GDPR
Linc AB, (“Linc” or “the Company”) is responsible for the processing of personal data related to interaction with Linc in its activities as an investment company (“the Service”). Linc is thereby responsible for ensuring that all personal data is processed correctly and in accordance with applicable data protection legislation. All processing of personal data within Linc takes place in accordance with applicable personal data legislation. Within the EU / EEA, as of 25 May 2018, the so-called Data Protection Regulation (GDPR) applies.
This personal data policy, (herein referred to as “the Policy”), describes how Linc processes personal data, and is designed to create confidence that Linc processes data in accordance with applicable data protection legislation.
Personal data refers to all types of information that can either directly or indirectly be attributed to a living, physical person. The conduct of Linc’s business activities may involve personal data that relate to, for example, first and second names, personal identification numbers, phone numbers, addresses, post codes, email addresses etc., (herein referred to as “Personal data”).
WHY WE PROCESS YOUR PERSONAL DATA, LEGAL BASIS, WHICH PERSONAL DATA WE PROCESS AND STORAGE PERIOD
For communication with prospects
| Purpose | Actions taken | Categories of Personal data |
| To communicate with people in connection with new investment opportunities |
Communication via phone and email Distribution of information, e.g. investment opportunities, etc. Registration and storage of personal data in a contact database |
Name Contact details Address Company |
| Where do we obtain Personal data? For this purpose, we only register Personal data that you give to us. | ||
| Who else may have access to Personal data? For this purpose, administrative partners may have access to your data, similarly Linc’s IT suppliers. | ||
| Legal basis: Processing is necessary to fulfil our legitimate interest in being able to communicate with those who have shown interest in our Service, and where we have judged that this interest outweighs your interest in having your personal data untouched. | ||
| Your right to withhold consent: Linc cares about your integrity and will not process personal data for this purpose if you no longer wish us to do so. Contact us via info@Linc.se, and we will remove your personal data. | ||
| Storage period: Linc annually reviews the contact database and then deletes Personal information that is no longer relevant. As a starting point, your Personal Information is stored for no longer than 1 year from the time Linc last had contact with you regarding the Service. In some cases, however, there may be an obligation for us to store certain Personal Data for longer than 1 year according to law or regulation. | ||
| Purpose | Actions taken |
Categories of personal data |
| To exercise ownership role in existing investments | Personal data may be registered in Linc’s contact database |
Name Contact details Address Company |
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Where do we obtain your Personal data? For this purpose, Linc only registers Personal data that you give to us. |
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Who else may have access to Personal data? For this purpose, administrative partners may have access to your data, similarly Linc’s IT suppliers. |
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Legal basis: Processing is necessary to fulfil our legitimate interest in being able to communicate with those who are involved in Linc’s investment activities, and where Linc has judged that this interest outweighs your interest in having your Personal data untouched. |
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Your right to withhold consent: This processing of you Personal data is necessary for us to be able to conduct investment activities. If you elect to withdraw your consent to this processing, Linc will be unable to provide the Service to you. |
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Storage period: Linc annually reviews the contact database and then deletes personal information that is no longer relevant. As a starting point, your Personal Information is stored for no longer than 1 year from the time Linc last had contact with you regarding the Service. In some cases, however, there may be an obligation for us to store certain Personal Data for longer than 1 year according to law or regulation. |
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| Purpose | Actions taken |
Categories of personal data |
| To communicate with contacts at suppliers and partners |
Communication via email and phone Registration and storage of Personal data in a contact database |
Name Contact details Address Company |
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Where do we obtain your Personal data? For this purpose, we process only personal data that you give to Linc, or that Linc receives from your employer. |
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Who else may have access to Personal data? For this purpose, administrative partners may have access to your data, similarly Linc’s IT suppliers. |
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Legal basis: Processing is necessary to fulfil Linc’s and your employer’s legitimate interest in being able to communicate with those who are acting as a contact person for Linc, and where Linc has judged that this interest outweighs your interest in having your Personal data untouched. |
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Your right to withhold consent: Linc cares about your integrity and will not process your personal data for this purpose if you no longer wish us to do so. Contact us via info@Linc.se, and we will remove your personal data. |
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Storage period: For this purpose, Linc retains your Personal data for up to one year after Linc has concluded a business relationship with your employer, or up to one year from when Linc has received information that you are no longer Linc’s contact person. |
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| Purpose | Actions taken |
Categories of personal data |
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To send financial information such as annual and interim reports to which you subscribe |
Distribution of subscriber newsletter via email or post |
Name Company Address |
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Where do we obtain your Personal data? For this purpose, Linc only processes personal data that you give to Linc. |
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Who else may have access to Personal data? For this purpose, administrative partners may have access to your data, similarly Linc’s IT suppliers. |
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| Legal basis: Processing is conducted with your consent. | ||
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Your right to withhold consent: Linc cares about your integrity and will not process your personal data for this purpose if you no longer wish us to do so. At any time, you may withdraw your consent by clicking on “unregister” in digital material, or contact us via info@Linc.se, and Linc will remove your personal data. |
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| Storage period: For this purpose, Linc retains your Personal data until further notice. Every year, you will be reminded that you have consented to this storage. | ||
RECIPIENTS OF PERSONAL DATA AND TRANSFERS OUTSIDE THE EU/EES
Being responsible for Personal data, Linc may instruct a partner or supplier to carry out the action outlined above, for example IT support, law firms, consultancies etc.. Such processing will only be conducted for the purpose specified. Certain partners and suppliers may have parts of their operations outside the EU/EES, (a so-called third country). Such transfers are made only to such countries that, according to the EU Commission, have a sufficiently robust level of protection; or to suppliers that are subject to legally binding and enforceable instruments that guarantee the security of the data in question.
Linc also discloses your Personal Information to third parties when investigating suspected crimes or if we are otherwise obliged to do so by law or government decision.
Linc or a substantial portion of Linc may be sold to third parties. In such a case, your Personal Data may be shared with such third party as a result of such sale. Such division then takes place on the basis of Linc’s (or its shareholders’) legitimate interest in being able to carry out such a sale.
RIGHTS OF INDIVIDUALS REGISTERED WITH LINC
As an individual registered by Linc you have the right to:
- request information about the personal data Linc has about you, and you may request a copy of such data (a transcript),
- have inaccurate personal data corrected or deleted,
- object to the manner in which certain personal data are processed, and request that the processing of personal data is restricted,
- have submitted personal data transferred to another entity responsible for personal data (the right to data portability),
- if processing is based on consent, withdraw said consent at any time, and
- if you are unsatisfied with how we process your personal data, you may make a complaint to the Swedish Authority for Privacy Protection, the agency responsible for data protection. Contact details of the Swedish Authority for Privacy Protection can be found on datainspektionen.se.
You may, at any time, receive a transcript of your Personal data, delete your personal data, or restrict our use of your personal data. Please note that if you request a restriction to the use of, or the deletion of your Personal data, this may result is us being unable to provide the Service to you.
PERSONAL DATA PROTECTION
We have taken appropriate technical and organisational steps to protect Personal data from loss, abuse, unauthorised access, disclosure, alteration or destruction. To ensure that personal data is processed securely and confidentially, we use computer networks that are protected by firewalls and code numbers, in line with industry best practice.
To ensure the integrity of the personal data that you provide to us, we may use encryption technology when we transfer personal data over the Internet to the Company’s servers.
Our employees and suppliers are bound by confidentiality agreements, and are required to respect our data and IT security rules, the Policy, and other internal regulations that further regulate the processing of personal data.
AMENDMENTS TO THIS POLICY
Linc reserves the right to revise the Policy periodically. The date of the most recent amendment to the Policy is provided at the bottom of the last page of the Policy. If Linc makes several changes to the Policy, the Company will publish details of these changes on its website. We therefore recommend that you regularly read the Policy to ensure that you are aware of potential changes to it. If Linc alters the Policy in such a way that it substantially differs from what was communicated when you gave your consent, Linc will notify you of such changes, and, when necessary, request consent again for Linc’s personal data processing.
The Personal data policy was adopted on 11 May 2022
CONTACT INFORMATION
Questions relating to the Policy, or to our processing of personal data, should be directed to:
Linc AB (publ)
Karl Tobieson
Strandvägen 7A
114 51 Stockholm
+46 709 35 85 74
info@linc.se