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PRIVACY POLICY

This privacy policy describes the personal data processing that takes place within Storskogen Group AB, Storskogen Industrier AB, Storskogen Utveckling AB and Storskogen 3 Invest AB (“Storskogen”, “we”, “us" and “our”). Our processing of your personal data and how we ensure that the processing of your personal data is carried out responsibly and in accordance with applicable data protection legislation is described below. Your privacy is important to us and we therefore encourage you to read this policy carefully. 

We may update this privacy policy if our personal data processing changes, e.g. if we were to process more of your personal data than described below.

INTRODUCTION
This privacy policy applies to you who visit our website, contact us via e-mail or the contact form on our website, is an external stakeholder (e.g. corporate broker or investor) as well as a shareholder in Storskogen. 

Storskogen is the data controller for the processing carried out by us or others on our behalf. This means that we decide why and in what way your personal data will be processed. If you have any questions about how your personal data is processed please contact us via the contact details provided at the end of this document.

Euroclear Sweden AB (“Euroclear”) is responsible for keeping the shareholder’s register for Storskogen Group AB (public limited company) and is the data controller for the processing of personal data that takes place in connection with this task. Please contact Euroclear if you want to know more about how Euroclear processes your personal data.

On occasion, our website may embed content via RSS feeds, such as press releases. As a visitor to our website you may be redirected via a RSS feed to a website for which Storskogen is not the data controller and which Storskogen does not have access to and has no control over, including cookies or the information they collect. You should check the relevant websites for further information when you leave Storskogen’s website.

WHAT PERSONAL DATA DO WE PROCESS AND FOR WHICH PURPOSES?
Depending on when, and in which the role, we encounter you, we will process different categories of personal data. In your contact with Storskogen, you will provide us with certain information such as name and contact information. Your personal information has been obtained either directly from you or from your employer in connection with the business relationship that exists between us and your employer. 

We may also collect your personal information from other sources. For example, we obtain shareholder register from Euroclear in connection with general meetings.

Website visitors, contact via e-mail or contact form and newsletter subscribers
The following personal data is processed when you visit our website, contact us via e-mail or contact form or sign up to subscribe to our newsletter:

  • Name, e-mail and possibly other information you give us in the form or by e-mail.
  • Indirect personal data collected via your use of features on the website and through our use of cookies (described later in this policy). 

The data is processed to communicate with you regarding your matter, for marketing purposes and to facilitate new business for Storskogen. Information from cookies is used to improve our website (find out more about the processing that takes place in connection with cookies below).

External stakeholders

The following personal data is processed when you are an external stakeholder to us:

  • Name, e-mail and possibly other information you give us in connection with your communication with us.

The information is processed to communicate with you in your matter, for marketing purposes, for example to communicate our completed acquisitions and information about Storskogen and to facilitate new business for Storskogen.

Employees of our suppliers and / or customers
The following personal data is processed about you as an employee of a supplier and/or customer to us:

  • Name, professional contact information and possibly other information you or your employer provide to us in connection with your communication with us.

The information is processed to communicate with you in your case, for administration of and/or fulfilment of agreements between us and your employer.

Shareholders
The following personal data is processed when you are a shareholder:

  • Name and contact details
  • Personal identification number
  • Holdings of shares or other financial instruments, voting rights and information about rights linked to the shareholding
  • Photography, video and audio recordings (insofar as such photography and recordings are taken or made at an Annual General Meeting)
  • The following data are also processed in connection with shareholders’ meetings: (i) information on advisers (if notified) and representatives (when using a proxy), (ii) information on voting to the extent that it can be linked to certain shareholders based on the number of votes, and (iii) notes in the minutes of the meeting (e.g. in case of dissenting opinions, statements etc.)
  • Information about any trustee, pledge and pledgee or other notes in the CSD register
  • E-mail correspondence to the extent that it occurs in your capacity as a shareholder
  • Account details for administering payments and dividends 

The data is processed to be able to hold shareholders’ meetings and provide services in connection with it as well as to comply with legal obligations in accordance with applicable laws and regulations, answer questions from shareholders about their holdings and be able to check information on questions from authorities or other competent third parties. Information on the 10 largest shareholders must, in accordance with good practice in the stock market, be published in the company's quarterly reports and annual report. We also process your contact information to be able to send out information that is relevant to you as a shareholder, such as financial reports. Furthermore, the information is processed in order to be able to administer the shareholder agreement that exists between the shareholders.

In connection with you becoming a shareholder in Storskogen, either through the acquisition of shares or participation in a share issue, Storskogen processes the following personal data about you:

  • Name and contact information
  • Personal identification number
  • VP account 

The information is processed in order for Storskogen to be able to maintain and facilitate the post-transfer acquisition right in accordance with our articles of association and requirements in accordance with the shareholders' agreement that apply between all shareholders in the Storskogen. 

Storskogen and its subsidiaries have an obligation under the Swedish Companies Act to preserve share registers with information about previous owners of a company for a period of 10 years after the company has been liquidated or otherwise wound up. Share registers contain information about you who are or have been a shareholder in a company that Storskogen has acquired or formed, namely name, personal identification number, address, number of shares and period of ownership.

Personal data within the scope of the acquisition process
As a seller of a company to us, we will process your personal data within the framework of the transaction. The following personal data is processed about you as a seller:

  • Name, social security number, address, contact information
  • Shareholding in the target company 

The information is processed in order to be able to produce agreements and other related documentation within the framework of the acquisition process and in order for us to be able to meet requirements in accordance with applicable anti-money laundering legislation.

Whistleblowing
On our website, we provide a whistleblowing service in accordance with applicable laws. The service gives individuals an opportunity to inform us about a suspicion of a serious misconduct. You as a notifier can be completely anonymous when using the service. In the event that a processing of personal data takes place, it is on the basis of a balance of interests where our legitimate interest is that the whistleblowing service provides a possibility to inform us about a suspicion of serious misconduct and it is an important channel for safeguarding good corporate governance and maintaining customer and public confidence. Personal data about violations of the law is only processed for key persons or persons in senior positions, in accordance with the Swedish Authority for Privacy Protection’s guidelines.

LEGAL BASIS FOR THE PROCESSING OF YOUR PERSONAL DATA
Storskogen processes your personal data when it is in our legitimate interest to do so. This applies, for example, to the processing that takes place in connection with you visiting our website or contacting us via e-mail or contact form (including the subsequent handling of the matter and marketing). This is also the case with certain processing that takes place in connection with annual general meetings (e.g. maintaining adequate security and order during meetings). After the acquisition process, we may process your personal data to the extent necessary for us to be able to meet contractual obligations or to safeguard our legal interest. 

All other processing that takes place regarding shareholders is necessary for us to be able to comply with our legal obligations.

As an employee of a customer or supplier to us, we will also process your personal data to fulfil the agreement that exists between us and your employer.

DISCLOSURE OF YOUR PERSONAL DATA
Data may be disclosed to external companies that we engage or collaborate with in connection with the processing described above. For example, there are companies that help us with the operation, testing and development of IT systems, data backup and financial administration. We have agreements in place with these companies to ensure that they take appropriate security measures. We take special security measures when dealing with companies that process data outside the EU/EEA area, e.g. agreements containing the European Commission's standard contractual clauses for data transfer available on the European Commission's website. 

Within the scope of an acquisition process, we may disclose information to external advisers and to wholly or partly owned subsidiaries in order to comply with agreements. We also disclose information to, for example, public authorities if we see that there is a legitimate interest in such disclosure or if we are otherwise obliged to disclose information by law or public authority decision.

STORAGE PERIOD
Your personal data is only stored for as long as it is necessary to fulfil the purposes of the processing, or for as long as we are required to store the data by law (e.g. for accounting purposes in accordance with the Accounting Act). We also store personal data in order to comply with agreements or if we deem that we have a legitimate interest in processing the personal data or when we are required to save them under the statute of limitations. You can unsubscribe from subscriptions to press releases, newsletters and the like at any time, and your personal data will then no longer be stored for this purpose. 

Information, images and news notices that we publish on the website with the support of our legitimate interest are preserved as long as there is a news value in the information that is published and the purpose remains. For example, such further treatment may be necessary to inform the public and investors.

YOUR RIGHTS UNDER DATA PROTECTION LEGISLATION
Under certain conditions, you have certain rights under data protection legislation in connection with our processing of your personal data. These are:

  • Right of access (register transcript) – a right to obtain a copy of the data we process about you and information about the data being processed
  • Right to rectification – a right to have erroneous data rectified
  • Right to erasure – a right to have data erased
  • Right to restriction of processing – a right to request restrictions on our processing (e.g. during the period in which you have requested that data be corrected, and we investigate whether the data are correct)
  • Right to data portability – a right to request that your data is transferred from us to another data controller
  • Right to object to our processing
  • Right to lodge a complaint with the supervisory authority (the Swedish Data Protection Authority) if you believe that we are not processing your personal data in accordance with data protection legislation

CONTACT DETAILS FOR DATA CONTROLLER
If you would like further information about how your personal data is processed, or wish to exercise any of the rights listed above, please contact us at the contact details below:

Storskogen Group AB
FAO: Privacy
Hovslagargatan 3
SE-111 48 Stockholm, Sweden
info@storskogen.com

COOKIES
We use cookies on this website. A cookie is a small text file placed on the computer/device you use to visit the website. The website also uses cookies which allow us to optimise the website's features, to improve your experience of the website, to make the website easier to use and to tailor the website to your interests and needs. Cookies are also used to compile anonymous statistics so that we can understand how our users surf the website, thereby giving us the opportunity to make improvements. 

Find out more about cookies on the Swedish Post and Telecom Authority’s website.  

The information collected through cookies is only used for Storskogen’s purposes, i.e. not for third parties’ purposes.

There are three types of cookies on the website:

Session cookies, i.e. cookies that are temporarily stored in the browser's memory while you visit the website. They may, for example, be used to identify the language you have selected. Session cookies are deleted when the web browser is closed.

Persistent cookies, i.e. cookies stored on your device for a longer time. They are used, for example, for features telling you what's new since you last visited the website. How long the cookie stays on your device depends on the lifetime of the specific cookie and your browser settings.

Third-party cookies, i.e. cookies that belong to domains other than those displayed in the address bar. Third-party cookies open opportunities to track user web history.

The cookies used on our website are described in the following table.

NamePurpose of the cookie and the data collectedStorage period 
CookieAgree Managing that the user closes the cookie banner. 12 months
_ga Creates an anonymous ID for statistical purposes and collects statistics about the user's session.
Used by Google Analytics.
26 months
_gat Improves user experience. Used by Google Analytics.1 minute
_gid Creates an anonymous ID for statistical purposes and collects statistics about the user's session.
Used by Google Analytics. 
24 hours
_gat_Waas Improves user experience. Used by Google Analytics.1 minute

Most browsers accept cookies automatically, although the settings in your browser can be adjusted to block and erase cookies. The specific procedure for doing this varies between different browsers, and further information can be found either in the respective browser’s instructions or in the help function which accompanies most browsers. Further information about how to manage and erase cookies can be found on the following website: www.aboutcookies.org

Please note that blocking cookies can result in a degraded user experience.

Our website sometimes embeds content and sharing tools from social networks via RSS feed. The suppliers of these services may thereby come to use cookies on our website. Storskogen has no access to or control over these cookies or the data they collect. You should check the websites of the suppliers concerned for further information about these cookies and whether you can opt-out of receiving them.