Privacy Policy

Below is a description of how we collect, use, and deal with the information, including personal information, which you provide us with, and which is generated as a part of the contract that is formed when you use our services and products.

1. Introduction

Soluno BC AB, org.nr 556377-2317 (the “Company”) is the controller of personal data for the processing of your personal data related to providing services within telecommunications (the “Service”) and is therefore responsible to ensure that all personal data is processed in a correct manner and in accordance with applicable data protection legislation.

This Privacy Policy (hereinafter the “Privacy Policy”) describes the Company’s processing of your personal data and has the purpose of ensuring you that we, in our capacity as controller of personal data, are processing the information about you in accordance with applicable data protection legislation. This Privacy Policy describes the Company’s processing of your personal data.

Personal data means all types of information which can, directly or indirectly, be associated with a living physical person. Within the Company’s activities there may occur personal data relating to e.g. given names and surnames, telephone numbers, addresses, postal codes, e-mail addresses, personal ID numbers, etc. (hereinafter collectively referred to as “Personal Data”).

“Customer Data” is Personal Data connected to the Service – e.g. name, address, email, telephone number and social security number. It also includes information about which Service you use, and how you use them, order, user-ID, password and other information you have left when you have been in contact with us.

“Traffic Data” is Personal Data connected to what happens when you use our Services. Traffic Data is used with the objective to send electronic messages though an electronic communications network when you use the Services. The Traffic Data is also used to invoice your use of the Services, and for instance shows who you have communicated with, the time that the communication started and ended, the duration of the communication and what networks was used.

If you cannot find answers to your questions, please get in touch with us. You will find information about how to contact us under the heading “Contact Information” below.

2. Processing of Personal Data

2.1 Customers or representative of customers as well as potential customers
Purpose Type of processing Categories of Personal Data
To fulfil obligations within current contracts for the delivery of services and products. We process Personal Data to identify you as a customer or user, to handle and deliver orders in accordance with your agreement and to provide the Services – such as to ensure the operation of the Service.

We also process data to charge for the services you use to manage your invoices and payments, for credit disclosure purposes, to correct errors and handle other incidents, and to handle complaints.

Customer Data
Traffic Data
From which sources will we collect your Personal Data? Customer, customer’s employee, SPAR and UC
Lawful Basis: Fulfilment of contract
Automated decision-making: No, this processing does not mean that decision-making will be made based on automated processing of Personal Data.
Storage time: Customer data: As long as you are a customer at Soluno and for 24 months after you have you have ended your contractual relationship with Soluno.

Traffic Data: Is saved for billing purposes. The Traffic Data is deleted after 6 months after the invoice is payed.

 

Purpose Type of processing Categories of Personal Data
To provide service information and updates. We process data in connection with other communications with you, such as when we send information about our Services and contact you regarding questions about our Services. When you call our customer service, the call can be recorded. When you chat with our customer service, the written texts can be analysed. We do this to educate our employees, improve our speeches and our way of working in order to always help you in the best possible way. Customer Data
Traffic Data
From which sources will we collect your Personal Data? Customer, customer’s employee
Lawful Basis: Legitimate interest (Customer Data) and consent (Traffic Data)
Automated decision-making: No, this processing does not mean that decision-making will be made based on automated processing of Personal Data
Storage time: Customer data: As long as you are a customer at Soluno and for 24 months after you have you have ended your contractual relationship with Soluno.

Traffic Data: We save Traffic Data to help you if something is wrong with the services we deliver. This data is saved for 6-24 months.

 

Purpose Type of processing Categories of Personal Data
To evaluate, develop and improve our services, products and offerings. We process data to develop and manage our operations and Services as well as our processes. For this purpose, we may also compile statistics for analytical needs. Customer Data
Traffic Data
From which sources will we collect your Personal Data? Customer, customer’s employee
Lawful Basis: Legitimate interest (Customer Data) and consent (Traffic Data)
Automated decision-making: No, this processing does not mean that decision-making will be made based on automated processing of Personal Data
Storage time: Customer data: As long as you are a customer at Soluno and for 24 months after you have you have ended your contractual relationship with Soluno.

Traffic Data: In order for us to continuously offer better services based on our customers’ needs, we also save statistics based on these tasks. This data is saved for 6-24 months.

 

Purpose Type of processing Categories of Personal Data
To administer and customize your visit and access to selected parts of our online services. We process data in order to continuously offer better services based on our customers’ needs and to personalize you use of our online Service. Customer Data
Traffic Data
From which sources will we collect your Personal Data? Customer, customer’s employee
Lawful Basis: Legitimate interest (Customer Data) and consent (Traffic Data)
Automated decision-making: No, this processing does not mean that decision-making will be made based on automated processing of Personal Data.
Storage time: Customer data: As long as you are a customer at Soluno and for 24 months after you have you have ended your contractual relationship with Soluno.

Traffic Data: In order for us to continuously offer better services based on our customers’ needs. This data is saved for 6-24 months.

 

Purpose Type of processing Categories of Personal Data
To deliver direct marketing material. We process different types of data in order to market our products and services directly to you. You can receive direct marketing it via e.g. phone, text message and e-mail. For this purpose, we may also compile statistics for analysis. Customer Data
Traffic Data
From which sources will we collect your Personal Data? Customer, customer’s employee
Lawful Basis: Legitimate interest (Customer Data) and consent (Traffic Data)
Automated decision-making: No, this processing does not mean that decision-making will be made based on automated processing of Personal Data.
Storage time: Customer data: As long as you are a customer at Soluno and for 24 months after you have you have ended your contractual relationship with Soluno.

Traffic Data: In order to offer you attractive market deals based on your needs, we save certain data, such as number of texts and phone calls, as well as information about your data usage. We save the information for 36 months.

 

Purpose Type of processing Categories of Personal Data
To implement marketing and customer analysis. For this purpose, we may compile statistics for analysis. Customer Data
Traffic Data
From which sources will we collect your Personal Data? Customer, customers employee
Lawful Basis: Legitimate interest (Customer Data) and consent (Traffic Data)
Automated decision-making: No, this processing does not mean that decision-making will be made based on automated processing of Personal Data.
Storage time: Customer data: As long as you are a customer at Soluno and for 24 months after you have you have ended your contractual relationship with Soluno.

Traffic Data: In order for us to continuously offer better services based on our customers’ needs. This data is saved for 6-24 months.

 

Purpose Type of processing Categories of Personal Data
To fulfil our obligations under telecom legislation. We process data in order to fulfil our statutory obligations as a telecom service provider/operator. Customer Data
Traffic Data
From which sources will we collect your Personal Data? Customer, customers employee
Lawful Basis: Legal obligation
Automated decision-making: No, this processing does not mean that decision-making will be made based on automated processing of Personal Data.
Storage time: Customer data: As long as you are a customer at Soluno and for 24 months after you have you have ended your contractual relationship with Soluno.

Traffic Data: In order to comply with statutory obligation we may process you Traffic data for 24 months after you have ended your contractual relationship with Soluno.

 

Purpose Type of processing Categories of Personal Data
To ensure data security and to avoid misuse of the Service. We process data in order to meet the security of all our services and communications networks, to detect or prevent various types of illegal use or use that otherwise violate the terms of service. We also treat these data to prevent network and service abuse, and to detect and prevent fraud, virus attacks, etc. Customer Data
Traffic Data
From which sources will we collect your Personal Data? Customer, customers employee
Lawful Basis: Legal obligation
Automated decision-making: No, this processing does not mean that decision-making will be made based on automated processing of Personal Data.
Storage time: Customer data: As long as you are a customer at Soluno and for 24 months after you have you have ended your contractual relationship with Soluno. Traffic Data: In order to comply with statutory obligation we may process you Traffic data for 24 months after you have ended your contractual relationship with Soluno.

 

2.2 Suppliers and partners
Purpose Type of processing Categories of Personal Data
To communicate with suppliers and partners We process data to handle deliveries and collaborations. Contact information
From which sources will we collect your Personal Data? Suppliers and partners.
Lawful Basis: Legitimate interest in order to communicate with representatives for suppliers and partners.
Automated decision-making: No, this processing does not mean that decision-making will be made based on automated processing of Personal Data
Storage time: Until we have received information that the representative no longer work for the supplier/partner or the representative has changed contact information.

 

2.3 Potential employees
Purpose Type of processing Categories of Personal Data
To administer a recruitment process This includes, for example, to review the application and communicate with the applicant. Name
Address
Social security number
Contact informationID
From which sources will we collect your Personal Data? Potential employee and their employer.
Lawful Basis: Until the position has been filled: Fulfilment of contract.

After the position has been filled: Legitimate interest or consent.

Automated decision-making: No, this processing does not mean that decision-making will be made based on automated processing of Personal Data.
Storage time: Up to two years after the position has been filled. After the recruitment process the data will be filed in order for us to defend our rights in any legal dispute concerning for example discrimination.

 

2.4 Visitors
Purpose Type of processing Categories of Personal Data
To administer visits. This includes, for example, to register external visitors for safety reasons. Name
Contact information
From which sources will we collect your Personal Data? Visitors.
Lawful Basis: Legitimate interest in order for us to ensure our safety.
Automated decision-making: No, this processing does not mean that decision-making will be made based on automated processing of Personal Data.
Storage time: One month after the visit.

3. Recipients of Personal Data and transfers to third countries outside the EU/EEC

We may as controller of your Personal Data assign the processing listed above to a partner or supplier, e.g. Zendesk Inc (ticketing system), Interoute (International numbers). Such processing will not be made for other purposes than as described above. Some partners and suppliers may have parts of their businesses in countries outside of the EU/EEC (so-called Third Countries). Transfer of Personal Data will only be made to such countries which offer an adequate level of data protection, as decided by the EU Commission, or if the supplier has a legally binding and enforceable instrument which guarantees the safety of the Personal Data.

4. Your rights as registered

You have the right to:

  • Request information about which of your Personal Data we process and you can request a copy of these;
  • Have incorrect Personal Data rectified and you can under certain circumstances have your Personal Data erased;
  • Oppose against certain processing of your Personal Data and request that the processing is restricted,
  • Have your Personal Data transferred to another controller (right to data portability),
  • If the processing of data is based on consent, withdraw a given consent, and
  • If you are unsatisfied with our processing of your Personal Data, report our processing to the Swedish Data Protection Authority, who is the supervising authority

You may at any time obtain, erase or restrict the processing of your Personal Data. Please notice that if we restrict the processing of or erase your Personal Data we might not be able to provide the Service to you.

5. Protection of the Personal Data

The Company has undertaken appropriate technical and organisational measures in order to protect Personal Data against loss, abuse, unauthorized access, revealing, alteration and destruction. In order to ensure that the Personal Data is processed in a secure and confidential manner, the Company uses firewalls and other security measures to protect networks against breach, authentication methods pursuant to industry standards. OWASP 2017 guide lines are followed for http interfaces. In order to secure the integrity of the Personal Data the Company may use encryption techniques when the Company transfers such Personal Data over the Internet to the Company´s servers.

Company employees and suppliers are bound by confidentiality agreements and are obligated to follow the Company’s rules for information and IT security, this Privacy Policy and other internal rules and policies which regulate the processing of Personal Data.

6. Amendments to the Privacy Policy

The Company retains the right to amend this Privacy Policy as the Company sees fit. The date for the latest amendment is indicated at the end of this Privacy Policy. If the Company amends this Privacy Policy the Company will notify this through our newsletters and notice on this web site. You are therefore recommended to read this Privacy Policy regularly in order to be updated on any amendments.

If this Privacy Policy is substantially amended compared to when the Company obtained your consent, the Company will notify you of these amendments and, if necessary, obtain new consent the Company’s processing of your Personal Data.

7. Contact information

If you have any questions regarding the Privacy Policy or any other question regarding our processing, please feel free to contact us:

Soluno Business Communications AB, reg. no. 556377-2317
Att: Data Protection Officer
Lumaparksvägen 9
120 31 Stockholm
010 410 50 00
dpo@soluno.se

The Privacy Policy was adapted on 2018-05-23