This notice applies to personal data processed in conjunction with a general meeting of shareholders ("GM") in AB Industrivärden (publ) ("Industrivärden"), regarding shareholders of the Company, as well as any other individual visiting or otherwise connected to a GM ("you" or "your").
This notice explains what types of personal data are gathered about you, how the personal data is used, and with whom the personal data is shared. It also describes your rights in relation to personal data.
Who controls your personal data?
We, Industrivärden, with registered office in Stockholm, Sweden and corporate registration number 556043-4200, are the controller of the processing of your personal data performed by us or our service providers in connection with the GM. Please note that in some cases, we may be regarded as joint controllers together with a third party service provider and a third party service provider may also be the sole controller if that is stipulated by law.
Updates of this privacy notice
This notice may be updated from time to time to comply with changing legal or technical requirements as well as business developments. You can see when it was last updated by checking the "last updated" date displayed at the first page of this notice. Please consider the version available online as the latest version.
2. PERSONAL DATA AND PROCESSING OF SUCH DATA
2.1 What personal data do we process and why?
In connection with a GM, including the preparation of a GM as well as work conducted following a GM, we process personal data regarding you consisting of:
contact details (e.g. name, title, address, telephone number and email address);
identification details (e.g. date of birth and ID number);
financial information (e.g. voting rights, information regarding holdings and entitlements connected to the holdings);
recording of images, photographs, video and sound, to the extent resolved by the GM;
if a proxy is appointed, information on who you are representing or are represented by (as relevant);
if a shareholder or a proxy gives notice of attendance for assistant(s) to attend the GM, information regarding who you assist or are assisted by (as relevant);
information on how you have voted may be processed, e.g. if voting devices are used or vote counting is carried out and to the extent your voting is possible to connect to you based on your holdings (e.g. in some cases a certain number of votes may be connected to a certain number of shares held by you); and
notes in the minutes from the GM (e.g. dissenting opinions or when exercising the right as shareholder to propose business at the GM or ask questions).
Our purpose for collecting and processing your personal data is to carry out a GM and providing services in connection therewith as well as to comply with applicable law and regulations.
What are the legal bases for our processing of your personal data?We process your personal data when:
it is necessary to comply with our legal obligations; or
it is in our legitimate interests to do so, e.g. to maintain adequate security or order at the GM, and such interest is not overridden by your legitimate interests or fundamental rights and freedoms which require the protection of personal data.
How long do we keep the personal data?
Personal data related to the GM is kept for as long as necessary given the purpose of the processing, unless otherwise required or permitted by applicable laws or regulations.
Personal data that is only required to carry out the GM will normally be deleted shortly after the conclusion of the GM. Personal data regarding attendance, holdings, voting etc. which is processed to carry out and document the GM according to law will be stored as required or permitted by applicable laws or regulations.
For example, personal data included in the GM share register (your name, address, ID- number and holdings) must be stored for a period of ten years following the GM, in accordance with rules issued by Euroclear Sweden AB. Personal data included in the minutes from the GM will be stored during a period of ten years following the GM, unless storage during a longer period is justified based on the resolutions adopted at the GM or otherwise.
Where does your personal data come from?
The personal data we collect about you comes from the following sources:
(i) Personal data you give us
We collect personal data we directly receive from you, e.g. when you send us personal data on forms, e-forms and e-mails, provide us personal data via the phone or provide us personal data during the GM.
(ii) Personal data we receive from other sources
We may receive your personal data through:
information received from public records;
information received from third party service providers in connection with the GM (such as Euroclear Sweden AB or legal advisors); or
the shareholder you represent or your proxy (if relevant).
2.5 With whom may we share your personal data?
Transfer within the Group or to third parties
We may transfer personal data to other affiliated entities or business partners to the extent necessary in connection with the GM. We take precautions to allow access to personal data only to those staff members who have a legitimate business need for access and with a contractual prohibition of using the personal data for any other purpose.
We may provide personal data to any competent law enforcement body, regulatory, government agency, court or other third party such as but not limited to, the police, the financial supervisory authorities and the tax agency, where we believe disclosure is necessary (i) as a matter of applicable law or regulation, or (ii) to exercise, establish or defend our legal rights.
We may disclose personal data to our third party vendors, service providers and partners who provide services to us (e.g. third party consultants working with the GM, law firms/advisors or security agents), which are or will be involved in providing services in connection with the GM or who otherwise process personal data for purposes that are described in this privacy notice or as notified to you when we collect your personal data.
We may disclose personal data to our auditors, advisors, legal representatives and similar agents as may be necessary in connection with the advisory services they provide to us for legitimate business purposes and under contractual prohibition of using the personal data for any other purpose.
We may provide the list of notices of attendance (which contains names of shareholders together with information regarding their number of shares and votes, and information on their respective proxy and/or assistant(s), if any) to the participants in the GM as the basis for determining the voting list at the GM.
We may disclose personal data to other shareholders who request a copy of the minutes from the GM.
We may also publish certain information containing personal data on our website, to the extent we are obliged to do so according to law or other regulation (e.g. minutes from the GM).
(ii) International personal data transfers
Our third party contractors and consultants operate around the world. This means that we may process personal data outside the European Economic Area (EEA) in jurisdictions which may not have an adequate level of protection. However, we have taken appropriate safeguards to require that your personal data will remain protected in accordance with this notice. These measures include, where applicable, implementing EU standard contractual clauses. Such contractual clauses are available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.If other safeguards are used, we will provide additional information to you regarding such safeguards (as indicated in the notice to the GM).
2.6 What are your rights in respect to your personal data?
The right to be
We are publishing this privacy notice to keep you informed as to what
we do with your personal data. We strive to be transparent about how we
use your personal data.
The right to access
You have the right to access your personal data. You have a right to
receive a copy of your personal data processed by us.
The right to
If your personal data kept by us is inaccurate, not complete or up to date,
you have the right to ask us to rectify or update the data. If such personal
data has been disclosed to a third party in accordance with this privacy
notice, we will also ask them to rectify or update your personal data (if
The right to erasure
You have the right to request that we erase your personal data and if we
(the right to be
do not have a legal reason to continue to process and hold it, we will
erase the data.
The right to object
You have the right to object to certain processing of your personal data.
The right to restrict
In some cases, you have the right to request that we restrict the
processing of your personal data. This means we are permitted to store
the data but not to process it further unless with your consent or with
respect to legal claims.
The right to data
In some cases, you are allowed to obtain your personal data kept by us in
a structured, commonly used and machine-readable format and to
transmit those personal data to another controller.
This is an excerpt of the original content. To continue reading it, access the original document here.
AB Industrivärden published this content on 26 October 2021 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 26 October 2021 09:25:07 UTC.