Last updated: 29 April 2022

Privacy Policy

Estrid Sweden cares about privacy and protecting the Personal Data handled by us. All Personal Data is Processed in accordance with Applicable Law. In this Policy we describe how and the purposes for which we use your personal information as well as what lawful basis we use and what measures we take to protect Personal data. We also provide information on how you exercise the rights you have linked to our Processing of Personal data.

WHY AND WHO?


Estrid Sweden AB Reg. No. (559197-2400) ("Estrid Sweden", "we", "us", "our") is the Controller of all Personal Data listed in this Privacy Policy (the "Policy") which covers all Estrid Sweden brands: Estrid and April. In order to be fully transparent regarding where your Personal Data is stored and Processed, we will also provide a list of categories of recipients to whom the personal data will be disclosed (“Our Processors” below). This Policy provides information on how we handle Personal Data when you communicate with us or visit our websites www.estrid.com and/or www.itsapril.com (together the "Functions").

The intended recipient of the information provided in this Policy is:

  • Customers

  • Visitors of our website

DEFINITIONS


"Applicable Law" refers to the legislation applicable to the processing of Personal Data, including the GDPR, supplementary national legislation, as well as practices, guidelines and recommendations issued by a national or EU supervisory authority.

"Controller" is the company/organisation that decides for what purposes and in what way personal data is to be processed and is responsible for the Processing of Personal Data in accordance with Applicable Law.

"Data Subject" is the living, natural person whose Personal Data is being processed.

"Personal Data" is all information relating, directly or indirectly, to an identifiable natural person.

"Processing" means any operation or set of operations which is performed on Personal data, e.g. storage, modification, reading, handover and similar.

"Processor" is the company/organisation that processes personal data on behalf of the Controller and can therefore only process the Personal Data according to the instructions of the Controller and the Applicable Law.

The definitions above shall apply in the Policy regardless if they are capitalised or not.

ESTRID SWEDEN'S ROLE AS A CONTROLLER


The information in this Policy covers Personal Data Processing for which Estrid Sweden is the Controller. As a Controller we are responsible for the Processing for which we decide the purpose of ("the why") and the means for the Processing (what methods, what personal data and for how long it is stored). The Policy does not describe how we Process Personal Data in the role of a Processor - i.e. when we process Personal Data on behalf of our customers.

Estrid Sweden provides products on a subscription basis and we therefore collect and store data so that we can, among other things, create user accounts, ship products, and communicate with our customers.

ESTRID SWEDEN'S PROCESSING OF PERSONAL DATA


We have a responsibility to describe and demonstrate how we fulfill the requirements that are imposed on us when we Process your Personal Data. This section aims to describe:

  • That Processing of Personal Data is necessary for the purpose

  • That we have identified the lawful basis for the Processing

    LAWFUL BASIS


Consent - Estrid Sweden may process your personal data after you have given your consent to the Processing. Information regarding the processing is always provided in connection to the request of consent.

Performance of a contract - The Processing is necessary for the performance of a contract entered between us and the Data Subject, or to prepare for entering into an agreement with the Data Subject.

Legitimate interest - Estrid Sweden may process Personal Data if we have assessed that a legitimate interest overrides the interest of fundamental rights and freedoms of the Data Subject, and if the processing is necessary for the purpose in question.

Legal obligation - We are required by laws and regulations to process Personal Data as a result of our business.

PROCESSINGS AND FOR HOW LONG WE STORE YOUR PERSONAL DATA


We will keep your personal data as long as it is necessary for the purpose for which it was collected, for instance as long as you have an active agreement (subscription) with us, as well as 3 years after the agreement has been cancelled. In the list below, we indicate, where possible, the period during which the Personal Data will be stored and the criteria used to determine the storage period.

1. Processing and purpose of Processing: Handle orders and purchases

Personal Data: Name, email address, delivery address, billing address, payment method, subscription and order information (products ordered, subscription frequency, order number etc.)
Source: Directly from the Data Subject and from our order management system
Lawful basis: Contract (Terms & Conditions)
Storage period: The data is stored during the time you have an active agreement (subscription) with us, as well as 3 years after the agreement has been cancelled.

2. Processing and purpose of Processing: Creation of an account

Personal Data: Name, email address, delivery address, billing address, phone number, payment method, subscription and order information (products ordered, subscription frequency, order number etc.)
Source: Directly from the Data Subject and from our order management system
Lawful basis: Contract (Terms & Conditions)
Storage period: The data is stored during the time you have an active agreement (subscription) with us, as well as 3 years after the agreement has been cancelled.

3. Processing and purpose of Processing: Provide customer service

Personal Data: Name, email address, delivery address, billing address, phone number, payment method, subscription and order information (products ordered, subscription frequency, order number etc.)
Source: Directly from the Data Subject and from our order management system
Lawful basis: Contract (Terms & Conditions)
Storage period: The data is stored during the time you have an active agreement (subscription) with us, as well as 3 years after the agreement has been cancelled.

4. Processing and purpose of Processing: Follow applicable law such as for accounting purposes

Personal Data: Name, delivery address, billing address, email address, phone number, payment method, subscription and order information (products ordered, subscription frequency, order number etc.)
Source: Directly from the Data Subject and from our order management system
Lawful basis: Legal obligation (Bokföringslagen)
Storage period: 7 years as according to the law

5. Processing and purpose of Processing: Personalized communication and marketing via email and SMS

Personal Data: Name, delivery address, billing address, email address, phone number, demographics (e.g., age), subscription and order information (products ordered, subscription frequency, order number etc.), data from cookies (for example which products you have clicked on)
Source: Directly from the Data Subject, from our order management system, and from first and third party analysis technology (cookies etc.)
Lawful basis: Legitimate interest
Storage period: The data is stored during the time you have an active agreement (subscription) with us, as well as 3 years after the agreement has been cancelled.

6. Processing and purpose of Processing: Receive newsletters

Personal Data: Email address
Source: Directly from the Data Subject
Lawful basis: Consent
Storage period: The data is stored during the time you have an active agreement (subscription) with us, as well as 3 years after the agreement has been cancelled.

7. Processing and purpose of Processing: Develop, improve and analyse our business, processes and services

Personal Data: Name, email address, delivery address, billing address, payment method, subscription and order information (products ordered, subscription frequency, order history etc.), data from cookies (for example which products you have clicked on)
Source: Directly from the Data Subject, from our order management system, and from first and third party analysis technology (cookies etc.)
Lawful basis: Legitimate interest
Storage period: The data is stored during the time you have an active agreement (subscription) with us, as well as 3 years after the agreement has been cancelled.

8. Processing and purpose of Processing: Collect product reviews

Personal Data: Name, subscription and order information (order history etc.), your review
Source: Directly from the Data Subject and from our order management system
Lawful basis: Consent
Storage period: The data is stored until you actively ask to remove your product review, or at the longest for 10 years.

YOUR RIGHTS


You are the one in control of your Personal data and we always strive to ensure that you can exercise your rights as efficiently and smoothly as possible.

Access - You always have the right to receive information about the Processing of data that concerns you. We only provide information if we have been able to verify that it is you that is requesting the information.

Rectification - If you find that the Personal Data we process about you is incorrect, let us know and we will fix it!

Erasure - Do you want us to completely forget about you? You have the right to be forgotten and request deletion of your Personal Data when the Processing is no longer necessary for the purpose for which it was collected. If we are required to retain your information under applicable law or a contract that we have entered with you, we will ensure that it is processed only for the specific purpose set forth in such applicable law or contract. We will thereafter erase the information as soon as possible.

Objections - Do you disagree with our assessment that a legitimate interest for Processing your Personal Data overrides your interest in protecting your privacy? Don’t worry - in such case, we will review our legitimate interest assessment. Of course, we add your objection to the balance and make a new assessment to see if we can still justify our Processing of your Personal Data. If you object to direct marketing, we will immediately delete your personal information without making an assessment.

Restriction - You can also ask us to restrict our Processing of your Personal Data

  • Whilst we are Processing a request from you for any of your other rights;

  • If, instead of requesting erasure, you want us to limit the Processing of Personal Data for a specific purpose. For example, if you do not want us to send advertising to you in the future, we still need to save your name in order to know that we should not contact you; or

  • In cases where we no longer need the information in relation to the purpose for which it was collected, provided that you do not have an interest in retaining it to make a legal claim.

    Data portability - We may provide you with the data that you have submitted to us or that we have received from you in connection with a contract that we have entered with you. You will receive your information in a commonly used and machine-readable format that you can transfer to another personal data manager.

    Withdraw consent - If you have given consent to one or several specific processing(s) of your Personal Data, you have the right to withdraw your consent at any time and thus ask us to terminate the Processing immediately. Please note that you can only withdraw your consent for future processing of Personal Data and not for Processing that has already taken place.

    HOW YOU USE YOUR RIGHTS


Contact us at [email protected] if you have any questions or would like to access your personal data.

TRANSFER OF PERSONAL DATA AND OUR PROCESSORS


In order to run our business, we may need help from others who will process Personal Data on our behalf, so-called Processors.

We have entered into Data Processing Agreements (DPA) with all our Processors. The DPA sets out, among other things, how the Processor may process the Personal Data and what security measures are required for the Processing.

We will share your personal data such as name, email address, delivery address, and IP address to our Processors within the categories: IT service providers, communication platforms, and marketing platforms (data is encrypted after upload).

We may also need to disclose your personal information to certain designated authorities in order to fulfil obligations under applicable law or legally binding judgements.

TRANSFER OF PERSONAL DATA OUTSIDE EU/EEA


In cases where our Processors transfer Personal Data outside the EU/EEA, we have ensured that the level of protection is adequate, and in compliance with Applicable Law, by controlling that either of the following requirements are fulfilled:

  • The EU Commission has determined that the level of protection is adequate in the third country where the data is processed;

  • The Processor has signed up to the EU Commission's standard contract clauses (SCCs) for data transfer to non-EU/EEA countries; or

  • The Processor has taken other appropriate safeguards prior to the transfer and that such safeguards comply with Applicable law.

    TRANSFER OF PERSONAL DATA TO ANOTHER CONTROLLER


We share your Personal Data with delivery service providers, payment service providers, and our warehouse partner in order to be able to deliver according to the contract. We also share your Personal Data with our partners (such as advisors and financial institutions) to develop, improve and analyse our business, processes and services. For more information about their processing of your data, we kindly ask you to contact the respective Controller.

SECURITY MEASURES


Estrid Sweden has taken technical and organisational measures to ensure that your Personal Data is processed securely and protected from loss, abuse and unauthorised access.

Our security measures

Organisational security measures are measures that are implemented in work methods and routines within the organisation, such as:

  • Login and password management

  • Physical security (premises etc.)

Technical security measures are measures implemented through technical solutions, such as:

  • Encryption

  • Pseudonymisation

  • Access control level

  • Access log

  • Secure network

  • VPC

  • VPN

  • Firewall

  • Back-up

  • Two-step verification

    COOKIES


Estrid Sweden uses cookies and similar tracking techniques to analyse the use of the Functions so that we can give you the best user experience.

IF WE DON'T KEEP OUR PROMISE


If you think that we are not Processing your Personal Data correctly, even after you have notified us of this, you are always entitled to submit your complaint to the Swedish Authority for Privacy Protection.

More information about our obligations and your rights can be found at https://www.imy.se/

You can contact the authority via e-mail at: [email protected]

CHANGES TO THIS POLICY


We reserve the right to make changes to this Policy. In the event that the change affects our obligations or your rights, we will inform you about the changes in advance so that you are given the opportunity to take a position on the updated policy.

CONTACT


For questions, reach out to us at [email protected].

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