Tubus System’s Privacy Policy

1. Introduction

[Tubus System International AB] with company registration number [556728-4319 (“Tubus System”) is the data controller for the processing of your personal data, as set out in this policy. All references in this privacy policy to “we”, “us” or “our” are references to Tubus System. Our contact information can be found at the end of this privacy policy.

We respect your privacy and are committed to protecting your personal data.

2. Scope of privacy policy

This privacy policy aims to inform you about how, why and when we process your personal data, in accordance with what you are entitled to under Article 12-14 of the General Data Protection Regulation (“GDPR”). To minimize information fatigue, we have limited the information to personal data processing that has the greatest impact on you, is least obvious or most frequently performed. Should you have any questions or want to know more, please do not hesitate to contact us. You can find our contact information at the end of this privacy policy.   

For more information on how we use cookies, please see our Cookie policy.

To help you find relevant information about how we process your personal data, we have placed the information under headings that reflect our various relationships with you. This privacy policy includes information about how we process personal data about the following categories of individuals:

  • Website visitor
  • Potential customer’s contact person
  • Customer’s contact person
  • Apartment owner
  • Recruitment candidates
  • Supplier’s contact person
  • Subcontractor’s employee


If you do not recognize yourself in any of the categories above but have reason to believe we still process your personal data, you are most welcome to contact us, and we will help you.

Below we explain the types of personal data we process, our purpose for each processing and the legal basis on which we base our processing. It is important to understand that the following information is not an exhaustive description but a summary of the processing that we think you are most interested in.

3. How do we process personal data?

Website visitor

When you visit our website, you have the option to consent to store cookies on your device, that enables us to collect information and analyse (which we do on an aggregated level), to develop and improve our website.

Purpose

Processing activities

Categories of personal data

Administer, compile statistics and conduct analysis on our website

  • Improving the website.

  • Improving the user experience of our website.

  • Ensuring the functionality of the website.

  • Keeping statistics on visits to our website.

  • Providing relevant and customized content.

  • Technical data related to used devices and its settings collected via cookies (language setting, IP address, your location, browser setup, operating system, screen resolution and platform).

  • Information on your use of our website collected via cookies (for how long you visit the website, which web pages and links you click and if you submit an inquiry form).

Legal basis: Consent.

Tubus System collects consent for the processing of cookies, except for the cookies that are strictly necessary for the website to function.

    

Retention period: Each cookie has a pre-determined lifetime, depending on its function and purpose. You can find all information in our Cookie Policy.

    

Potential customer’s contact person

When you get in contact with us or in another way has shown interest in our services, we will process your personal data for the purpose of answering your questions and to market our services. Your personal data could be collected directly from you at a meeting, fair or if you have filled out any form at our website. In addition, we could have collected your contact information from other sources in the event we have judged that our services are relevant to you in your professional role.

Purpose

Processing activities

Categories of personal data

Market our services

  • Collecting contact information.

  • Structuring contact information to contact you with relevant marketing information.

  • Analyse engagement with our email marketing, to adjust our communication.

  • Name.

  • Contact information (email address and phone number).

  • Company related information (address to the company you represent, company’s name and your title).

  • IP address, to track opening rates and interaction with our marketing.

  • Lead scoring.

Legal basis: Legitimate interest.

Tubus System has a legitimate interest in marketing its services to people in roles where there may be a need for what we have to offer and where considered risks for the individual have not been considered to override this interest.

    

Retention period: Tubus System will process the personal data for marketing purposes until you decline further communication from us.

    

Purpose

Processing activities

Categories of personal data

Answer questions, book meetings and follow up after a meeting and make quotes

  • Collecting contact information.

  • Manage your request.

  • Contact and follow-up.

  • Name.

  • Contact information (email address and phone number).

  • Company related information (address to the company you represent, company’s name and your title).
 

Legal basis: Legitimate interest.

Tubus System has a legitimate interest in answering your questions through various channels. This matches your expected interest in getting answers from us regarding questions concerning our and your organisation's business.

    

Retention period: Tubus System will process the personal data for the above purpose during the time we have an active dialogue, from the last date of contact to one year thereafter. The information may be further processed, if we do business, since we have a continued legitimate interest in keeping certain information relevant to the contractual relationship between us and the organisation you represent.

    

Customer’s contact person

If we enter into an agreement with the organisation you represent, we will process your personal data to ensure that we can deliver the best possible service, answer your questions, provide our services, provide and maintain warranty commitments, invoice your organisation, and care for our customer relationship and in some cases ask for permission to use you as a reference. We have collected the information from you or one of your colleagues.

Purpose

Processing activities

Categories of personal data

Performance of customer services

  • Communicating and answering of any questions to our customer service, via email, contact forms on our websites and our social media.

  • Identification when you contact our customer service.

  • Examination of complaints.

  • Investigating and supporting complaints related to our services, e.g. when we solve a problem that occurred when you purchased a service from us.

  • Name.

  • Contact information (email address and phone number).

  • Company related information (address to the company you represent, company’s name and your title).

  • Your correspondence with our customer service.
 

Legal basis: Legitimate interest.

Tubus System has a legitimate interest in handling customer service matters by responding to and investigating its customers' questions and views.

    

Retention period: Until the customer service issue is resolved, or longer when necessary to defend and/or establish legal claims related to the performance of our services.

    

Purpose

Processing activities

Categories of personal data

Market our services

  • Structuring of personal data to contact you with relevant marketing in the newsletters.

  • Name.

  • Email address.

  • Company related information (address to the company you represent, company’s name and your title).
 

Legal basis: Legitimate interest.

Tubus System has a legitimate interest in marketing its services to you who represent one of our customers and where considered privacy risks for you have not been considered to override this interest.

    

Retention period: Tubus System will process the personal data for marketing purposes until you decline further communication from us.

    

Purpose

Processing activities

Categories of personal data

Invoicing of our service

  • Structure the documentation and produce an invoice and send it.

  • Name.

  • Contact information (email address and phone number).

  • Company related information (address to the company you represent, company’s name and your title).

     
 

Legal basis: Legal obligation.

The invoice that we issue to our customer constitutes a verification, which we have a legal obligation to save for seven years according to Chapter 7, Section 2 of the Swedish Accounting Act (Sw. Bokföringslagen (1999:1078)).

    

Retention period: The information contained in the invoice will be stored for [seven years] after the financial year in which it is issued.

    

Apartment owner

If you are an apartment owner with one of our customers, we may process your personal data to perform our services.

Purpose

Processing activities

Categories of personal data

Performance of our service

  • Communication with apartment owner to schedule, plan and perform our services.

  • Administration / control of service / work performed

  • Name.

  • Contact information (email address, phone number, address and postal code).

  • Tenant owners’ association / co-operative that you represent or are a member of.

  • Apartment number, where applicable.
 

Legal basis: Legitimate interest.

Tubus System has a legitimate interest in performing the services ordered by our customers.

    

Retention period: We will process your personal data during the time we have a customer relationship with our customer and one year thereafter, or longer if it is necessary to defend and/or establish legal claims related to the performance of the services.

    

Recruitment candidates

If you have applied for an advertised position with us, we will process your personal data to evaluate you as a candidate.

Purpose

Processing activities

Categories of personal data

Recruitment of new employees

  • Communicating with prospective employees.

  • Administrating the recruitment process.

  • Evaluation of job applications.

  • Interviewing candidates.

  • Name.

  • Contact information (email address, phone number, address and postal code).

  • Application documents (CV, cover letters, certificates).

  • Candidate assessment and candidate skills assessment.
 

Legal basis: Legitimate interest.

Tubus System has a legitimate interest in processing personal data about you who have shown interest in an advertised employment with us.

    

Retention period: Tubus System will process the information until the position is filled, which usually takes up to 6 months, or as long as necessary to defend and/or establish legal claims related to the recruitment, for a maximum of 2 years.

    

Supplier’s contact person

If you work as a contact person for one of our suppliers, we may process your personal data to place and follow up on orders.

Purpose

Processing activities

Categories of personal data

Manage purchases

  • Contact with contact person at supplier regarding ordering of material or service.

  • Name.

  • Contact information (email address and phone number).

  • Company related information (address to the company you represent, company’s name and your title).
 

Legal basis: Legitimate interest.

Tubus System has a legitimate interest in administering orders of goods and services.

    

Retention period: The personal data will be processed during the time the organisation you represent is a supplier to us.

    

Purpose

Processing activities

Categories of personal data

Manage transactions and bookkeeping

  • Processing the invoice and add it to the accounting journal. 

  • Name.

  • Company related information (address to the company you represent, company’s name and your title).
 

Legal basis: Legal obligation.

The invoice that we receive from our suppliers constitutes a verification, which we have a legal obligation to save for seven years according to Chapter 7, Section 2 of the Swedish Accounting Act (Sw. Bokföringslagen (1999:1078)).

    

Retention period: The information contained in the invoice will be stored for [seven years] after the financial year in which it is issued.

    

Subcontractor’s employee

If you are employed by one of the companies that we hire as a subcontractor in the performance of our customer assignments, we may need to process personal information about you in order to fulfil legal requirements.

Purpose

Processing activities

Categories of personal data

Administration of personnel ledger

  • Attendance management at the construction site in accordance with legal requirements.

  • Name.

  • Contact information (email address, phone number, address and postal code).

  • Company related information (address to the company you represent, company’s name and your title).

  • Social security number.

  • Construction site identification number.

  • Start and end time for work shifts.
 

Legal basis: Legal obligation.

According to Chapter 39 § 11a of the Swedish Tax Procedure Act (sw: Skatteförfarandelagen (SFS 2011:1244)) and Chapter 9 § 5 of the Swedish Tax Produre Regulation (sw: Skatteförfarandeförordningen (SFS 2011:1261)) Tubus System International AB is required to keep an electronic personnel ledger on each construction site.

    

Retention period: The information must be retained for two years after the end of the calendar year in which the tax year applicable to the business has expired.

    

4. With whom do we share your personal data?

External suppliers and systems are a natural part of and an important support for our business. We may share your personal data within the processing described above, with the following recipients:

(a) Suppliers of analytic tools for our website, and

(b) IT- and system suppliers.

Suppliers then process your personal data under our instruction and management, whose terms and limits are regulated and secured through data processing agreements. Through these agreements we require that the suppliers, as a minimum, meet the same strict requirements that we place on ourselves in our processing of your personal data.

5. Will we transfer your personal data outside of the EU/EEA?

Tubus System may transfer your personal data to suppliers where this means that your personal data is processed in countries outside the EU / EEA. Such processing may involve particular risk, as a provider in the country where the personal data is processed may not be covered by the protection provided by EU data protection laws. There are therefore special requirements for how such a transfer may take place and Tubus System controls its suppliers and ensures that protective measures are taken.

If the European Commission has not decided that a country to which your personal data is transferred meets the so-called adequate level of protection (equivalent level of protection as within the EU / EEA), which is the case for the subcontractors we have in the US, you are entitled to a description of which security measures is taken and the legal basis on which we base the transfer to ensure that the transfer of your personal data takes place in accordance with European data protection law. Please contact us by sending a written request to the contact details stated at the end of this privacy policy for information on whether we transferred your personal data to a country outside the EU / EEA, which countries we have transferred your personal data to and what security measures were taken for the transfer.

6. What rights do you have?

Below is a summary of the rights you have under the GDPR. It is free for you to exercise these rights and you can exercise them by contacting us, see our contact information at the end of this privacy policy. Do not hesitate to contact us if you have any questions regarding your rights.

Please note that Tubus System will always check your identity to ensure that information about you is provided to you and no one else.

Not all rights listed below are absolute. There are exceptions and we have tried to describe them as well as possible. If your request can not be fully met, we will clearly inform you why.

(a) Right of access. You are upon your request entitled to receive confirmation about whether Tubus System process your personal data, and if that is the case you have the right to receive a copy of your personal data as well as to obtain supplementary information about Tubus System’s processing of your personal data. 

(b) Right to rectification. You have the right to have your personal data corrected and/or completed if it is inaccurate and/or incomplete.

(c) Right to erasure. In some cases, you have the right to request that Tubus System delete your personal data, without undue delay. It is possible for us to meet such a request in full or in part in the following situations:

- the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;

- you withdraw your consent to a processing activity and there is no other legal basis for the processing;

- you make a valid objection to the processing of your personal data;

- the personal data has been unlawfully processed; or

- the personal data has to be erased for compliance with a legal obligation.

(d) Right to restrict processing. You have the right to request restriction  of the processing of your personal data under the following circumstances:

- the accuracy of the personal data is under examination;

- the processing is unlawful or is no longer needed for the purposes of the processing but you oppose the erasure of personal data and request restriction instead;

- Tubus System no longer needs the personal data but you need the personal data for the establishment, exercise or defence of legal claims; or

- you have objected to the processing of your personal data and such objection is under verification.

(e) Right to data portability. If the personal data is received from you, our processing is based upon your consent or the performance of a contract, and the information is processed digitally, you have the right to receive this personal information from us in a machine-readable format and transmit the data to another data controller.

(f) General right to object. You have the general right to, at any time, object to the processing of your personal data that is based on Tubus System’s legitimate interest. If you object, we have to demonstrate that we have compelling legitimate grounds for such processing or that we need the personal data for the establishment, exercise or defence of legal claims. Otherwise, we will cease to process your personal data for that purpose.

(g) Right to object to direct marketing. You have a right to, at any time, object to the processing of your personal data for direct marketing purposes. If you do this, Tubus System may no longer process your personal data for such purposes.

(h) Right to lodge complaint with a supervisory authority. You always have the right to lodge a complaint with a supervisory authority regarding Tubus System’s processing of your personal data. [Each EU and EEA Member State has its own supervisory authority, and you can find all supervisory authorities and their contact information here.]

7. How can you contact us?

You may contact us through the following communication channels:

Tubus System International AB
Designvägen 3
435 33 Mölnlycke
Telephone number: +46 (0)31 382 26 05
Email: info@tubussystem.com

8. Version history

We may from time to time need to update the information in our Privacy Policy. You can find the latest version on our website.

Current version 2022:01.

 

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Thank you for taking the time to read through our information about how we process your personal data!

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