PRIVACY POLICY

INTRODUCTION

CADcog AB (“CADcog” or “we”, “us”, “our”) Process Personal data in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, General Data Protection Regulation (“GDPR”) and any other Swedish laws and regulations applicable in the field of data protection. This Privacy Policy explains how we use the Personal data that we collect from you (“Customer” or “you”) when you use our Services as stated in our Terms of Use. It also describes your rights toward us and how you can exercise your rights.

1. DEFINITIONS

Unless otherwise defined herein, all capitalized terms shall have the meaning given to them in CADcog’s Terms of Use.

“Personal data” means any information relating to an identified or identifiable natural person that, directly or indirectly in combination with other information, can be linked to a living, natural person. Personal data is a very broad term, and it includes, but is not limited to, the name, contact details and IP addresses of such person.

“Process” or “Processing” of Personal data means, including but not limited to, collecting, registering, organizing, structuring, and storing. Processing also means alteration, production, reading, listing, using, and disclosing Personal data by transfer, disseminating, changing, removing as well as deletion of the Personal data.

“Data subject” means an identified or identifiable person to whom Personal data relates.

2. LEGAL GROUNDS FOR PROCESSING

CADcog will only Process Personal data if we have a lawful basis for doing so. CADcog may Process Personal data based on the following legal grounds in GDPR:

2.1 CONSENT

In the event CADcog foresees the need to Process your Personal data for a purpose which, pursuant to applicable laws and regulations, should be based on your consent (on grounds of Art. 6(1)(a) GDPR), we will contact you in advance, to inform you about the Processing for which your consent is required before the consent is collected. You may withdraw your consent at any time.

2.2 FULFILMENT OF AGREEMENT

To fulfil our agreement with you (including to provide our Services to you or to respond to your requests, such as a request for customer service). The legal ground for this is that the Processing is necessary for the performance of an agreement or contract to which the Data subject is party or to take steps at the request of the Data subject prior to entering into an agreement or contract (Art. 6(1)(b) GDPR).

2.3 LEGAL OBLIGATIONS

To comply with legal obligations to report to authorities and third parties. The legal ground is that Processing is necessary for compliance with a legal obligation to which the data controller is subject (Art. 6(1)(c) GDPR). CADcog may Process Personal data in relation to claims handling, debt collection and legal processes pertaining to the Data subject or the company the Data subject represents. We may also Process Personal data for the prevention of fraud, misuse of our Services and for data, system and network security.

2.4 LEGITIMATE INTEREST

CADcog Processes your Personal data primarily to pursue our legitimate interest to run, maintain and develop our business and to create and maintain customer and other business relationships, such as marketing our Services by contacting potential and existing Customers via e-mail, newsletters, or letters, in order to inform you about our Services, offers and events. The legal ground for this is that the Processing is necessary and that CADcog has a legitimate interest (Art. 6(1)(f) GDPR) that is not overridden by the fundamental interests and freedoms of the Data subjects.

3. COOKIES

We base our use of cookie files, which are not necessary but can be classified as analytical, to provide the Services, on your explicit consent, cf. (Art. 6(1)(a) GPDR).

We store cookie files on your computer, telephone (or other digital device which you may use to visit our digital channels) for the purpose of identifying your browser and to recognize your search history, settings and preferences. You will have the right to refuse CADcog’s Processing of Personal data using cookie files. We use various technologies to collect and store analytics data and other information when you visit our website, including cookies, pixel tags and web beacons.

Cookies are small text files sent and saved on your device that allows us to identify visitors of our website and facilitate the use of the website and the Services and to create aggregate information of our visitors. By sending the content of the cookie file back with each request to the website, the web server can keep track of the Customer’s identity or preferences. This helps us to improve the Services and better serve our Customers. The cookie file can have several purposes, e.g., storing information about the Customer and their use of a website, Customers’ buying patterns, or enabling direct individualized advertising to the Customer. The cookies will not harm your device or files.

A web beacon is a technology that allows identifying readers of websites and emails e.g. for identifying whether an email has been read.

The Customer may choose to set their web browser to refuse cookies, or to alert when cookies are being sent. For example, the following links provide information on how to adjust the cookie settings on some popular browsers:

Please note that some parts of our Services may not function properly if use of cookies is refused.

We will only store cookie files for one (1) year. In addition to us, other third parties will be able to share cookie files like Hotjar, Wix, Meta and Google.

4. IMPROVEMENT OF SERVICES

CADcog is a data controller when it Processes Personal data for the purposes of improving the Services and trend analysis.

We may send you “customer satisfaction forms” that we will ask you if you would like to complete and submit to us. Wherever possible, we use aggregated, non-personally identifiable data.

5. TYPE OF INFORMATION WE COLLECT

When you visit one of our digital channels (for example our website, social media), as well as when you contact us via e-mail, we may collect information about you. In some cases, we may Process your personal identity number. Personal data that may be collected and Processed by CADcog could include:

Your name, e-mail address, postal address, telephone number, banking information and payment details, IP address, picture, personal settings;
Cookie files stored on your computer or your telephone (or other digital device which you may use to visit our digital channels) for the purpose of identifying your browser and to recognize your search history, settings and preferences. You will have the right to refuse CADcog’s Processing of Personal data using cookie files; and
Other information regarding your use of our Services, which we may collect from our surveys and other means of communication with CADcog.

You agree to not use your real name or other personal data to access the Services, regardless of your use of a free account or a paid subscription.

Please note that when you enter your Personal data in connection with using the services of our payment providers, you must read and accept the payment provider’s terms and conditions, which can be found here: www.stripe.com/se/privacy

6. STORAGE AND INCIDENTS

In the event a Personal data incident occurs, CADcog shall notify the Customer as soon as possible and in any event within 72 hours of becoming aware of the incident. A Personal data incident means a security incident that leads to an accidental or unlawful destruction, loss or alteration, unauthorized disclosure or unauthorized access to the Personal data transferred, stored, or otherwise Processed. As Personal data will be transferred over the internet, it is important for Data subjects to be aware of the associated risks.

The Personal data will be, dependent on the purpose for which it is collected, archived, confidentially erased, or anonymized in accordance with the rules of archiving when it is no longer necessary. Personal data will be stored during the time it is necessary for CADcog to fulfil its obligations and for the purposes set out above. CADcog will implement measures to provide the Personal data with protection against unauthorized access and loss thereof.

Most Personal data relating to a Customer will be deleted after a period of 12 months has lapsed after the Customer in question has terminated their registration with the Services. Thereafter, some of the Personal data may be stored by us only as long as such Processing is required by law or is reasonably necessary for our legal obligations or legitimate interests such as claims handling, bookkeeping, internal reporting and reconciliation purposes.

CADcog does not store your Personal data longer than is legally permitted and necessary for the purposes of this Privacy Policy. The storage period depends on the nature of the information and on the purposes of Processing. The maximum period may therefore vary per use.

We will store anonymized analytics data of a Customer that does not have an account with the Services for a period of 12 months.

7. SHARING YOUR INFORMATION WITH OTHERS

The Customer has through this Privacy Policy been informed about the fact that Personal data will be stored in a database for the purposes described above. If CADcog is involved in a merger, engages co-operation partners, acquisition or asset sale, we may transfer your Personal data to the third party involved. CADcog shall ensure that any Personal data is afforded equivalent protection as prescribed in this Privacy Policy and in accordance with the GDPR. CADcog may also transfer Personal data to others within CADcog’s business operation, coordinators, co-operation partners and providers, as well as third parties, including but not limited to suppliers, cloud service providers, consultants, and authorities. CADcog shall, however, only transfer Personal data if CADcog has a legal ground under the GDPR to do so and continue to ensure the confidentiality of all Personal data. CADcog will give notice to the Customer when the Personal data is transferred.

8. TRANSFERS TO COUNTRIES OUTSIDE EUROPE

CADcog may also transfer Personal data to a third country, i.e., a country outside the EU/EEA, or to international organizations according to applicable laws and data regulations. CADcog and third parties may be based anywhere in the world, which could include countries that may not offer the same legal protections for Personal data as the Data subject’s country of residence. CADcog will follow local data protection requirements and its internal global privacy standards and CADcog will apply the necessary safeguards under the applicable law of the country transferring the Personal data for such transfers. The Customer is encouraged to get further information about the legal aspects of third-party transfers: www.imy.se. More information regarding the transfers of Personal data may be obtained by contacting us on any of the addresses indicated below.

9. YOUR LEGAL RIGHTS

Data subjects have the right to object to CADcog’s Processing of Personal data such as, for example, when Processed in connection with direct marketing. Customer also have the right to request deletion, restriction, and rectification of the Personal data. If consent is withdrawn, or if the stored Personal data is incorrect or irrelevant, CADcog must delete, restrict, or correct such Personal data. CADcog will do so unless CADcog have a legitimate ground to not delete the data.

Data subjects have the right to request information about CADcog’s Processing of Personal data. If a request is made electronically, CADcog shall provide the information in an electronically readable form which is structured and commonly used. Any request from Data subjects shall be answered within a reasonable period by CADcog.

Data subjects have the right to transfer the Personal data to another data controller (data portability), as well as to lodge a complaint regarding CADcog’s Processing of Personal data. Complaints shall be submitted to CADcog and/or the competent supervisory authority according to the contact details in clause 10 below, including the following information: full name, address, e-mail addresses and phone number.

CADcog shall, upon request, provide information about the purpose of the Processing, what Personal data is being Processed, recipients of the Personal data and, if possible, for how long the Personal data will be stored. Upon request, CADcog shall also provide information about the possibility to request deletion, rectification, or alteration of the Personal data, as well as how to lodge a complaint to CADcog or the competent supervisory authority. Furthermore, CADcog shall upon request provide information about the origin of the Personal data, the existence of profiling and automatic decision-making, and any transfers to third countries. If requested, CADcog shall also provide the Data subjects with a copy of the Processed Personal data.

10. CONTACT INFORMATION

This Privacy Policy may be updated at any time and the latest updated version may always be found on CADcog’s website: www.CADcog.com/terms.

CADcog’s contact details are as follows: CADcog AB, with address Valectric AB, Brisgatan 54, 802 74 Gävle. CADcog can also be reached by e-mail, johan.holtby@cadcog.com

The contact details of the competent supervisory authority in Sweden are as follows: The Swedish Authority for Privacy Protection (Sw. ‘Integritetsskyddsmyndigheten’), org. no. 202100-0050, with address Box 8114, SE-104 20 Stockholm, Sweden. The Swedish Authority for Privacy Protection can also be contacted by telephone, +46 (0)8-657 61 00, or by e-mail, imy@imy.se.

For more information about the Swedish Authority for Privacy Protection, please visit: www.imy.se.