Vimian Group Privacy Notice for Sharing of Personal Data

Implemented: Version: February 2024 1.0

1. INTRODUCTION

Vimian Group is a global animal health company with businesses operating within different areas relating to animal health. To facilitate cooperation between our businesses, tailor our communication to our customers, allow the businesses to make analyses to follow-up, evaluate and to improve our business models, offerings, and strategies, and to provide a better customer experience, the businesses within the Vimian Group share information, including personal data, that the businesses have collected, among themselves.

Being transparent with our processing of personal data and compliance with applicable data protection legislation, including the EU General Data Protection Regulation (GDPR), are priorities within the Vimian Group.

The purpose of this privacy notice for sharing of personal data (the “Privacy Notice”) is to describe and keep you informed about which businesses within the Vimian Group that share personal data with each other, for which purposes, and the legal basis for the sharing.

This Privacy Notice supplements each business’ own existing external privacy notice, which describes how each business collects, uses, shares, or processes personal data. For further information on how the specific business processes your personal data, please read the business’ external privacy notice. Links to the businesses’ external privacy notices are included in Section 11 below.

If you have any questions on how the businesses within the Vimian Group process and share your personal data, please reach out to us by contacting us on the contact details outlined in Section 9 below.

2. SHARING OF PERSONAL DATA

In this Privacy Notice:

  • “Personal data” means any information that, directly or indirectly, relates to an identifiable individual. Examples of personal data are name, e-mail address, but also details about your pet.
  • “Sharing” means when a business (a data exporter) within the Vimian Group transfers or otherwise makes available personal data to another business (a data importer) within the Vimian Group in accordance with this Privacy Notice.
  • “We, us, or our” means the businesses within the Vimian Group covered by this Privacy Notice, which are outlined in Section 11 below.

3. WHO IS COVERED BY THIS PRIVACY NOTICE

This Privacy Notice covers you who:

  • is a customer or a prospective customer of us,
  • a user of our websites or other digital channels or services,
  • a contact person of a supplier or business partner to us, including clinics, and
  • other external persons that otherwise engage or interact with us, for example by attending meetings or events or participate in surveys that we carry out or if you in any other way communicate with us.

4. RESPONSIBILITY FOR THE SHARING OF PERSONAL DATA

Each business that shares personal data (data exporter) with another business (data importer) within the Vimian Group in accordance with this Privacy Notice is responsible (a data controller) for its sharing of personal data. The role of the data importer depends on the specific scenario in which personal data is shared. As such, the business being the data importer will have different roles in relation to the processing of the personal data received under applicable data protection regulations as follows:

  • Separate data controller: If the business being the data importer will process the personal data received for its own purposes (as outlined in this Privacy Notice) the business will be a separate data controller for such subsequent processing of the personal data received. Example: A business shares an attendee list from a seminar that the business has arranged with another business within the Vimian Group to allow the business receiving the attendee list to identify whether there are any attendees that also are customers of the business to follow-up and evaluate customer engagement. Please see Follow-up and evaluate customer engagement and Follow-up and evaluate meetings, events and similar activities below.
  • Joint or co-controller: If the business being the data importer and the business being the data exporter have jointly decided for which purposes (as outlined in this Privacy Notice) and how the personal data shared will processed, they are joint or co-controllers and jointly responsible for the processing of personal data shared. Example: The businesses have jointly decided to carry out a joint communication to provide a joint offer to their customers. Please see Provide offers and marketing below.
  • Processor: If the business being the data importer processes the personal data received from the business being the data exporter and only processes this personal data on behalf of the data exporter and based on its written instructions, the data importer is a processor in relation to the data exporter. Example: The business being the data exporter instructs the business being the data importer to carry out an analysis using personal data received from the data importer for obtaining business insights. Please see Carry out analysis to obtain business insights below.

The businesses within the Vimian Group that are covered by this Privacy Notice have entered into an intra-group data transfer agreement to ensure that there are adequate safeguards in place to protect your personal data when shared between businesses within the Vimian Group. The agreement also includes a joint arrangement as required under Article 26 of the GDPR, which outlines the roles and responsibilities of the businesses when they are joint or co-controllers in relation to the processing of your personal data. This Privacy Notice reflects the joint arrangement, but if you want a copy of the essence of the joint arrangement, please contact us at the contact details outlined in Section 9 below

5. DESCRIPTION OF SHARING OF PERSONAL DATA WITHIN THE VIMIAN GROUP

Below we describe for which purposes we share between businesses within the Vimian Group. To read more about which categories of personal data, which legal basis that we rely on for the sharing and the processing of your personal data for each purpose, please see our detailed information on our sharing of personal data.

For which purposes we specifically share your personal data depend on your role and how you interact with us.

Marketing
  • Communicate about us, our products and services: We share personal data within the Vimian Group to communicate about us, our products and services, for example to provide you updates on our business, our products and services via e-mail.
  • Provide offers and marketing: We share personal data within the Vimian Group to provide offers and marketing in different channels, for example via e-mail or on social media, regarding our businesses’ and partners’ products and services.
  • Provide personalized offers, marketing and recommendations: We share personal data within the Vimian Group to provide personalized offers and marketing in different channels, for example via e-mail or on social media, regarding our businesses’ and partners’ products and services. To provide relevant and for you personalized offers, marketing recommendations, we carry out certain profiling of your personal data, including combining personal data from the businesses within the Vimian Group that you have interacted with.
  • Carry out meetings, events and similar activities: We share your personal data within the Vimian Group to carry out meetings, events and similar activities, for example to enable businesses within the Vimian Group to arrange joint events and activities, but also to make it possible for businesses to invite customers belonging to another business to a meeting or event that may be relevant to such customers.
  • Create and provide personalized content in our digital channels: We share personal data within the Vimian Group to create and provide personalized content in our digital channels, for example to ensure that our websites display content that is relevant for you based on your interactions with us.
  • Facilitate marketing communications: We share personal data within the Vimian Group to facilitate marketing communications, for example to enable the businesses within the Vimian Group to create joint send lists of individuals.
Analysis
  • Follow-up and evaluate sales and campaigns: We share personal data within the Vimian Group to follow-up and evaluate sales and campaigns, for example to enable the businesses to follow-up and evaluate campaigns on a group level or to follow-up campaigns carried out jointly by two or several businesses.
  • Follow-up and evaluate customer engagement: We share personal data within the Vimian Group to follow-up and evaluate customer engagement, for example to make it possible to analyze customer engagement on a group level.
  • Carry out analysis to obtain customer insights: We share personal data within the Vimian Group to carry out analysis to obtain customer insights on an aggregated level, for example to better understand which products and services that our customers use. This in order for us to obtain a better understanding and insight in our customers' behaviours and patterns on an aggregated level which allow us to develop and improve our business for the benefit of all of our customers.
  • Carry out analysis to obtain business insights: We share personal data within the Vimian Group to carry out analysis to obtain business insights, for example to better understand how we can operate in a more efficient way and how we can develop and improve our business procedures, routines and strategies to support the business in a better way.
  • Carry out analysis to select and tailor marketing communication: We share personal data within the Vimian Group to carry out analysis to select and tailor marketing communications, for example to identify the relevant audience for a certain marketing communication and to ensure that you only receive relevant communications from us.
  • Follow-up and evaluate the use and performance of our websites and digital channels: We share personal data within the Vimian Group to follow-up and evaluate the use and performance of our websites and digital channels, for example to collect and compile statistics of all of our websites to better understand how our websites and digital channels are used across different businesses.
  • Follow-up and evaluate meetings, events and similar activities: We share personal data within the Vimian Group to follow-up and evaluate meetings, events and similar activities carried out, for example to collect and compile statistics of joint events or activities carried out and to plan for future events.
  • Follow-up and evaluate the performance of communications: We share personal data within the Vimian Group to follow-up and evaluate the performance of communications, for example to collect and compile statistics on opening frequency of e-mail communications.
  • Follow-up and evaluate the relationship to suppliers, business partners and clinics: We share personal data within the Vimian Group to follow-up and evaluate the relationship to suppliers, business partners and clinics, for example to better understand the engagement we have with suppliers, business partners and clinics within the group.
  • Carry out customer, user and market surveys: We share personal data within the Vimian Group to carry out customer, user and market surveys, for example to carry out joint surveys or to share the results of a survey carried out within the group.
Service
  • Respond to questions, manage customer matters and provide customer support: We share personal data within the Vimian Group to respond to questions, manage customer matters and provide customer support if necessary to respond to your request or manage the matter.
Relationship management
  • Manage shared customer records: We share personal data within the Vimian Group to manage shared customer records, for example to make it possible for the businesses within the group to view, update and delete customer records to reflect customer relationship changes. This enables greater transparency between the businesses and a more efficient customer relationship management.
  • Manage potential customers and contacts: We share personal data within the Vimian Group to manage potential customers and contacts, for example to share information on leads and prospects with other businesses within the group.
  • Manage supplier, business partners and clinic relationships: We share personal data within the Vimian Group to manage supplier, business partners and clinic relationships, for example where a supplier provides services to several businesses within the group or when several businesses have a relationship with a business partner or clinic.
  • Manage orders and subscriptions: We share personal data within the Vimian Group to manage orders and subscriptions, for example where a business provides assistance to another business in order to manage the order or subscription or when the businesses jointly cooperate to manage an order or subscription.
Business development etc.
  • Develop and improve our business strategies, offerings and methods: We share personal data to develop and improve our business strategies, offerings and methods, for example by sharing information, knowledge and best practices between the businesses for this purpose.
  • Communicate internally and externally in the course of the business: We share personal data within the Vimian Group in connection with internal and external communication in the course of the business, for example when our personnel communicate with each other and external persons via e-mail to carry out their work duties.

6. WE KEEP AND SHARE PERSONAL DATA IN A SECURE WAY

We implement technical and organizational security measures to protect your personal data and ensure that your personal data is shared in a secure way. For example, we ensure that personal data is encrypted when transferred and that only authorized personnel have access to your personal data on a need-to-know basis.

7. INTERNATIONAL TRANSFERS OF PERSONAL DATA

Being a global company, the businesses within Vimian Group operate in various countries, including within the EU, in the United States, Australia, the United Kingdom, Switzerland, and New Zealand. Personal data about you is transferred when the businesses share personal data for the purposes described in this Privacy Notice. Please note that some of these countries may have data protection laws that are different from the laws of your country and, in some cases, may not be as protective.

To ensure that your personal data is adequately protected when shared between businesses within the Vimian Group, the businesses have entered into an intra-group data transfer agreement which includes contractual guarantees and imposes requirements for implementing technical and organizational measures. The intra-group data transfer agreement uses the EU Commission's adopted standard contractual clauses for international transfers according to decision 2021/914.

For more information on to which countries that your personal data is transferred and the safeguards that we have taken to protect personal data, please contact at the contact details outlined in Section 9 below.

8. YOUR RIGHTS

Your rights in relation to the processing of your personal data vary depending on the country you reside in. You have under applicable data protection laws certain rights in relation to the processing and sharing of your personal data. The rights that you have vary depending on the country you reside in. In general, you have the following rights:

Right to access

You have the right to request access and copy of your personal data.

Right to rectification

You have the right to request that we rectify or supplement your personal data if you consider that your personal data is incorrect, incomplete, or misleading.

Right to erasure

You have in some specific situations the right to request erasure of your personal data, subject to certain exceptions.

Right to withdraw your consent

Where we rely on your consent for the sharing and processing of your personal data, you have the right to at any time withdraw your consent.

Right to opt-out of marketing communications

You always have a right to object to our use of your personal data for direct marketing purposes. We include a link in our marketing communication with you allowing you to unsubscribe from future communications. If you have notified us that you no longer would like to receive marketing communication from us, we will register this and stop with such communication or otherwise process your personal data for marketing purposes.

Moreover, if you reside within the EU, you also have the following rights under the GDPR:

Right to object to our processing of your personal data

In certain situations, you have the right to object to our use of your personal data, for example when we rely on our or another's legitimate interest for the use of your personal data, subject to certain exceptions.

Right to request restriction of your personal data

In certain situations, you have the right to request restriction of your personal data which means that you can, at least for a certain period, stop us from using your personal data, subject to certain exceptions.

Right to a copy of certain personal data and transfer such personal data to an external recipient (data portability)

The right to data portability means that you have a right to receive a copy of the personal data that you have provided to us in a structured commonly used format. Moreover, where it is technically feasible, you also have the right to request that the copy of your personal data is transferred directly to an external recipient. The right, however, only applies if we rely on the performance of an agreement with you or your consent for the use of your personal data.

For additional information on rights in relation to the processing and sharing of your personal data that apply in the countries where the businesses operate, please read each business’ external privacy notice. Links to the businesses’ external privacy notices are included in Section 11 below.

Request to exercise your rights: To exercise any of these rights, please contact us on the contact details outlined in Section 9 below and specify which right(s) you wish to exercise and in relation to which businesses. We might ask you for further information if necessary to verify your identity and/or to manage your request. We will respond to your request within the required timeframe.

9. CHANGES TO THIS PRIVACY NOTICE

We update and change this Privacy Notice on a regular basis to ensure that it reflects how we share and process personal data in practice and to fulfill new or changes legal requirements. We will notify you about significant changes to this Privacy Notice in advance by appropriate means, for example by sending a notice to your registered e-mail address and/or by placing a prominent notice on this page. At the top of this page, you can see when this Privacy Notice was last updated.

10. IF YOU HAVE QUESTIONS

We welcome your questions or comments regarding this Privacy Policy. You can contact us on the following contact details. If you wish to contact a specific business of the Vimian Group, please use the contact details outlined in Section 11.

Vimian Group AB (publ)
Address: Riddargatan 19, 114 57 Stockholm, Sweden
E-mail: Legal@vimian.com

If you are not satisfied with our response or if you have concerns about our processing of your personal data, you have the right to lodge a complaint with your supervisory authority. For information on appointed supervisory authorities within the EU and their contact information, please see the list of supervisory authorities on the European Data Protection Board’s website.

11. VIMIAN GROUP BUSINESSES COVERED BY THE PRIVACY NOTICE

The table below outlines the Vimian Group businesses that are covered by this Privacy Notice:

  • Business: Vimian, Contact details: Legal@vimian.com, Privacy Policy: Privacy Policy - Vimian
  • Business: Nextmune, Contact details: Legal@vimian.com, Privacy Policy: Privacy Policy - Nextmune
  • Business: VetFamily, Contact details: Legal@vimian.com, Privacy Policy: GDPR-Policy | VetFamily
  • Business: Heiland, Contact details: Legal@vimian.com, Privacy Policy: heiland.com - Datenschutz
  • Business: Movora, Contact details: Legal@vimian.com, Privacy Policy: Privacy Policy - Movora
  • Business: Indical, Contact details: Legal@vimian.com, Privacy Policy: INDICAL Bioscience | Privacy Policy

Detailed information on our sharing of personal data

INTRODUCTION

In this detailed information on our sharing of personal data between the businesses within the Vimian Group, we describe in detail the categories of personal data shared for each purpose and the legal basis that we rely on for sharing your personal data.

INFORMATION ON SHARING OF PERSONAL DATA
Marketing
  • Communicate about us, our products and services: Categories of personal data: Contact information, Engagement information, Identity information, Profile information. Legal basis: Legitimate interest.
  • Provide offers and marketing: Categories of personal data: Contact information, Engagement information, Identity information, Profile information, Transaction and order information. Legal basis: Legitimate interest.
  • Provide personalized offers, marketing and recommendations: Categories of personal data: Contact information, Engagement information, Identity information, Profile information, Technical information, Transaction and order information, User generated information. Legal basis: Consent: The processing of your personal data is based on your consent, for example the consent that you provide when signing up for this type of marketing communications or by accepting our use of cookies on our websites or in our digital channels for this purpose .
  • Carry out meetings, events and similar activities: Categories of personal data: Contact information, Event information, Identity information, Picture, video and audio material, Profile information. Legal basis: The processing of personal data is necessary to satisfy our legitimate interest of carrying out meetings, events and similar activities. The assessment is that this legitimate interest outweighs your privacy interest, given the purpose of the processing, that only simple personal data is processed and that the impact on you would be limited. Additionally, your personal data is normally only processed if you participate in the specific activity.
  • Create and provide personalized content in our digital channels: Identity information, Technical information, User generated information. Consent: The processing of your personal data is based on your consent, for example the consent you provide by accepting our use of cookies on our websites or in our digital channels for this purpose.
  • Facilitate marketing communication: Contact information, Engagement information, Identity information, Profile information. Legitimate interest: The processing of personal data is necessary to satisfy our legitimate interest of facilitating marketing communication. The assessment is that this legitimate interest outweighs your privacy interest, given the purpose of the processing, that only simple personal data is processed and that the impact on you would be limited.

Analysis
  • Follow-up and evaluate sales and campaigns: Identity information, Profile information, Transaction and order information. Legal basis: Legitimate interest: The processing of personal data is necessary to satisfy our legitimate interest of follow-up and evaluate sales and campaigns. It is of significant importance for the businesses within the Vimian Group to understand how the business performs on an aggregated level. The assessment is that this legitimate interest outweighs your privacy interest, given the purpose of the processing, that only simple personal data is processed and that the
    impact on you would be limited, especially since the result of the processing is statistics.
  • Follow-up and evaluate customer engagement: Engagement information, Event information, Identity information, Profile information, Transaction and order information. Legal basis: Legitimate interest: The processing of personal data is necessary to satisfy our legitimate interest of following-up and evaluating customer engagement. It is of significant importance for the businesses within the Vimian Group to better understand the level of customer engagement across the group. The assessment is that this legitimate interest outweighs your privacy interest, given the purpose of the processing, that only simple personal data is processed and that the impact on you would be limited, especially since the result of the processing is statistics.
  • Follow-up and evaluate potential customers and contacts: Engagement information, Event information, Identity information, Profile information. Legal basis: Legitimate interest: The processing of personal data is necessary to satisfy our legitimate interest of following-up and evaluating potential customers and contacts. It is of importance for the businesses within the Vimian Group to work together in relation to customer acquisition. The assessment is that this legitimate interest outweighs your privacy interest, given the purpose of the processing, that only simple personal data is processed and that the
    impact on you would be limited.
  • Carry out analysis to obtain customer insights: Communication, Engagement information, Event information, Identity information, Profile information, Technical information, Transaction and order information, User generated information (only based on your consent). Legal basis: Legitimate interest: The processing of personal data is necessary to satisfy our legitimate interest of carrying out analysis to obtain customer insights. This to enable the businesses within the Vimian Group to improve and develop the business to our customers needs. The assessment is that this legitimate interest outweighs your privacy interest, given the purpose of the processing and that the impact on you would be limited since the result of the analysis is on an aggregated level. Consent: To the extent user generated information is processed for this purpose, the processing of your personal data is based on your consent, for example
    the consent you provide by accepting our use of cookies on our websites or in our digital channels for this purpose.
  • Carry out analysis to obtain business insights: Engagement information, Event information, Identity information, Profile information, Transaction and order information. Legal basis: Legitimate interest: The processing of personal data is necessary to satisfy our legitimate interest of carrying out analysis to obtain business insights. This to enable the businesses within the Vimian Group to better understand how we can operate in a more efficient way and how we can develop and improve our business procedures, routines and strategies to support the business in a better way. The assessment is that
    this legitimate interest outweighs your privacy interest, given the purpose of the processing and that the
    impact on you would be limited since the result of the analysis is on an aggregated level.
  • Carry out analysis to select and tailor marketing communication: Engagement information, Event information, Identity information, Profile information, Technical information, User generated information (only based on your consent). Legal basis: Legitimate interest: The processing of personal data is necessary to satisfy our legitimate interest of carrying out analysis to select and tailor marketing communication. This to enable the businesses within the Vimian Group to identify the relevant audience for their marketing communication and to ensure that you only receive relevant communications from us. The assessment is that this legitimate interest outweighs your privacy interest, given the purpose of the processing and that the impact on you would be limited. Consent: To the extent user generated information is processed for this purpose, the processing of your personal data is based on your consent, for example the consent you provide by accepting our use of cookies on our websites or in our digital channels for this purpose.
  • Follow-up and evaluate the use and performance of our websites and digital channels: Identity information, Technical information, User generated information. Legal basis: Consent: The processing of your personal data is based on your consent, for example the consent you provide by accepting our use of cookies on our websites or in our digital channels for this purpose.
  • Follow-up and evaluate meetings, events and similar activities: Event information, Identity information, Profile information. Legal basis: Legitimate interest: The processing of personal data is
    necessary to satisfy our legitimate interest of following-up and evaluating meetings, events and similar activities that we carry out. This enables the businesses within the Vimian Group to collect and compile statistics of joint events or activities carried out and to plan future events The assessment is that this legitimate interest outweighs your privacy interest, given the purpose of the processing, that only simple personal data is processed and that the impact on you would be limited.
  • Follow-up and evaluate the performance of communications: Identity information, Technical information, User generated information. Legal basis: Consent: The processing of your personal data is based on your consent, for example the consent that you provide when signing up for this type of marketing communications or by accepting our use of cookies on our websites or in our digital channels for this purpose.
  • Follow-up and evaluate the relationship to suppliers, business partners, and clinics: Engagement information, Identity information, Profile information, Transaction and order information. Legal basis: Legitimate interest: The processing of personal data is necessary to satisfy our legitimate interest of following-up and evaluating the relationship to suppliers, business partners and clinics. This enables the
    businesses within the Vimian Group to better understand the engagement we have with suppliers, business partners and clinics within the group. The assessment is that this legitimate interest outweighs your privacy interest, given the purpose of the processing, that only simple personal data is processed and that the impact on you would be limited.
  • Carry out customer, user and market surveys: Communication, Contact information, Engagement information, Identity information, Profile information. Legal basis: Legitimate interest: The processing of personal data is necessary to satisfy our legitimate interest of carrying out customer, user and market surveys. This enables the businesses within the Vimian Group to collect relevant information to better understand how we can improve our business, marketing and customer offerings. The assessment is
    that this legitimate interest outweighs your privacy interest, given the purpose of the processing, that only simple personal data is processed and that the impact on you would be limited, especially since you voluntarily participate in surveys that we carry out.

These detailed descriptions continue to outline the specific categories of personal data involved in each activity and the rationale behind their processing within the Vimian Group. This provides transparency and accountability in how personal data is handled, in line with regulatory requirements and best practices for data protection.

Service and Customer Relationship Management
  • Respond to questions, manage customer matters and provide customer support: Contact information, Communication, Engagement information, Identity information, Profile information, Transaction and order information. Legal basis: Legitimate interest: The processing of personal data is
    necessary to satisfy our legitimate interest of responding to questions, manage customer matters and provide customer support. The assessment is that this legitimate interest outweighs your privacy interest, given the purpose of the processing, and that the impact on you would be limited, especially if the processing is carried out to respond to your inquiry or request.
  • Manage shared customer records: Communication, Contact information, Engagement information, Identity information, Profile information. Legal basis: Legitimate interest: The processing of personal data is necessary to satisfy our legitimate interest of managing shared customer records. This enables greater transparency between the businesses within the Vimian Group and a more efficient customer relationship management. The assessment is that this legitimate interest outweighs your privacy interest, given the purpose of the processing and that the impact on you would be limited.
  • Manage potential customers and contacts: Communication, Contact information, Engagement information, Identity information, Profile information. Legal basis: Legitimate interest: The processing of personal data is necessary to satisfy our legitimate interest of managing potential customers and contact. This enables the businesses to manage potential customers and contacts jointly and in a
    more efficient way. The assessment is that this legitimate interest outweighs your privacy interest, given
    the purpose of the processing, that only simple personal data is processed and that the impact on you
    would be limited.
  • Manage supplier, business partners and clinic relationships: Communication, Contact information, Engagement information, Identity information, Profile information. Legal basis: Legitimate interest: The processing of personal data is necessary to satisfy our legitimate interest of managing supplier, business
    partners and clinic relationships. This enables the businesses within the Vimian Group to cooperate when engaging a new supplier or in discussins with business partners and clinics. The assessment is that this legitimate interest outweighs your privacy interest, given the purpose of the processing, that only simple personal data is processed and that the impact on you would be limited.
  • Manage orders and subscriptions: Identity information, Contact information, Profile information, Transaction and order information. Legal basis: Legitimate interest: The processing of personal data is
    necessary to satisfy our legitimate interest of managing orders and subscriptions. This enables the within the Vimian Group to cooperate on managing orders and subscriptions. The assessment is that this legitimate interest outweighs your privacy interest, given the purpose of the processing and that the impact on you would be limited, especially if the processing is carried out to manage the order or subscription that you have requested.
Business Development and Communication
  • Develop and improve our business strategies, offerings and methods: Communication, Engagement information, Event information, Identity information, Profile information, Transaction and order information. Legal basis: Legitimate interest: The processing of personal data is necessary to satisfy our legitimate interest of developing and improving our business strategies, offerings and methods. This enables the businesses within the Vimian Group to share information, knowledge and best practices between the businesses for this purpose. The assessment is that this legitimate interest outweighs your privacy interest, given the purpose of the processing and that the impact on you would be limited, especially since the personal data is normally analyzed on an aggregated level for this purpose.
  • Communicate internally and externally in the course of the business: Communication, Contact information, Identity information, Picture, video and audio material, Profile information. Legal basis: Legitimate interest: The processing of personal data is necessary to satisfy our legitimate interest of enabling internal and external communication in the course of the business. It is of significant importance that the businesses can communicate internally and externally for this purpose. The assessment is that this legitimate interest outweighs your privacy interest, given the purpose of the processing and that the impact on you would be limited.
Categories of Personal Data

In the table below, we describe which categories of personal data that we share and the types of personal data that are covered by each category.

  • Communication and content: Contents of e-mails, chat conversations and instant messages, responses to surveys.
  • Contact information: E-mail address, telephone number, physical address.
  • Engagement information: Activities carried out, such as meetings, calls, or e-mail correspondence, level of engagement, conversion.
  • Event information: Participation in an event or activity, date of activity or event, type of activity or event.
  • Identity information: Name, ID numbers, username.
  • Picture, video and audio material: Video and audio recordings and streams, pictures.
  • Profile information: Job title, level, age, gender, qualifications, experience, company or organisation that the individual works for, status, country of residence.
  • Technical information: IP address, type of device, device identifier, version of browser and operating system, network identifier.
  • Transaction and order information: The service or product ordered, order history, date of order and delivery, shipping address, assignment period, cost and payment, payment method, billing information.
  • User generated information: User activity, interactions and reactions, page views, clicks, visits.