Privacy Policy
Effective Date: 21 April, 2026
Nordic Funds and mines (“NORDICFUNDS”) and with Bottnia Group International FZCO (BOTTNIA”) is committed to protecting the privacy of personal information of its members, exhibitors, event attendees and all users of its services. This Privacy Policy has been prepared to affirm Nordic Funds commitment to maintaining high standards of confidentiality and to set out, in general terms, Nordic Funds’s practices concerning the collection, use and disclosure of your personal information. Please read this policy carefully. By using our services Nordic Funds deems you to have consented to the collection, use and disclosure of your personal information for the purposes and in accordance with the practices set out below.
- Defining Personal Information
Personal information is any information about an “identifiable individual” that can be used to distinguish, identify or contact a specific individual. Business contact information such as information on your business card and certain publicly available information, such as names, addresses and telephone numbers as published in telephone directories are not considered personal information. Likewise, aggregated and/or de-identified information which cannot be associated with an individual is not considered to be personal information. Information about corporations is also not considered personal information.
Where an individual provides his or her home address to Nordic Funds as their business contact information, Nordic Funds considers it to be business contact information, and is therefore not subject to protection as personal information.
- Collection of Personal Information
Nordic Funds limits the collection of personal information to what is reasonably required to fulfill the purposes for which it is collected. Nordic Funds collects personal information in a variety of ways as further detailed in the “How Nordic Funds Collects Personal Information” section below.
Personal information Nordic Funds collects may include:
- Identifiers and contact information, such as your name, email telephone number, and Internet Protocol (IP) address;
- Demographic data, such as date of birth, age, gender;
- Financial information, which may be collected in order to render services, process honoraria payments or for legally required forms related to such payments. We do not retain Credit Card information provided for online payments.
- Browsing activity on our websites, such as pages viewed, opt-out preferences, email bounce backs, click-throughs, social media content, and IP addresses.
- Any other information you provide to us. We collect no personal information about you unless you choose to provide that information to us. We do not use techniques that collect personal information about anyone without their knowledge. We only collect personal information about individuals when they specifically and knowingly provide it to us, for example when they apply for membership, register for a program or complete a registration form.
- Means of Personal Information Collection
Nordic Funds collects personal information in a variety of ways, including: directly from you, from other sources, through online technologies (such as when you interact with Nordic Funds through the Nordic Funds website) and from third-party social networks.
- Directly From You
Nordic Funds may collect personal information directly from you by email, over the telephone, through the Nordic Funds website contact form or in any other direct manner, for instance when you participate in a survey, interview, or other market research.
- From Business Partners
Occasionally, Nordic Funds may receive personal information from Nordic Funds’s business partners. Nordic Funds may also receive your personal information from other sources with your consent or when authorized by law.
- Through Online Technologies
Nordic Funds may collect certain types of information electronically when you interact with the Nordic Funds website, emails, social media accounts, online advertising, or through the use of Nordic Funds or a third party’s technologies, which include cookies or single pixel gifs or analytics engines. This information helps Nordic Funds understand what actions you take on Nordic Funds’s website and allows the Nordic Funds website to work correctly.
To learn more about the privacy choices available to you, please visit the “How Can You Change Your Privacy Choices?” section below.
The technologies Nordic Funds uses include:
- Cookies, which are small text files that are saved on your computer when you visit a website so that information can be saved between visits, such as your login credentials or language preferences. For example, cookies allow you to log in quickly when you visit Nordic Funds’s website.
- Web Bottnias, and single pixel gifs, which are small image files that have information about you, such as your IP address, that can be downloaded when you visit a website or open an e-mail. This allows Nordic Funds to understand your online behaviour, monitor Nordic Funds email delivery, and provide you with interest-based advertising. These tools also allow Nordic Funds third-party tracking tools to gather information, such as your IP address, and provide this back to us in an anonymized, aggregate form (i.e. in a manner that prevents us from identifying you personally). Aggregate information refers to personal information compiled and expressed in a summary form where no personal identifiers are included.
- Web analytics tools such as Google Analytics, which uses cookies to analyze your use of the Nordic Funds website, to create reports about visitor and user activities for Nordic Funds and to provide further services associated with the use of Nordic Funds’s website.
- Analytics engines, which pull usage data from multiple sources and help manage and collect this data to gain insights into Nordic Funds customer needs and preferences.
- Tools that help protect against inappropriate uses, such as Google Invisible reCAPTCHA, which collects hardware and software information, such as device and application data and the results of integrity checks, as well as unique online identifications such as IP address, and sends that data to Google for analysis.
You may delete or disable certain of these technologies at any time via your browser. However, if you do so, you may not be able to use some of the features on the Nordic Funds website. To learn more about the privacy choices available to you, please visit the “How Can You Change Your Privacy Choices?” section below.
- Third-Party Social Networks
Nordic Funds may collect your personal information if you interact with Nordic Funds through Nordic Funds social media pages and accounts (e.g. Twitter, LinkedIn). For instance, Nordic Funds collects the personal information the respective social media platforms allow Nordic Funds to collect from Nordic Funds’s followers. Nordic Funds may also collect any content you upload to Nordic Funds social network pages (including photos or videos).
In addition, third-party social networks that provide interactive plug-ins to enable social network features (e.g., to connect to LinkedIn) on the Nordic Funds website may use cookies to gather information on your use of the website. How this collected data is used by a third party is dependent on the privacy policy of the social network which is available on the appropriate parties’ website. Nordic Funds encourages you to review the privacy policies of third parties as well. Third parties involved may use these tracking methods such as but not limited to cookies to achieve their own business goals and purposes by relating and combining information about your usage of the Nordic Funds website to any other personal information they may have collected on you. Nordic Funds may also obtain and use analytical and statistical information from third-party social networks to help Nordic Funds measure performance and effectiveness of content Nordic Funds displays on social networks, for example, by measuring impressions and clicks on the content Nordic Funds promotes.
- How we use the information we collect:
Nordic Funds processes personal information collected via our websites and registration forms for the following legitimate interests:
- Communications & Marketing
Your information may be used to send you details of those products or services that we offer that we have identified as likely to be of interest to you. This will be in accordance with any communication preferences that you may have indicated when you completed a data capture form. We also enable communications from time to time between you and others through our services. We will use data about you to suggest connections for you and others (e.g. Matchmaking activities) and enable you to invite others to connect with you. You may change your communication preferences at any time by notifying us at info@nordicfundsandmines.com
- At Events
We may provide relevant information for hospitality and safety purposes to hotels and venues hosting our events and third-party service providers. At some of our events we may use RFID-enabled badges (which we use to track your location around our event venue so we can better understand your areas of interest). You can opt to have your personal details anonymised at point of collection.
- Payments
All transactions are processed through a PCI compliant gateway provider and are not stored or processed on our servers.
- Surveys & Research
We may communicate with you about surveys, marketing, promotions, events, educational forums, and other exclusive opportunities offered by Bottnia and its partners and affiliates. You are not obligated to respond to surveys.
- Customer Support
We use the data (which can include your communications) needed to investigate, respond to and resolve complaints and service issues.
- Aggregate Insights
We use your information to produce aggregate insights that do not identify you. For example, we may use your data to generate statistics about users, their profession or industry and the number of pages served or clicked on.
- Data Retention
We retain the personal data you provide as needed to provide you services as listed in this policy. Data may persist in copies made for back up and business continuity purposes for additional time, including information required for regulatory and legal compliance.
- Videography & Photography
Multim media material such as Interview footage/clips will be used in Nordic Funds multimedia material such as videos to promote content and marketing for our events. Participants have the right to receive updates from Nordic Funds for the usage of any footage in future campaigns/products.
Highlight footage will be processed following each event to create highlight videos.
All footage may also be used in events highlight videos to promote our future events and used in marketing campaigns on the Nordic Funds website, emails and social media.
Photographs may be published on the Nordic Funds website to promote the events, they may also be used in association with the event presentation library, as a cover image or thumbnail.
- Disclosure of Personal Information
We may share your personal information with other organizations as described below.
In respect of personal information disclosed to third parties, Nordic Funds takes appropriate steps, where permitted by law, to ensure that such third parties use the personal information only in connection with the purposes for which the information was collected and to safeguard the personal information against unauthorized use or disclosure. While personal information is being processed outside your country of residence by third party service providers on behalf of Nordic Funds, the personal information may be accessed by the courts, law enforcement and national security authorities of the foreign country where it is being processed.
- Service Providers
In the course of providing our services we may share your personal information with third party service providers who perform services on our behalf. These service providers help us operate our business and improve the services we offer to you. They provide services to us, such as sending emails, data hosting, providing advertisements, market research. We require these service providers to limit their access to and/or use of personal information to what is required to provide their services and require that those third parties adhere to confidentiality as well as security procedures and protections.
Examples of service providers with whom Nordic Funds may share your personal information include:
- Payment solution providers;
- Vendors providing services for Nordic Funds events and conferences, including hotels, event spaces, lead retrieval, and email marketing
- Data processing, facilities management, and customer support operations;
- Other Permitted Reasons
In certain circumstances Nordic Funds may share personal information without your consent and when authorized by law to do so, such as to comply with a warrant or other order from a court or a governing regulatory authority; to investigate the breach of an agreement or applicable law (for example, investigating potential theft); and when required in the context of a prospective or completed business transaction, such as a transfer of assets or shares or merger.
In these circumstances, Nordic Funds will not share more personal information than is reasonably required to fulfill that particular purpose.
- With your consent
Other than for the purposes listed above, Nordic Funds may also share or disclose your personal information with your implied or express consent. For example, Nordic Funds may disclose your personal information to references you provide or to your designated agent.
Nordic Funds will generally obtain consent when Nordic Funds wants to use personal information for a new purpose or for a purpose other than those stated at the time of collection in this Privacy Policy or in the terms and conditions of a specific service or Nordic Funds offering in which you have participated. You may be entitled under applicable law to withdraw your consent (except in limited circumstances, including legal or regulatory requirements or as a result of your contractual obligations with Nordic Funds). For information on how to manage your privacy preferences, please see the “How Can You Change Your Privacy Choices?” section below.
If you choose not to provide Nordic Funds with certain personal information or if you withdraw your consent, where such withdrawal is available, Nordic Funds may not be able to offer you the programs, products, services, contests, promotions, events or information that you requested or that could be offered to you.
- Security and Storage of Personal Information
Nordic Funds endeavours to maintain appropriate safeguards and adequate physical, procedural and technical security with respect to our offices and information storage facilities so as to prevent any unauthorized access, disclosure, copying, use, or modification of personal information. Safeguards include securing physical documents and technological measures by way of secure access and encryption. Nordic Funds employees are authorized to access personal information based only on their need to deal with the information for the reason(s) for which it was obtained. Safeguards are in place to ensure that the information is not disclosed or shared more widely than is necessary to achieve the purpose for which it was gathered. We also take measures to ensure the integrity of this information is maintained and to prevent its being lost or destroyed.
To ensure the integrity and privacy of the personal and credit card information you pass to us via the Internet when you make an online transaction, Nordic Funds uses a certified data center and the services of a third party application which performs all credit-card processing and is validated annually by the Payment Card Industry (PCI) Council to meet the Payment Application Data Security Standard (PA-DSS).
Nordic Funds will store your personal information in accordance with Nordic Funds’s retention policies or as otherwise required or permitted by law, after which your personal information will be securely destroyed or anonymized (so the information no longer identifies you).
- How Can You Change Your Privacy Choices
Nordic Funds wants you to clearly understand your choices and make informed decisions about your privacy options. There are several options available for you to manage your privacy preferences.
Learn more about how to change your privacy choices when you register or by contacting Nordic Funds directly, and using third party unsubscribe functionality
- When Register or by Contacting Us Directly
You may opt in to receiving email marketing communications at the time that you register for Nordic Funds’s services.
You may opt out of:
- Receiving email marketing communications, by clicking “unsubscribe” within any marketing email you receive, following the opt-out instructions provided;
- Receiving interest-based advertisements by changing your browser settings on your device, and/or using third party unsubscribe functionality (e.g., via Google or LinkedIn) to change your preferences within their platforms. Please note that disabling, blocking or deleting some of these technologies, such as cookies, may cause you to lose the functionality of certain features on our websites.
Please note the following regarding withdrawal of consent or changes in your privacy preferences:
- Even if you have opted out of receiving marketing communications from Nordic Funds, we may still contact you for transactional purposes, in compliance with applicable laws (e.g., for customer service or reminder notices). Nordic Funds may also need to contact you with questions or information regarding your customer service inquiries.
- Using Third Party Unsubscribe Functionality
Nordic Funds may use third parties (e.g., social media platforms) that use certain technologies to analyze your browsing behaviour as you visit Nordic Funds’s website. You can manage your privacy preferences with respect to certain third parties, such as Google, by using the unsubscribe functionality within their platforms. Please note that disabling, blocking or deleting some of these technologies, such as cookies, may cause you to lose the functionality of certain features on the Nordic Funds website.
For example, Google Analytics uses cookies to analyze your browsing behaviour on Nordic Funds’s website. This information is not provided to Nordic Funds in a personally identifiable format and is collected through your ad settings on your device or browser. If you would like to opt out of Google’s ad settings, please go to www.google.com/settings/ads or use the Google opt out browser add-on located at https://tools.google.com/dlpage/gaoptout.
Nordic Funds may also embed links to other websites, including social media websites, on Nordic Funds’s website. For more information about social media plug-in protocols, such as “Like” buttons on Twitter, LinkedIn and their impact on your privacy rights, please visit the appropriate social media help center (e.g., LinkedIn Help Center at https://www.linkedin.com/help/linkedin).
- Accessing and Correcting Your Personal Information
You may have the right to access and rectify the personal information Nordic Funds holds about you under the law applicable in the jurisdiction where you reside. In this case, upon request, Nordic Funds will provide you with access to your personal information within a reasonable timeframe, in compliance with applicable laws. It is your responsibility to provide accurate, correct and complete information.
You can request access or rectification by contacting the applicable Privacy Office as described in the “Where to Learn More” section.
- Cookie Policy
We use cookies across our websites to improve their performance and enhance your user experience. This policy explains how we do that.
What are cookies?
Cookies are small text files which a website may put on your computer or mobile device when you first visit a site or page. The cookie will help the website to recognise your device the next time you visit.
There are many functions cookies serve. For example, they can help us to remember your username and preferences, analyse how well our website is performing and allow us to recommend content we believe will be most relevant to you.
Certain cookies contain personal information – for example, if you click to “remember me” when logging in, a cookie will store your username.
What sort of cookies do we use use?
- Performance Cookies
We utilise other cookies to analyse how our visitors use our websites and to monitor website performance. This allows us to provide a high quality experience by customising our offering and quickly identifying and fixing any issues that may arise. For example, we might use performance cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages. We might also use these cookies to highlight articles or site services that we think will be of interest to you based on your usage of the website.
- Functionality Cookies
We use functionality cookies to allow us to remember your preferences. For example, cookies save you the trouble of typing in your username every time you access the site, and recall your preferences, such as which sections of the website you want to see when you log in.
- Behaviourally Targeted Advertising Cookies
Bottnia and our advertisers sometimes use cookies to serve you with targeted advertisements that we believe are relevant to you and your interests.
We also use or allow third parties to serve cookies. For example, we use Google Analytics to help us monitor our website traffic. We may also use third party cookies to help us with market research, revenue tracking, improving site functionality and monitoring compliance with our terms and conditions and copyright policy.
Can Visitors Block Cookies?
When you accessed our site, you should have seen an overlay which explained that by continuing to access our site, you are consenting to our use of cookies.
However, if you do wish to disable our cookies then please follow the instructions from www.aboutcookies.org/Default.aspx?page=1.
Please remember that if you do choose to disable cookies, you may find that certain sections of our website do not work properly
More information
More detail on how businesses use cookies can be found at www.allaboutcookies.org.
10. Updates to Policy
Nordic Funds may make changes to this policy from time to time. Any changes Nordic Funds makes will become effective when posted on the Nordic Funds website. If the changes made are significant, Nordic Funds will provide a more prominent notice as required by applicable laws.
11. Where to Learn More
To learn more about the collection, use, disclosure and protection of your personal information, to request access to or correction of your personal information, or to make a complaint, please contact us at info@Nordicfundsandmines.com
EU GDPR ADDITION
Name and address of the entity controlling the information also reffered to as the controller in the EU.
Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
Bottnia Group International FZCO
IFZA Business Park, Dubai Silicon Oasis, DDP, Building A1, Dubai, United Arab Emirates.
Email: info@nordicfundsandmines.com
Website: www.nordicfundsandmines.com
DEFINITIONS
The data protection declaration of the Bottnia Group International FZCO is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.
In this data protection declaration, we use, inter alia, the following terms:
- a) Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- b) Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
- c) Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- d) Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
- e) Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
- f) Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person
- g) Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
- h) Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
- i) Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
- j) Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
- k) Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
RIGHTS OF THE DATA SUBJECT
- a) Right of confirmation
Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.
- b) Right of access
Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
- the existence of the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from the data subject, any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.
- c) Right to rectification
Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.
- d) Right to erasure (Right to be forgotten)
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
- The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
- The personal data have been unlawfully processed.
- The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
- The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the Bottnia Group International FZCO, he or she may, at any time, contact any employee of the controller. An employee of Bottnia Group International FZCO shall promptly ensure that the erasure request is complied with immediately.Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employees of the Bottnia Group International FZCO will arrange the necessary measures in individual cases.
- e) Right of restriction of processing.
Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
- The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
- The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
- The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the Bottnia Group International FZCO, he or she may at any time contact any employee of the controller. The employee of the Bottnia Group International FZCO will arrange the restriction of the processing.
- f) Right to data portability
- g) Right to object
- h) Automated individual decision-making, including profiling
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, the Bottnia Group International FZCO shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of the Bottnia Group International FZCO.
- i) Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the Bottnia Group International FZCO.
LEGAL BASIS FOR THE PROCESSING
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR.
In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR.
Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDP
THE LEGITIMATE INTERESTS PURSUED BY THE CONTROLLER OR BY A THIRD PARTY
Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.
PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
PROVISION OF PERSONAL DATA AS STATUTORY OR CONTRACTUAL REQUIREMENT; REQUIREMENT NECESSARY TO ENTER INTO A CONTRACT; OBLIGATION OF THE DATA SUBJECT TO PROVIDE THE PERSONAL DATA; POSSIBLE CONSEQUENCES OF FAILURE TO PROVIDE SUCH DATA
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner).
Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded.
Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.
EXISTENCE OF AUTOMATED DECISION-MAKING
As a responsible company, we do not use automatic decision-making or profiling.
ROUTINE ERASURE AND BLOCKING OF PERSONAL DATA
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
CONTACT POSSIBILITY VIA THE WEBSITE
The website of the Bottnia Group International FZCO contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.
COLLECTION OF GENERAL DATA AND INFORMATION
The website of the Bottnia Group International FZCO collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using these general data and information, the Bottnia Group International FZCO does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the Bottnia Group International FZCO analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
REGISTRATION ON OUR WEBSITE
The data subject has the possibility to register on the website of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for his own purposes. The controller may request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to the controller.
By registering on the website of the controller, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.
The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.
The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The entirety of the controller’s employees are available to the data subject in this respect as contact persons.
SUBSCRIPTION TO OUR NEWSLETTERS
On the website of the Bottnia Group International FZCO, users are given the opportunity to subscribe to our enterprise’s newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.
The Bottnia Group International FZCO informs its customers and business partners regularly by means of a newsletter about enterprise offers. The enterprise’s newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.
During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.
The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller, or to communicate this to the controller in a different way.
NEWSLETTER-TRACKING
The newsletter of the Bottnia Group International FZCO contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, the Bottnia Group International FZCO may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.
Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller. The Bottnia Group International FZCO automatically regards a withdrawal from the receipt of the newsletter as a revocation.
