PURPOSE OF THIS POLICY
Personal data is information that can be used to identify you or which may otherwise be linked to you. It is important that you feel secure when you provide your personal data to CBG Konsult & Information AB and its subsidiaries in the Group, hereinafter referred to as CBG. In many cases, it is the parent company, CBG Konsult & Information AB, which is considered to be the Data Controller for the processing of personal data. However, a subsidiary may be the Data Controller when it independently determines the purpose and means for the processing of personal data, e.g. in relation to customers who enter into agreement directly with the subsidiary.
CBG has worked out this policy to explain to you for what your personal data may be used for and how, and what rights you have and the obligations CBG as Data Controller has in the processing of your personal data.
WHAT PERSONAL DATA IS PROCESSED?
CBG will mainly process personal data that you have provided when we have been in contact with each other and personal data that CBG gets access to when performing different assignments according to business agreements. For example, it may have been in connection with a customer contact, assignments, and recruitment or in any other context. Therefore, the personal data CBG processes depends on what kind of contact it concerns. CBG stores complete name, job title, address, phone number, email address, the legal entity you represent, owe or where you work and information about your previous workplaces or involvement for the following categories:
- Person making an inquiry regarding CBG’s services on the web
- Customer representative accessing systems hosted by CBG or by CBG's service providers.
- Applicant for language-related freelance assignments
- Applicant participating in a recruitment process - Potential employee
- Representative – Potential customer
- Representative – Active customer
- Representative – Potential supplier
- Representative – Supplier
If a contact is developed and leads, for example, to the participation in a tender on the behalf of CBG, to a freelance cooperation or to the participation in a recruitment process for an employment, CBG will request additional personal data necessary to carry out the processes related to a tender process, to a freelance cooperation or a recruitment process for an employment.
Some personal data about you may have been obtained from other sources, such as standard search engines, professional online directories and social media for the purpose of developing and marketing our business mainly in terms of freelance resources like translators and customers.
Since CBG’s organization is constituted by teams with team members located in different countries, it has a legitimate interest to transfer personal data between CBG's various entities in the Group in a continuous information and knowledge exchange in order to ensure that the global operations can be conducted in a manner consistent with established business goals.
We will also transfer personal data between the CBG’s entities in China (P.R.C) and the U.S. In these cases we will take all reasonable legal, technical and organisational measures in order to ensure that your personal data is handled securely and with an adequate security level and in accordance with applicable data protection legislation.
You are not required to provide your personal data to us, but if requested personal data is not disclosed, CBG cannot for example initiate a recruitment process, undertake an assignment or place an order.
THE PURPOSE OF PROCESSING PERSONAL DATA
CBG uses your personal data for the purpose to:
- Manage contacts and the cooperation with customers, freelance resources like translators and providers of different services, which require that accurate and updated personal data is maintained in CBG's various systems.
- Perform recruitment processes for potential employment, which require that accurate and updated personal data is maintained in CBG's various systems.
- Fulfill CBG's obligations according to legal requirements including for example accounting and invoicing purposes.
- Prevent abuse of a service, prevent, discourage and investigate criminal actions against CBG, e.g. possible fraud or other offenses or protect and improve CBG’s IT environment against attacks and intrusion.
- Use for the development of CBG’s business activities like sales, marketing, production processes, methodology, services.
- Fulfill the obligations towards the customers according to concluded agreements.
Personal data that CBG possesses will be processed based on the following legal grounds:
- To fulfill concluded agreements with customers, freelance resources like translators or providers of different services.
- To comply with legal requirements.
- To fulfill a purpose to meet CBG’s or a third party’s legitimate interest.
CBG only uses your personal data for the purpose for which you provided the data.
WHO MAY ACCESS YOUR PERSONAL DATA
CBG is responsible in ensuring that its personnel shall only have access to your personal data on a need-to-know basis and be committed to keep such data confidential. CBG will not disclose personal data to third parties other than when:
- When it has been agreed upon between CBG and you.
- It is necessary for CBG to comply with legal requirements from e.g. government authorities.
- It is necessary to fulfill CBG’s commitments to customers by contracting external service providers, so-called Data Processors(*), like financial institutions, insurance companies, companies providing fringe benefits, companies providing occupational healthcare, freelance language resources such as translators, IT service providers, provider of telecom services, recruitment companies and, where required by law, regulation or government decision as in the case of auditors.
(*) A Data Processor is a company that processes personal data on behalf of CBG in accordance with CBG's instructions. A Data Processor is not entitled to use the data for purposes other than those agreed in a Data Processing Agreement, where the Data Processor undertakes to ensure the security of the personal data processed and undertakes to comply with detailed security requirements and to take the necessary technical and organizational measures to protect your personal data.
STORING OF PERSONAL DATA
CBG will save your personal data as long as the information is required for the purpose they were collected. CBG will delete the data that is no longer required but may retain certain personal data to meet legal requirements.
Certain personal data regarding freelance language resources like translators, which are stored in CBG’s business system, are considered crucial for CBG’s business activities.
Data processed for the purpose of developing, and marketing CBG’s business is stored for a period of one year from the last contact.
If you opt out of receiving newsletters or participating in CBG’s yearly customer survey, CBG will stop using your personal data for these purposes.
Personal data related to taxes and bookkeeping will be stored according to the period of time stipulated in the current legislation of the country where the CBG entity has its legal domicile.
YOUR RIGHTS AS REGISTERED
Right to register extract
You have the right to receive information regarding what personal data we process about you.
Please bear in mind that if CBG receives a request for registry extracts, it may be necessary to ask for additional information to ensure the effective handling of your request and that the information is provided to the correct person.
Right to ask for correction
You have the right to request your personal data to be corrected if the data is incorrect. Within the stated purpose, you also have the right to supplement any incomplete data.
Right to erasure
Personal data will not be stored longer time than stated previously (see section “Storing of personal data”) and CBG will delete personal data in accordance with applicable law. You may request the deletion of your personal data that is stored at CBG. CBG may also correct or delete data that is incorrect or limit the processing of such data on its own initiative. CBG may have the right to deny your request if there are legal obligations that prevent CBG from immediately deleting certain personal data or if the personal data is needed for another purpose.
Right to dataportability
You also have the right to receive your personal data in a commonly used machine-readable format that you have previously submitted to CBG for processing in the event that this data was processed according to your consent or because of agreement.
Right to withdraw your consent
If you have given your consent to CBG, you have the right to withdraw your consent. When you withdraw your consent, the processing that the consent intended will cease and the personal data collected by your consent will be deleted provided that the personal data is not required for any other purpose that CBG has the right to process your personal data for.
Right to object to and restriction of processing
You can always object to our processing of your personal data for marketing purposes or to any processing carried out for the purpose of fulfilling CBG’s or third party’s legitimate interest.
In some cases you also have the right to request that we restrict the processing of your personal data.
EXERCISE OF YOUR RIGHTS
If you wish to exercise any of your rights listed above, please contact us. Contact details are provided in the section “How do you contact CBG?”
CBG will promptly handle your request. In case CBG does not intend to concede your request or to not concede it in full, you will be informed and the reasons for the decision.
DATA PROTECTION AUTHORITY
In every EU country where the parent company and its subsidiaries are established, there is an authority that is responsible for monitoring the application of the GDPR. If you believe that your personal data has been handled in violation of current legislation, you will be able to file a complaint with the respective authority.
HOW DO YOU CONTACT CBG?
CBG takes privacy and data protection seriously. CBG continuously monitors the security measures that it considers necessary to protect personal data through confidentiality and ensure its availability and accuracy. Contact information in the event of a request for register extract/amend/delete data as well as other questions relating to personal data processing is as follows:
Name: CBG Konsult & Information AB
Corporate ID number: 556172-1993
Postal address: Box 1036, 172 21 SUNDBYBERG, Sweden
Visitor’s address: Löfströms allé 6 A, 3rd floor, 172 66 SUNDBYBERG, Sweden
Telephone: +46(8)555 84 00
You can reach our Data Protection Officer (D.P.O.) on the following e-mail address.