For anyone who is a representative of a supplier, media contact, corporate customer or other partner to Swedish Match
What personal data and why?
As part of our business operations, we may process data relating to you.
These are data that we may have received from your employer in the event that we have a contract or another business relationship with them, such as if you appear as company signatory or are given as the contact person for a certain contract or for a certain matter. Additionally, we may have received the data from you directly if you have contacted us directly by telephone, e-mail or given your business card (or other contact details) to one of Swedish Match’s representatives. Collection of these types of details may also occur when we ourselves gather information by searching for contact persons at companies with which we have or want to establish a business relationship.
The data that we typically process regarding you are your e-mail address, your name, your telephone number, your workplace and your title. If your company has a customer relationship with Swedish Match, we also process data related to the customer case, such as customer number, password for the customer account, notes on activities for the case, preferences and order history, transaction data, invoicing data, payment information and data relating to signing the contract and credit checks conducted (where relevant).
If you have a business relationship with us as a sole trader, your personal identity number, account number and residential address/invoicing address may be processed in addition to the information specified above if this is required in order for Swedish Match to be able to identify you as a customer and meet the purposes in accordance with the following.
The purposes of us processing your personal data are that we must be able to communicate with you in order to maintain or establish a business relationship with you and/or the organization that you represent and, where necessary, to complete and administer the contractual relationship with your employer, manage purchases and deliveries, invoices/payments and communicate with you within the framework of the contractual relationship. In relevant cases, we also need to process your data with the aim of meeting our legal obligations, such as in accordance with accounting, product safety and product liability laws.
Our legal basis for processing is our contract with you or the organization that you represent (where relevant) and/or our legitimate interests in communicating with you in your professional capacity. The communication may comprise information connected with your business relationship with Swedish Match, news and events that we believe could be of interest to you, and occurs as part of our endeavor to maintain and establish a positive business relationship with you.
The processing of data that we require for our accounting or to manage legal claims is conducted in relevant cases also with the support of Swedish Match’s legal obligations in accordance with legislation that includes accounting, product safety and product liability laws.
In conjunction with entering a new contract or other business partnership, we may need to collect and process certain data regarding you in case we are obliged to do so in accordance with special regulations established in relation to economic sanctions, export controls, money laundering, financing of terrorism and market abuse. The data are collected through our suppliers’ compliance systems and may comprise data regarding publication in the media (including photos), offenses, persons in politically exposed positions and other special categories of personal data that are relevant for us to have knowledge of for the context in question. Data that we process regarding offenses include information about any disqualification from commercial activities, money laundering or other criminal acts. Data regarding persons in politically exposed positions comprise information on how you, someone close to you or one of your coworkers is a so-called person in a politically exposed position and, where relevant, the name, personal identity number and occupation/position for such a politically exposed person. Our legal basis for processing these personal data is that we, in relevant cases, must be able to observe the special rules established in relation to economic sanctions, export control, money laundering, financing of terrorism and market abuse, as well as defending ourselves against legal claims.
How long do we save the data?
If we process your personal data with the aim of fulfilling the contract we have with the organization that you represent, we will process the data as long as it is necessary to enable us to administer the contractual relationship and to exercise our rights and obligations in relation to our contractual counterpart. However, thereafter we may save some of your personal data for a longer time if we are obliged to do so by law (such as for our accounting) or assess that we are entitled to do so with the support of legitimate interests.
We may also save your personal data for a longer time if it is necessary to establish, enforce, or defend legal claims.
Who do we share your personal data with?
Swedish Match may share your personal data with other companies within the Swedish Match Group, as well as with collaborating partners, for example when providing IT services. These recipients only process your personal data on our behalf and in accordance with our instructions. Swedish Match takes all appropriate legal, technological and organizational measures to ensure that your personal data is processed securely, and with an adequate level of security when transferring to, or sharing with, selected recipients of this kind.
Swedish Match may also share your personal data with other companies who process your personal data independently, outside of our control. We only share your information with these companies in order to fulfill our commitments towards you. When your personal data is shared with these companies, which are independent controllers, your personal data is processed in accordance with what is outlined in these companies’ privacy notices.
Swedish Match may also share your personal data with government agencies if we are obligated under the law to do so, or on suspicion of criminal activity.
Where do we process your personal data?
Your personal data will primarily be processed within the EU/EEA, but may also be transferred to a country outside the EU/EEA, such as the United States, for example, if we share your information with other companies in the Swedish Match Group.
Swedish Match will only transfer your personal data to a country outside the EU/EEA if there are legal grounds to do so and sufficient guarantees that your personal data will be handled in a lawful manner. In such cases, Swedish Match takes all appropriate legal, technological and organizational measures to ensure that your personal data is processed securely, and with an adequate level of security comparable to the level of protection offered within the EU/EEA.
How do we protect your personal data?
Swedish Match takes the security measures needed to protect your personal data.
What are your rights?
Read about your rights here: What are your rights?
Contact, questions and complaints
Read about i.a. how to contact Swedish Match here: Contact, questions and complaints
