PRIVACY POLICY

PRIVACY NOTICE

NJIE Foods AB, corporate ID number 556761-7518 (hereinafter referred to as the “Company” or “We”), is the controller in relation to the processing of Personal Data through our digital channels, such as this website and the websites Lowcaly.se and Propud.com. The aim of this Privacy Notice is to ensure that you, as a user, feel assured that we, as the controller, will process your data in accordance with applicable privacy legislation.

INTRODUCTION

Please bear in mind that when you have accepted our Tracking Technology Notice, Privacy Notice and other terms, conditions and policies that we present to you in any of the digital channels and/or any of the products, offers, functions, tools, services or resources that we use (hereinafter referred to as the “Services”), you may approve our processing of Personal Data about you. The processing of Personal Data is necessary for us to be able to provide the Services to you. There is no requirement that you must provide any Personal Data in order to visit the digital channels/Services, but if you do not provide the necessary information or express consent in the cases where this is required, it is possible that you will not be able to receive the Services or visit all parts of the digital channels in full.

Please contact us if you are unable to find the information you require. Our contact details are provided below under the heading “Contact Details”.

PROCESSING OF PERSONAL DATA

The term Personal Data refers to all types of information that can be directly or indirectly attributed to a living natural person.

Collection and processing of your Personal Data only takes place with your consent or on the basis of an existing contract or legal obligation, for example when we must save the data pursuant to applicable legislation, or in cases where we need such data in order to be able to complete delivery of the Services. Exceptions are made in cases where prior consent is not possible for practical or technical reasons and the processing of the data is permitted on a legal basis.

In certain situations, we need to collect Personal Data in order to be able to provide the Service. Such situations could, for example, arise when we arrange competitions and we need to be able to get in touch with a possible winner. The data collected could include, but is not limited to, name, email address, phone number, address, answers and/or entries for a competition, user name or alias on social media, or media submitted in relation to a competition.

The more technical types of Personal Data processed could include IP address, type of device, date and time of visit, interaction with ads, user behavior on websites or other data collected by tools we use.

All processing of Personal Data is subject to a legal basis. We refer here to article 6 of GDPR regarding lawfulness of processing.

CUSTOMER DATA

In order for us to handle your orders and purchases, we need information about your name, address, phone number, email address, personal ID number (in some cases), payment details and payment method, as well as other information about your order, such as product, delivery address and order number. We save this data for 36 months from the date of delivery and payment in order to assist you in case of complaints or other warranty issues. The legal basis for the processing in this case is our contractual relationship with you in accordance with our General Terms of Use.

We also need to save information about you in the form of your name, address, payment details and payment history, as well as other information about your order, for up to 7 years + the current year pursuant to the Swedish Accounting Act. This type of information is limited to our Finance Department, and the legal basis for the processing in this case is our statutory legal obligation.

When contacting customer service, we usually need information from you in the form of your name, phone number, email address, personal ID number, payment details and payment history, information about your order, as well as other information that you provide to us in the communication regarding your case. We save this type of information for 14 months from when your case is closed. The legal basis for the processing in this case is consent on your part and legitimate interest on our part, as the processing is necessary for the purpose in question.

In order for us to maximize your user experience on our website, and to give you the best possible product recommendations, we process information about your IP address and other data collected by cookies and the like, such as the products you have clicked on, your favorites and your shopping history. You approve this information by consenting to the use of cookies when you first visit our website. You can clear your cookie data at any time, but doing so may affect your experience of the website and may cause some features to not function properly. The legal basis for the processing in this case is consent on your part and legitimate interest on our part, as the processing is necessary for the purpose in question.

You can learn more about the collection, sharing and use of data, as well as how to limit the collection of data in other channels, by clicking on the following links:

Google

Facebook

When you register for our newsletter, we will obtain your consent to process Personal Data which may include, but is not limited to, your name, address, phone number, email address and other information you actively choose to provide, such as gender, age, product preferences, etc. If you choose to cancel your registration for our newsletter through an “opt-out”, we will immediately stop sending newsletters to you. We may save your information for up to 3 months after you cancel your registration by opting out. The legal basis for the processing in this case is consent on your part and legitimate interest on our part, as the processing is necessary for the purpose in question.

In order to prevent the abuse of our services or to prevent crime, we process information about your name, address, phone number, email address, payment details (such as repeated entries of incorrect card number), returns or deliveries, IP number, customer notes and customer service history. We save this type of information for 36 months after closing the case. The legal basis for the processing in this case is legitimate interest.

In order to improve our services, products and systems, as well as analyze data, we process information regarding your purchasing and user behavior (such as click and visit history), technical data regarding settings on various devices, such as language, platform, operating system and IP address, information about how you interact with us, such as how you log in, where you visit the website, when you leave the website, how you navigate on the website, etc. We do this by way of analysis at an aggregate level, i.e. the analysis is general and not at an individual level. We save such data as the basis for the analysis for one year from your last activity, after which we then pseudonymize the data, which means that it is not possible to see who the data belongs to. The legal basis for the processing in this case is legitimate interest.

If you return within two years of the date on which we pseudonymised your data, we link your data with your previous visit to our website and are thus able to see that you are a repeat customer and can better understand how repeat customers generally use our website. However, if more than two years have passed since we pseudonymised your data, we are no longer able to link your data, and your history is empty. If you contact us with a request to exercise your right to erasure (right to be forgotten), we will, of course, not be able to link any information about you.

SENSITIVE PERSONAL DATA IS NOT PROCESSED

Sensitive Personal Data is data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as personal data relating to health or sexual life. Data relating to health could, for example, be information about sick leave, pregnancy and medical examinations. We do not process any sensitive Personal Data within the scope of the Services.

WHAT DO WE USE PERSONAL DATA FOR?

The Company uses the collected Personal Data to process consumer matters in the form of complaints, communication, administration of competitions and other contact-related purposes when using the contact form on the website as well as email and contact via social media. Unless we have your permission, we will not disclose your Personal Data to another party in any way other than as described in this Privacy Notice, unless we are obligated to do so pursuant to the legal regulations in force at any given time, and to be able to complete the delivery of services such as, for example, the sending of a prize in connection with a competition.

DISCLOSURE OF INFORMATION TO ANOTHER PARTY

In addition to what is stated in this Privacy Notice, situations may arise in certain circumstances where we need to share the Personal Data you have provided with a third party, in order to be able to fulfil our obligation to provide the Service to you. In this context, the term third party does not refer to an individual or legal entity that directly or indirectly controls, is controlled by or is otherwise under the same control as the specified controller (hereinafter referred to as “Group Company”). Relevant Group Companies that receive the Personal Data will process such data in accordance with this Privacy Notice and applicable legal regulations at any given time.

We will not sell your Personal Data to a third party (excluding Group Companies) in any respect.

However, we may hire subcontractors for services in connection with our digital channels or the Services (processors). These subcontractors may process Personal Data and may need certain access to Personal Data collected via these channels or the Services, for example cloud service providers with whom Personal Data may be stored. We will always limit such subcontractors’ access to the Personal Data needed for us to be able to offer you access to our digital channels or the Services. We will also require these subcontractors to (i) protect your Personal Data in accordance with this Privacy Notice, and (ii) not use or disclose your Personal Data for any other purpose than to provide us with agreed products or services so that we, in turn, will be able to offer you access to our digital channels or the Services.

TRANSFERS TO THIRD COUNTRIES

In order to be able to provide our Services, it may in some cases be directly or indirectly necessary for us to transfer Personal Data to a third country (i.e. a country outside the EU/EEA), for example if we send out newsletters from a global service provider whose service is located on servers outside the EU/EEA.

CONSENT

When you approve this Privacy Notice, you consent to our use and processing of your Personal Data in accordance with this Privacy Notice. We recommend that you also read our Tracking Technology Notice before you approve our use of cookies and other such technologies on our websites.

If you do not accept what is stated in this Privacy Notice, please do not use the digital channels or the Services.

You can withdraw your consent at any time without this affecting the lawfulness of the processing that took place on the basis of your consent before it was withdrawn.

CHANGES TO THIS PRIVACY NOTICE

We reserve the right to make changes to this Privacy Notice at any time and without prior notice. Where possible, we will notify the parties concerned immediately. We recommend that our visitors read this Privacy Notice periodically. Adjustments to this Privacy Notice mainly take place in situations where a new law has come into effect, but also in cases where new agreements have been produced regarding the privacy of individuals in digital media, or if we consider it justified to make changes to this Privacy Notice for other reasons.

ERASURE OF DATA

Your Personal Data will not be stored for longer than is necessary with regard to the purposes of the processing, and we will otherwise erase Personal Data in a manner that complies with applicable legal regulations at any given time.

RIGHT TO REQUEST INFORMATION

You have the right to request, free of charge, information about the Personal Data (if any) we process about you (a register extract), and you also have the right to have any inaccurate data rectified. You can send us a written and signed request if you want to know whether we process Personal Data about you (our contact details are provided below).

When you send us your request, you need to specifically specify which data you are interested in (unless you are interested in all types of data), e.g. contractual documents, customer service correspondence, etc. In this way, we can provide you with the information that is relevant to you. If you submit a request for a register extract multiple times, we may charge a fee or, in certain statutory cases, refuse to comply with your request.

The register extract will be sent to you within 30 days of the date on which we receive your request. If the extract is so extensive that we need more time, or if, for some reason, we cannot complete your request, we will notify you to this effect.

RIGHT TO RECTIFICATION

In order to fulfil our obligations in terms of always having correct and relevant Personal Data, we work systematically with our registers and update Personal Data as necessary. If you notice that the information we possess about you is inaccurate or that we are missing important information, you have the right to have your data rectified. We normally rectify simple information without the need for special consideration, but in other cases we may need to consider your request. We will not approve your request if it is impossible or requires a major effort. If you so request, we will also inform you about the party or parties to whom the rectification has been disclosed.

If your Personal Data is changed at your request, we will provide information about the updated data to any suppliers and business partners to whom we have disclosed the data.

RIGHT TO BE FORGOTTEN

We save your Personal Data as long as you are our customer or as long as we otherwise need to save the data in order to be able to fulfil our obligations to you, or otherwise according to applicable law. The data is then erased.

You have the right to request that we erase your Personal Data if:

  • the data is no longer needed for the purposes for which the data was collected, and for which we process the data;
  • we process Personal Data based on your consent, and you withdraw your consent;
  • we process Personal Data for direct marketing, and you object to continued processing of the Personal Data for this purpose;
  • we process Personal Data based on an assessment of legitimate interest, and there are no legitimate grounds for the processing which override your interests;
  • we are not processing Personal Data in accordance with applicable regulations;
  • it is necessary to erase Personal Data in order to fulfil a legal obligation.

However, we have the right not to erase your Personal Data if we need to retain the data in order to fulfil a legal obligation or some other obligation to you.

When we receive your request, we will perform an assessment as to whether there are grounds to erase your Personal Data, after which you will be notified of our assessment. If we erase your Personal Data at your request, we will inform any suppliers and business partners to whom we have disclosed the data that the data has been erased. However, we will not do this if it is impossible or requires a major effort.

RIGHT TO OBJECT

You have the right to object to our processing of your Personal Data which we perform based on an assessment of legitimate interest according to law, in which case you need to specify in writing which processing you are objecting to. In we receive such an objection, we may only continue the processing if we can demonstrate that there are compelling legitimate grounds for the processing which override your interests.

If, however, your Personal Data is processed for direct marketing, you always have the right to object to the processing at any time.

RIGHT TO RESTRICTION OF PROCESSING

You have the right to request restriction of our processing of your Personal Data when:

  • you have contested the accuracy of the Personal Data, for a period enabling us to verify the accuracy of the Personal Data;
  • the processing is unlawful and you oppose the erasure of the Personal Data and instead request a restriction of the use of the data;
  • we no longer need the Personal Data for the purposes of the processing, but you require the data for the establishment, exercise or defence of legal claims;
  • you have objected to processing pending verification of whether our legitimate grounds override your legitimate interests.

Restriction means that the Personal Data will be marked so that the data may only be processed for certain limited purposes in the future.

RIGHT TO DATA PORTABILITY

If you have provided your Personal Data to us, you have the right, in certain cases, to receive your Personal Data and e.g. move the data to another company.

In order for you to be able to exercise your right to data portability, your request must relate to Personal Data that you have provided to us and that we process on the basis of consent from you or to perform a contract we have with you. The right to data portability does not apply when our processing of your Personal Data is based on an assessment of legitimate interest or a legal obligation.

RIGHT TO SUBMIT A COMPLAINT

If you have a complaint or objection regarding our processing of your Personal Data, please contact us in the first instance so that we can help you in the best possible way. However, please be aware that you always have the right to submit a complaint directly to the supervisory authority for privacy issues, which in Sweden is the Swedish Authority for Privacy Protection (IMY).

SECURITY

We take the security of your Personal Data very seriously, and we have therefore implemented technical and organizational security measures to protect your data from accidental, intentional or unlawful destruction, loss, alteration, unauthorized disclosure of or access to the data.

However, despite our efforts to maintain a high standard of security, it should be noted that no transmission of information over the internet is completely secure. While we strive to protect your Personal Data, we cannot guarantee the security of the information transmitted to or from our website. All transmission of data takes place at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

We also recommend that each individual should take responsibility for their own information and should take steps to protect their information to the greatest extent possible.

CONTACT DETAILS

If you wish to submit a request in accordance with your rights as described above, such request must be made in writing and sent to us at the address below. If you have any questions about this Privacy Notice or our processing of Personal Data, you can contact us at:

NJIE Foods AB
Corp. ID no. 556761-7518
info@njie.com
+46 31 380 20 90
Krokslätts Fabriker 30
431 37 Mölndal, Sweden

We take the security of your Personal Data very seriously, and we try to do everything we can to prevent your data from falling into the wrong hands. Any request must therefore be made in writing and signed by you, and the request must also be accompanied by a signed copy of valid ID (e.g. a passport or driver’s licence).