Privacy policy.
Last updated as per 15 November 2021
1. Introduction
1.1. The EU General Data Protection Regulation (EU) 2016/279 (”GDPR”) was enforced on 25 May 2018. One of the purposes of GDPR is to protect individuals´ fundamental rights and freedoms, particularly their right to protection of their personal data. Litorina is committed to protecting the privacy, integrity, and security of your personal data. Protecting your personal data is of utmost importance for us.
1.2. This privacy policy sets out how the personal data provided to Litorina Capital Advisors AB (556706-3192), Litorina V Advisor AB (559068-5375) and their affiliated entities and funds (together, “Litorina”, “the company”, “we” or “us”) is used, stored, transferred or otherwise processed, and other matters relating therero. We describe what type of personal data we collect, on what lawful grounds, who we may share your personal data with and certain rights and options that you have in this respect. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with Litorina.
1.3. For the purposes of applicable EU data protection laws, Litorina V Advisor AB and Litorina Capital Advisors AB are data controllers of personal data collected by us. Most of the time they will act as joint data controllers.
2. Personal data we collect, purposes and lawful grounds
2.1.Representatives from companies, organisations or authorities
Litorina processes your personal data to be able to contact and communicate with you in your capacity as a representative from a company (e.g. portfolio company, advisor, investor), organisation or authority. Your personal data is often collected from you or from the company, organisation or authority which you represent.
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CATEGORIES OF PERSONAL DATA |
PURPOSE |
LAWFUL GROUNDS |
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Contact information such as name, e-mail address, phone number, voice messages, photography, office address, personal identification number and position in the company, organisation or authority. |
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Legitimate interest in managing the business relation with the company, organisation or authority (weighing of interests). Legal requirements. Execute, fulfil, or comply with a contract with the data subject. |
2.2. People (such as board members, entrepreneurial owners, key management executives) that co-invest with Litorina.
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CATEGORIES OF PERSONAL DATA |
PURPOSE |
LAWFUL GROUNDS |
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Name, personal identification number, address, income, property holdings, civil status, information regarding family members and resume. |
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Legitimate interest to profoundly examine the potential co-investors of a company before investment. |
2.3. Website visitors
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CATEGORIES OF PERSONAL DATA |
PURPOSE |
LAWFUL GROUNDS |
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Device information. Information collected from cookies. |
To be able to customize and administer the website based on how it is used. |
Legitimate interest of improving and simplifying the company´s website (weighing of interest). |
2.4 Shareholders and board members of Litorina and/or portfolio companies
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CATEGORIES OF PERSONAL DATA |
PURPOSE |
LAWFUL GROUNDS |
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Name, personal identification number, position, business address, copy of passport, if PEP, evidence of private address, nationality, owned share and residence for tax purposes. |
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2.5. Close relatives of employees at Litorina
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CATEGORIES OF PERSONAL DATA |
PURPOSE |
LAWFUL GROUNDS |
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Contact information such as name, phone number and e-mail address. |
To be able to contact close relatives in the event of an accident involving employees at Litorina. |
Legitimate interest in being able to contact close relatives of employees in case of an accident. |
2.6. People seeking employment at Litorina and/or people looking for positions as potential board members, advisors or other executive positions at Litorina or its portfolio companies
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CATEGORIES OF PERSONAL DATA |
PURPOSE |
LAWFUL GROUNDS |
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Contact information such as name, address, phone number, e-mail address. Resume, nationality, personal identification number, languages, civil status and results from personal tests. |
To fulfil the need for recruitment of capable people to Litorina and/or our portfolio companies. |
Legitimate interest of being able to continuously recruit talented employees and/or board members, advisors and executives (weighing of interest). |
2.7. People who contact us spontaneously
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CATEGORIES OF PERSONAL DATA |
PURPOSE |
LAWFUL GROUNDS |
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Contact information such as name, title, e-mail address and phone number. |
To enable and facilitate communication with potential, customers, clients, shareholders, investors, advisors, partners, suppliers, etc. |
Legitimate interest of enabling and facilitating communication with potential customers, clients, shareholders, investors, advisors, partners, suppliers, etc. |
3. From where do we collect your personal data?
3.1. Litorina is processing personal data that you provide us with. We may also collect personal data from public records or third parties.
4. Who do we share your personal data with?
4.1. Litorina may share or transfer your personal data within the Litorina group of companies. Litorina may share or transfer your personal data to parties which processes data on our behalf to perform our services, e.g. providers of IT-services and accounting services. With those parties there are data processing agreements which stipulates how the personal data may be processed and protected. We may share your personal data with our portfolio companies, if we have initiated a recruitment process, and to our fund administrators and investors. We may also share your personal data because of legal obligations.
5. Transfer of data to a third country
5.1. To the extent Litorina transfers your personal data to a country outside the EU/EES, such transfer will be covered by a framework recognized by GDPR and relevant authorities ensuring an adequate level of protection of your personal data. i.e. by using the EU-commission´s standard contractual clauses.
6. How long time do we keep your personal data?
6.1. Your personal data will not be kept longer than necessary for the purpose for which it was collected. Some of your personal data will be kept if required by law, e.g. accounting legislation.
7. How do we protect your information?
7.1. Litorina has implemented adequate technical and administrative measures to protect your personal data from unauthorized access, use, distribution or alteration and unlawful destruction.
8. Your rights
8.1. Regardless of what personal data we have stored, you should always be in control of your own personal data. According to the GDPR you are entitled to exercise the following rights.
8.1.1. Your right of access – You have the right to ask for a record of your personal data processed by us.
8.1.2. Your right to rectification – You have the right to ask us to rectify information about you that you consider as inaccurate. You also have the right to ask us to complete information you think is incomplete.
8.1.3. Your right to erasure – You have the right to ask us to erase your personal data in certain circumstances.
8.1.4. Your right to limitation of processing – You have the right to ask us to restrict the processing of your data in certain circumstances.
8.1.5. Your right to data portability – You have the right to ask that we transfer the information you have given to us from one organization to another. The right only applies if we are processing information based on your consent.
8.1.6. Right to object – In certain cases you have the right to object to your personal data being processed.
9. If you are dissatisfied with our processing of your personal data
9.1. You may at any time file a complaint about our processing of your personal data to the Swedish Data Protection Authority (Integritetsskyddsmyndigheten “IMY”).
10. Changes in this privacy policy
10.1. We may from time to time carry out changes and updates to this document. You should therefore visit our website regularly to receive the most up-to-date version of this privacy policy.
11. How to contact us
11.1. If you have any questions regarding our processing of personal data or if you want to exercise some of your rights in relation to the procession of your personal data, please contact us.
Processors: Litorina V Advisor AB (559068-5375) and Litorina Capital Advisors AB (556706-3192).
Address: Sveavägen 9, 12th floor, 111 57 Stockholm
Phone number: +46 8 545 181 81
E-mail address: privacy@litorina.se