inaccurate, incomplete or misleading. You also have the right to complement the personal data with additional data if relevant information is missing.

c) Erasure of your personal data. You have the right to request that we erase your personal data if we do no longer have an acceptable reason for processing the data. Given this, erasure shall be made by us if:

(i) the personal data is no longer necessary for the purposes for which it was collected,

(ii) we process your personal data due to your consent, and you withdraw this,

(iii) you object to the processing of your personal data based on our legitimate interest and there is no overriding legitimate ground for the processing,

(iv) the personal data has not been lawfully processed,

(v) we are required to erase the personal data due to a legal obligation.

However, there might be requirements under applicable law, or other weighty reasons, that entail in that we cannot immediately erase your personal data. In such case, we will stop using your personal data for any other reasons than to comply with the applicable law, or the relevant weighty reason.

d) Right to restrict processing: This means that we temporarily restrict the processing of your personal data. You have the right to request restriction of the processing when:

(i) you have requested rectification of your personal data in accordance with section 9.2.1 b) above during the time period we are verifying the accuracy of the data,

(ii) the processing is unlawful and you do not want the personal data to be erased,

(iii) Jetpak, in its capacity as data controller, no longer needs the personal data for the purposes for which it was processed, but you require us to retain the information for the defence, establishment or exercise of legal claims, or

(iv) you have objected to our legitimate interest for the processing in accordance with section 9.3 below during the time period we determine whether the legitimate interest overrides your privacy rights.

9.2.2 At Jetpak, we will (from 25 May 2018) take all reasonable and possible actions to notify any recipients of your personal data as set out in section 7 above regarding any rectification, erasure or restrictions carried out by us. At your request, we will also inform you of which third parties we have shared your personal data with.

9.3 Your right to object to the processing

9.3.1 You have the right to object to such processing of your personal data based upon our legitimate interest (please see section 3 above). If you object to such processing, we will only continue with the processing if we have a compelling legitimate reason for the processing that outweighs your interest, rights or freedoms.

9.3.2 If you do not want Jetpak to use your personal data for direct marketing, you always have the right to object to such processing by contacting us. When we have received your objection we will cease our processing of your personal data for this marketing purpose.

9.4 Your right to withdraw consent

For the processing for which we use your consent as legal basis (see section 3 above) you can at any point in time withdraw your consent by contacting us, e.g. through our website or by unsubscribing yourself from received emails. You will find our contact details at the last page of this Privacy Statement.

9.5 Your right to portability

You have the right to portability. This means that you (from 25 May 2018) have the right to receive certain of your personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller. You only have this right when your personal data is processed by automated means and our legal basis for the processing is consent or the performance of a contract between you and Jetpak. This means e.g. that you have the right to receive and transfer all of the personal data that you have provided us with when creating a user account with us.

9.6 Your right to lodge a complaint with the data protection authority

You have the right to lodge any complaints regarding our processing of your personal data with the data protection authority.

10 WE PROTECT YOUR PERSONAL DATA

You should always feel safe when providing us with your personal data. Therefore, Jetpak has implemented appropriate security measures to protect your personal data against unauthorised access, alteration and erasure. In the case of a security breach that may significantly affect you or your personal data, e.g. when there is a risk of fraud or identity theft, we will contact you and inform you of what you can do to reduce this risk.

11 COOKIES

At Jetpak, we use cookies at our webpage and in our services to improve your user experience. We use cookies to e.g. simplify and adjust our web and application services. In our cookies policy, we provide you with more detailed information on how we use cookies and which choices you may make regarding our cookies. You will find the policy here.

12 AMENDMENTS TO THIS PRIVACY STATEMENT

Jetpak has the right to amend this Privacy Statement at any time. When we make any amendments that are not only linguistic or editorial, you will be provided with clear information of the amendments and which impact they will have on you before the amendments are effective.

12 CONTACT INFORMATION

Do not hesitate to contact us at Jetpak if you have any questions regarding this Privacy Statement, our processing of your personal data, or if you want to exercise your rights.

Jetpak Group AB, reg. no. 556415-6550

Postal address: Postal box 3009, SE-169 70 Solna

Visiting address: Gårdsvägen 8, SE-169 70 Solna

Attn: DPO

Email: dpo@jetpak.com

Telephone: +46 8-555 85 220

Webpage: https://www.jetpak.com