GDPR Policy
Privacy and Marketing Policy
- General
This privacy policy and marketing policy (“Privacy Policy”) describes how Fragus Group, company registration number 556576-0252, Alfagatan 10, 431 49 Mölndal, tel: +46 31 27 70 40, e-mail: info@fragus.com (“Fragus”, “we”) collects, uses, discloses and stores your personal data.
1.1 This Privacy Policy applies when Fragus provides services and products in connection with purchases, service matters and other contact with Fragus, as well as to visits to the website. The Privacy Policy also applies to the processing of personal data, which is done in connection with holding a Fragus account (“Account Holder”).
1.2 You should always feel safe when you disclose your personal data to us. In this Privacy Policy, we will describe how we ensure that your personal data is processed in accordance with the applicable data protection legislation.
- Data controller
Fragus is the data controller for our processing of personal data and is responsible for ensuring that such processing takes place in accordance with the relevant legislation. Fragus is also the data controller for our processing of personal data in connection with holding a Fragus account.
- When do we process your personal data?
3.1 For you to be able to visit our website, purchase our products or services or contact us to perform a service or for information, we must collect and process your personal data.
3.2 Fragus collects and processes your personal data when you carry out a purchase on Fragus’ website, use Fragus’ support services, visit Fragus’ website, attend an event organised by Fragus or contact Fragus in some other way. The data that we collect from you for bookings and purchases is required in order for you to be able to enter agreements with Fragus and for Fragus to be able to provide its services and offers.
3.3 If you are a registered customer, Fragus collects the data that you disclose upon registering as an Account Holder. Fragus also collects data from you during the time you are an Account Holder in connection with the account, such as your purchase history, how you interact with Fragus’ website and which offers you are interested in based on the e-mails you read and the links you click on. Fragus also processes data that Fragus is occasionally given access to through your Fragus account. As an Account Holder, you can update your data at any time by sending an e-mail to: support@fragus.com.
3.4 We also collect and update your address information through third-party services for changing your address.
- Which personal data do we process?
4.1 For Fragus customers
The personal data Fragus collects and processes regarding customers who purchase our products and services and use our support service includes:
- Name and identification number (social security number, national ID number or company registration number)
- Address
- Telephone number and e-mail address
- Payment information
- Customer number
- IP address and information on your use of Fragus’ website
4.2 For Account Holders
The personal data that Fragus collects and processes regarding Account Holders includes:
- Name and identification number (social security number, national ID number or company registration number)
- Address
- Telephone number and e-mail address
- Payment information
- Account information
- IP address and information on your use of Fragus’ website
- Information on which of our products or offers you have been interested in, how you interact with our newsletters and which of our events you have signed up to
- Data about your purchases
- Information about your account
- Title and attestation rights
- Data about your purchases
- Information about your account
- Why do we process your information?
5.1 For Fragus customers
Fragus processes your personal data for various purposes. Fragus mainly processes your personal data in order to:
- Fulfil our obligations to you as our customer, such as making purchases, invoicing and providing support;
- Enable general customer care and service, such as answering questions and correcting false information;
- Provide information and direct marketing via post, e-mail, SMS/MMS or telephone regarding Fragus’ and selected partners’ products and services;
- Manage the customer relationship and provide our services;
- Provide relevant information and adapted offers in newsletters and on our website;
- Assess the payment methods we can offer you, for example, through credit assessments;
- Improve our customer offers, such as developing services, products and functions;
- Prevent fraud and perform risk management; and
- Comply with applicable legislation, such as Swedish accounting laws.
Personal data can also form the basis of market and customer analyses, marketing research, statistics, and business monitoring, as well as business and methodological development related to purchasing products and services.
5.2 For Account Holders
In addition to the purposes listed above, Fragus processes your personal data as Account Holders in order to:
- Manage your account;
- Enable you to access Account Holder benefits as well as save favourites, pre-fill information, utilise more payment methods, handle cases and claims more smoothly and manage multiple addresses;
- Provide special offers;
- Enable communication with you as the Account Holder via post, e-mail, telephone or SMS/MMS; and
- Enable us to offer you personalised offers, marketing and event offers via telephone, post, e-mail and SMS/MMS.
- Our legal basis for processing your personal data
6.1 Fragus processes your personal data on a number of legal bases. These are described in this section.
6.2 We process your personal data for the purpose of fulfilling our agreement with you as the customer or Account Holder. This can include allowing you to make bookings and purchases and providing you with access to simplified management tools and order history. Under the authority of this legal basis, we also process your personal data as an Account Holder as this relates to, for example, your purchases, your behaviour on our website and your interaction with Fragus, as well as your interest in our offers and products. We do this in order to be able to fulfil our commitment to provide you with personalised offers.
6.3 Part of our purpose for processing personal data is based on a so-called balancing of interests. This processing enables us to send you offers about our products and services, as well as to segment customers to a limited extent based on, for example, total purchase amounts. Fragus does not process sensitive personal data nor do we perform any processing that amounts to profiling on the basis of balancing of interests.
6.4 In certain cases, Fragus may have a legal obligation to process your personal data. For example, we may process personal data in order to fulfil our obligations in relation to Swedish accounting law.
- Summary of our personal data processing
Purpose | Legal basis | Categories of personal data | Storage time |
|
|
|
|
To manage, develop and supply our products and services, as well as to provide support | Fulfilment of the purchase agreement (terms of sale)
| - Name, address, telephone | Two years after you were last active at Fragus, for example, buying our products and services or contacting our customer service |
To ensure that we are complying with our legal obligations, such as Swedish accounting law | Legal obligation
| - Name, address, telephone | As long as we are obliged to store the personal data in accordance with the applicable legislation
|
To market products and services from Fragus and our partners or affiliated companies via post, e-mail, telephone and SMS/MMS | Balancing of interests
| - Name, address, telephone
| Two years after you were last active at Fragus, for example, buying our products and services or contacting our customer service
|
To manage your account, enable you to receive customised offers and enable targeted communication via post, e-mail, telephone or SMS/MMS
| Fulfilment of the agreement on Fragus accounts
| - Name, address, telephone | As long as you have a Fragus account
|
- Profiling
8.1 If you are an Account Holder, Fragus can process your personal data through profiling. If you are an Account Holder, we analyse information on: how you use our website; which of our products, services and offers you are interested in; which of our newsletters you interact with; which of our events you sign up for; your purchases; and your account. We do this for the purpose of providing you with offers that we think suit you and inviting you to events we think you would like to attend.
8.2 You can object to our processing of personal data through profiling at any time by calling Fragus customer support or e-mailing us at info@fragus.com. Once Fragus has received your objection, we will stop processing your personal data for this purpose.
- How long do we store your personal data for?
9.1 Your personal data is stored only for as long as it is needed in order to fulfil the purpose of its collection according to this Privacy Policy. Fragus may store the data longer if there is a need to fulfil our legal obligations or to safeguard Fragus’ legal interests, for example, in the event of a judicial process.
9.2 Fragus stores a customer’s data for no more than 24 months following the customer’s last completed purchase or last interaction with Fragus.
9.3 Fragus stores data on an Account Holder for as long as the Account Holder has a Fragus account.
- Who do we disclose your personal data to?
10.1 Fragus may disclose your personal data to a third party, such as a Fragus-affiliated company or other partners, as well as suppliers of card and communication services. Fragus may also disclose your data to companies that provide services for changing addresses in order to ensure that we have your correct address information.
10.2 Third parties that Fragus discloses information to or to which Fragus provides information on a customer or Account Holder in another way may use that information only for the purpose of selling and marketing services and products from Fragus, Fragus’ partners and Fragus’ affiliated companies, or for the purpose of supplying services related to Fragus’ agreement with you as a customer or Account Holder. If you have chosen to apply for insurance with us, personal data may also be disclosed to an insurance company. If you apply for a loan when purchasing a product or service, your data may be disclosed to a credit bureau.
10.3 Furthermore, Fragus can also disclose your personal data if it is necessary for fulfilling applicable legal obligations or the requirements of authorities, for safeguarding Fragus’ legal interests or for detecting, preventing or providing notification of fraud and/or other security and technical problems.
10.4 Fragus may transfer your personal data to non-EU/EEA countries if some of Fragus’ suppliers or partners are located there. If personal data is transferred to a non-EU/EEA country, Fragus will take steps to ensure that the personal data remains protected and follow the necessary measures that are required to legally transfer personal data to non-EU/EEA countries.
10.5 We will not sell your personal data to third parties without your permission to do so.
- Changes to the Privacy Policy
11.1 Fragus has the right to adjust the Privacy Policy at any time. Fragus will inform you with reasonable notice of any changes to the Privacy Policy. If you do not accept these changes, you have the right to terminate your agreement with Fragus before the changes to the Privacy Policy enter into effect. You can terminate the agreement by contacting Fragus or, if you are an Account Holder, by selecting [close account] on “My account”. - Protection of your personal data
12.1 You should always feel safe in disclosing your personal data to us. Therefore, Fragus has taken the necessary security measures to protect your personal data against unauthorised access, alteration or erasure. For example, all personal data relating to customers and Account Holders is stored in a database that is protected by access control and a firewall.
13. Your rights
13.1 Fragus is responsible for ensuring that your personal data is processed in accordance with the applicable legislation.
13.2 Fragus will, either at your request or on its own initiative, rectify, anonymise, erase or supplement data that is incorrect, incomplete or missing.
13.3 You have the right to request:a. Access to your personal data. This means that you have the right to request an extract from the register of your personal data that we are processing. You also have the right to receive a copy of your personal data we are processing. Once a year, you have the right to submit a written signed application to obtain an extract from the register free of charge that contains information about which of your personal data we are processing, the purpose of this processing and the parties to which the data has been or will be disclosed. You also have the right to receive information in the extract regarding where the personal data was collected from if it was not provided by you and whether any automated decision-making (including profiling) is taking place, as well as the period of time the data is expected to be stored for or the criteria used to determine this period. Furthermore, in the extract you have the right to receive information about your general rights that are referred to in this section.
- Rectify your personal data. At your request, we will rectify any of your data that we are processing that is incorrect or incomplete as quickly as possible.
- Erase your personal data. This means that you have the right to request that your personal data be erased if it is no longer necessary for the purpose it was collected for. However, there may be legal requirements that prevent us from erasing your personal data, for example, in Swedish accounting and tax legislation. We will stop processing that is performed for any purpose other than fulfilling our legal obligations.
- Restrict processing of your personal data. This means that your personal data is marked so that it can be processed only for certain limited purposes. For example, you can restrict processing if you believe your personal data is incorrect and you have requested rectification in accordance with point 12.3 b). Processing of this data will be limited while its accuracy is being investigated.
13.4 Fragus will notify every party that the personal data has been disclosed to in accordance with point 10 of any rectifications or erasure of data, as well as any processing restrictions.
13.5 You have the right to data portability. This means that you have the right under certain conditions to receive and transfer your personal data in a structured, commonly used and machine-readable format to another data controller.
13.6 You have the right to object to personal data processing on the basis of a balancing of interests. If you object to this processing, we will continue processing it only if we have a legitimate interest to do so that outweighs your interests.
13.7 If you do not want us to process your personal data for direct marketing purposes, you always have the right to object to such processing by sending an e-mail to support@Fragus.se. Once we have received your request, we will cease processing your personal data for such marketing purposes.
13.8 You have the right to submit any complaints regarding how we process your personal data to the Swedish Authority for Privacy Protection.
- Contact information
14.1 If you have any questions about this Privacy Policy and how we process your personal data, or if you want to request an extract from the register, do not hesitate to get in touch. You can find our contact information below.
Klas Tenmark
klas.tenmark@fragus.com