Introduction

At Vargkläder AB (”Vargkläder”) we respect your privacy and apply an adequate protection of your data. This privacy policy explains how we collect and process your personal data. It also describes your rights and how you may take advantage of those rights. It is important that you read through this policy and feel comfortable with our processing of your personal data. You are also welcome to contact us in case you have questions around our processing of your personal data.

Data controller

The following company is the data controller responsible for the use of the data described in this policy:

Vargkläder AB

Swedish company registration number: 556917-2447
Datavägen 63
436 32 Askim

Sweden

Phone: +46 31-78 88 807

Email: info@vargklader.com

Who does this privacy policy apply to and what does it cover?

The information in this policy applies to you who, in one way or another, gets in contact with us and buys the products and services offered by Vargkläder, assuming that we are the responsible data controller.

What is personal data and what does processing of personal data mean?

‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

What personal data are we processing and what do we do with the data?

Processing of your personal data when buying a product or service/customer service matters and returns etc.

We process your personal data when you shop with us. This is done in order to process your order for various reasons, which could include e.g.:

• To manage any inquiries about our company, our website or our products
• To manage delivery of goods (such as sending notifications, dealing with issues around deliveries etc.)
• To ascertain identification and age control
• Handling of payment (including analysis of possible payment solutions, which may include a control check against payment history and collection of credit information from our partner Klarna)
• Making control checks of your address
• Handling complaints and warranty matters
• Communication and answering any questions to customer service (by phone or in digital channels, including social media)
• Investigation of any complaints

The categories of personal data processed are as follows:

• Name
• Social security number
• Contact information (e.g. address, e-mail and phone number)
• Payment history
• Payment information
• Credit information from credit information companies, if relevant
• Purchase information (e.g. which item has been ordered or whether the item is to be delivered to another address)
• Your correspondence with us
• Information about the time of purchase, place of purchase, any errors / complaints
• Technical information about your equipment

When processing your data to manage your purchase with us, the lawful basis for processing is that it is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract.

When processing your data for administering returns and complaints, the lawful basis is that the processing is based on our legitimate interest to provide our customers with efficient service after the purchase.

We store your personal data as long as it is necessary in order to comply with the above-mentioned purposes.

Processing of your personal data is also made when it is necessary for compliance with a legal obligation (e.g. to comply with legislations around bookkeeping, money laundering, product safety regulations etc.). We store your data as long as required by law.

We will only process your social security number when it is necessary to comply with a legitimate purpose, to ensure safe identification or any other legitimate reason.

Processing of personal data in connection with competitions, events etc.

At various types of competitions and events provided by Vargkläder, we may process your personal data for the following purposes:

• Communication before and after participating in a competition or event (e.g. confirmation of entries, questions or evaluations)
• To ensure identification and age control
• To select winners and distributing prices

The categories of personal data processed are as follows:

• Name
• Social security number or age
• Contact information (e.g. address, e-mail and telephone number)
• Information provided in competition entries
• Information provided in evaluations of events

The lawful basis for such processing is that it is necessary to satisfy our and your legitimate interest in managing your participation in competitions and/or events. We save your personal information during the time that the competition / event (including any evaluation) takes place. In cases of taxes to be paid by the winner, the archiving rules of the relevant ‘accounting act’ or similar applies.

We will only process your social security number when it is necessary to comply with a legitimate purpose, to ensure safe identification or any other legitimate reason.

Newsletters

We will process certain basic detail for the purpose of sending out such newsletter. The legal basis for such processing is that we have a legitimate interest to send such newsletter. You may unsubscribe to our newsletter at any time by clicking on the unsubscribe link or by contacting customer service at info@vargklader.com. We will send you the newsletter until you unsubscribe to the newsletter service.

From which sources do we collect your personal data?

In addition to the information you provide to us, or which we collect from you based on your purchase and how you use our services, we may also collect personal information from someone else (so-called third party).

The information we collect from third parties are as follows:

1) Address information from public registers to be sure that we have the correct address for you.

2) Credit rating information from credit rating agencies, banks or information companies.

Which parties do we provide your personal data to?

Personal data processors. We may share your personal information with companies that are our personal data processors. A personal data processor is a company that process the information on our behalf and according to our documented instructions. We work with data processors who assist us with matters such as:

1) Payment solutions providers (credit card companies, banks and other payment service providers) such as Klarna, Izettle.

2) Marketing / newsletter service providers (print and distribution services, social media, media agencies or advertising agencies etc.).

3) IT service providers (companies that handle the necessary operation, technical support and maintenance of our IT solutions).

When your personal data is shared with such data processors, it is only for purposes that are compliant with the purposes for which we have collected the information (e.g. to be able to fulfil our contractual obligations under the purchase agreement). We review all of our data processors to ensure that they can provide adequate guarantees regarding the security and confidentiality of your personal data.

We have entered into agreements with all data processors through which they guarantee the security of the personal data processed and undertake to comply with our security requirements as well as restrictions and requirements regarding international transfer of personal data.

Personal data controllers. We may also share your personal data with certain companies that are independently responsible for the processing of your personal data. The fact that the company is independently responsible for your personal data means that we are not the ones who control how the information provided to the company is to be processed. When your personal data is shared with a company that is independently responsible for personal data, that company’s privacy policy and personal data management apply.

Independent personal data controllers with whom we share your personal data are:

1) Companies that take care of the transport of goods (e.g. logistics companies).

2) Companies that offer payment solutions (credit card companies, banks and other payment service providers).

The data processors mentioned above could also, in certain circumstances, be regarded as data controllers.

Your personal data will not be passed on by us or our representatives for the use of additional third parties in any form, unless we have received your permission or are obliged to do so by law or if it is an approved data sub-processor. Certain personal data may be stored or processed in jurisdictions outside the EU and the EEA area, whose regulations on personal data may differ from EU regulations. In such cases, we ensure that appropriate protection measures are taken to ensure that those who process data in that country maintain a personal data protection that is equivalent to those which exist in the EU/EEA.

For how long do you store my personal data?

We store your personal data as long as it is necessary for the relevant purpose, please see further details under section 5 above. We have also implemented routines for erasing data which is no longer necessary.