What is personal data? Services, dealings and communications create records. Some of these records hold information. Personal data is all kind of information that relates to you or members of your household. Processing of personal data includes every measure taken with regard to personal data such as collection, registration, storage, disclosure and compilation.

This General Data Protection Notice (“Notice”) serves to inform you that Tech Troopers and any of its affiliated legal entities may process personal data relating to you as a customer to Tech Troopers.

This Notice is not intended to replace other more detailed notices or consents provided by specific entities of the Tech Troopers group in accordance with local laws and regulations or for specific processing. In the event of any conflict between notices or consents provided as required by local law and this Notice, such notices or consents as required will prevail.

Service provider is controller:

Tech Troopers, which is a Norwegian subsidiary of the Swedish company Tech Troopers AB, takes data protection/data privacy seriously. Under European Union law based rules every data controller (the entity that determines purpose and means of collection, use etc. of personal data) shall provide the individual whose personal data is processed (you) with information about the processing and this in accordance with in law rather detailed set out requirements. This document, thus, does not purport to extend your rights but rather to inform you about the processing of your personal data as may be required by law and which may be undertaken due to you being a customer.

The controller of your personal data described herein is the entity with which you have signed a service agreement, (henceforth “Tech Troopers”), unless otherwise is provided. It is Tech Troopers as controller that determines the purposes and means of the processing of your personal data.

Sources:

Personal data that you provide (or have provided) to Tech Troopers is personal data which this Notice is intended to cover and information you provide to Tech Troopers may, thus, be processed as further described in this Notice. Such information may include name, date of birth, social security number or other national identification number, address, telephone number, e-mail address, transaction information, including rental payments, deposits, method of payment and amount, where applicable credit card information, information about a guarantor and trustee if applicable, information about occupants of your household other than you such as family members/dependents names, if there are any, and other information requested on an application form or other documents from Tech Troopers.

Personal data may be obtained or generated from other sources, in addition to the data you provide directly. Such sources may include: (i) external persons providing contracting services to Tech Troopers, and (ii) data from security equipment.

Purpose and legal basis for processing (why):

Processing of your personal data is necessary for Tech Troopers´ business operations, including to provide services to you and to maintain the relationship between Tech Troopers and you as customer, and may, thus, occur for the following purposes and reasons:

a) for the performance of Tech Troopers’ service agreement with you;

b) to comply with legal obligations which fall upon Tech Troopers (e.g. communications to government authorities for purposes of tax reporting);

c) when necessary for the establishment, exercise or defence of legal claims your personal data may also be processed for such purpose (e.g. in the event of your non-payment of an invoice for services rendered); and

d) to the extent not covered by the above, Tech Troopers may process your personal data when necessary for purposes of legitimate interests pursued by Tech Troopers (or by a third party) except where such interests are overridden by your interests or your fundamental rights and freedoms (e.g. security as well as health and safety of Tech Troopers’ personnel and contractors).

How personal data may be processed (how):

For the above described purposes and reasons personal data may be shared with other entities within the Tech Troopers group of companies.

For the above described purposes and reasons, not least to provide cost efficient services, as part of Tech Troopers´ business operations personal data may be shared with the following categories of third parties also outside the Tech Troopers group:

a) with authorities for processing tax deductions;

b) police and local law enforcement, if they request information;

c) to IT-utility companies to ensure bills are invoiced to the correct people covering the correct dates; and

d) to contractors providing contracting services or IT-services.

Sharing of personal data shall be subject to undertakings as to compliance with data protection requirements and that any data is only to be used for the reasons for which it shared.

Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for you and your rights, appropriate technical and organisational measures to ensure a level of security appropriate to the risk shall have been implemented before processing of personal data takes place by Tech Troopers as well as by entities with which Tech Troopers shares personal data.

Any person acting under the authority of Tech Troopers, who is granted access to your personal data, shall not process those data except on, and in accordance with, by Tech Troopers given instructions or unless required to do so by law. The principal rule is access on “a need to know basis”.

Transfers abroad:

Your personal data may be transferred abroad, i.e. outside the country in which Tech Troopers and you are located, to the categories of third parties within and outside the Tech Troopers group as described above, for the above set out purposes and reasons.

For how long:

It is not possible to generally state a period for which personal data will be stored but the criteria used to determine that period are that your personal data shall not be stored for a period longer than necessary for the purposes for which it is processed and accordingly personal data held shall be screened regularly. Tech Troopers may keep details of the service agreement and related records also after termination or expiry of the service agreement, e.g. if necessary to monitor any remaining debts related to the agreement or as otherwise determined necessary to fulfil purposes for which the personal data has been collected and kept.

Access rights:

As determined by applicable law, as a data subject you have the right to request information about how Tech Troopers processes your personal data. Thereto you have, as determined by applicable law, the right to receive the personal data in order to exercise your right to data portability, i.e. to transmit your personal data to another controller. Such requests shall be in writing, be signed and sent to Tech Troopers (see contact details below).

You have, as determined by applicable law, the right to request rectification or erasure of personal data or restriction of processing or object to the processing and you can lodge a complaint with a national data protection authority, if the processing of your personal data or rights in relation thereto does not meet the requirements under applicable law. Should you need further information hereabout see further below under “Contact details etc”.

Contact details etc.:

In case of any questions regarding the processing of your personal data by Tech Troopers, e.g. the purposes of processing of your personal data or information about who may access your data or if you need information about your rights as to Tech Troopers´ processing of your personal data under applicable law, you can contact:

Name: Jerker Vannerus

Address: Tech Troopers, Kungsgatan 3, 111 43 Stockholm, Sweden

E-mail address: gdpr@techtroopers.com

Telephone number: 23 96 44 44

VERSION: 1.0/2018-04

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