Introduction

Data privacy and safe processing of personal data is a priority for Adtraction. Those who provide Adtraction with personal data can trust that the personal data is processed in accordance with applicable personal data legislation, for example the General Data Protection Regulation (EU) 2016/679 ("GDPR") and other supplementary national legislation.

 

Adtraction have taken great measures to be GDPR compliant and this Privacy Policy has been created in order for you to better understand how your personal data is processed by us. This Privacy Policy is not exhaustive but contains some fundamental privacy principles applied by Adtraction to safeguard the integrity of individuals.

 

Adtraction may change this Privacy Policy from time to time to keep it compliant with applicable laws such as the GDPR.

 

Adtraction and in some cases its subsidiaries are responsible for personal data provided to Adtraction.

 

 

 

 

Adtraction's processing of personal data

Definitions

Personal data comprises all types of information that directly or indirectly can be linked to an individual, including name, address or telephone number.

 

Personal data that Adtraction processes

Adtraction collects and processes several types of personal data, all depending on the situation. Examples of such personal data are names, addresses, e-mail addresses, phone numbers, IP-addresses, personal identity numbers, bank account numbers or other information that you provide within the framework of Adtraction's service.

 

Below is a description of the situations when we collect and process data. You can also read about what purposes we process data for, what legal grounds we rely on and for how long we store the data.

 

Personal data which Adtraction process when you visit Adtraction's website

If you are only using the website for information and do not register or transmit information to us in any other way, we only collect the personal data which your browser transmits to our server.

 

The purpose of processing personal data when you visit Adtraction’s website is to enable for us to display our website to you and to guarantee its stability and security. We collect the following data which is technically necessary to fulfil the purpose:

• IP address
• Date and time of the enquiry
• Time zone difference from Greenwich Mean Time (GMT)
• Content of the request (specific page)
• Access status / HTTP status code
• Quantity of data transferred in each case
• The website from which the request comes
• Browser
• Operating system and its interface
• Language and version of the browser software

 

The legal ground for processing data is our legitimate interest to display our website in a safe manner. This mean that we, after careful consideration, assess that your interests or fundamental rights and freedoms do not outweigh and require the protection of personal data. The retention time for personal data which is collected when you visit Adtraction’s website is listed in our cookie-table below.

 

When you contact Adtraction via e-mail, chat box or telephon

If you contact Adtraction by e-mail, telephone or via our chat box, for example because you have a question regarding our service, we handle the information you have chosen to provide at the time of contact. The processing of your personal data depends on what your matter concerns, we process the following data:

• Name
• Telephone number
• E-mail address

 

We process your personal data for our legitimate interest in handling your matter, meaning that we – after careful considerations – have found that your interests or fundamental rights and freedoms do not outweigh and require the protection of personal data.

 

If your case requires any action to be taken by Adtraction, your data will be stored for 24 months. However, if we believe that we are required to store the data longer than that, we will ask for your consent to your data being stored for a longer period. You have the right to receive information about how long the data may be stored and how to revoke your consent.

 

When you contact us via our support services, the data provided is transferred to and processed by a third party. To read more about how this third party processes your data, you may find their privacy policy here and information on how you may carry out your rights towards this third party. This service has its hosts in the USA, meaning that when you contact us through the support system your data may be stored in servers in the USA, i.e. a third country. Such transfers are supported by the use of the EU Commissions Standard Contractual Clauses. Read more about transfers to third countries below.

 

 

When you send a job application to Adtraction

If you send a job application to us via e-mail, we will process the personal data you provide us with in the application. The data which can be processed is:

• Name
• Address
• Telephone number
• E-mail address
• Personal security number

 

Personal data collected in connection with job applications is generally stored for 24 months. Exceptions are made for personal data collected in spontaneous applications, as such data is stored for a maximum of 12 months.

 

When you apply for a job with us, we handle your personal information for our legitimate interest in handling your application. This means that after careful consideration, we have assessed that your interests or fundamental rights and freedoms do not outweigh and require the protection of your personal data.

 

 

When you contact Adtraction via social media

If you contact us via social media, for example on our Facebook or Instagram page, the personal data will only be processed within the framework of the social media platform and the use of the platform means a possible transfer of your data to the USA (i.e. a third country). We will therefore refer you to email your case to our e-mail address info@adtraction.com. The personal data provided on our social media pages, such as your name, are processed based on your consent. You can revoke your consent at any time by contacting us directly on social media or via info@adtraction.com. Your personal data is only processed for as long as we have your consent.

 

 

When you register for Adtraction’s newsletter

If you sign up for our newsletter, we will process the personal information that is necessary to be able to send it to you. This means that we will process the following data:

• Name
• E-mail address

 

When you register for our newsletter, we will process your personal data by sending out newsletters and/or marketing emails. Your information is processed based on the fact that you have previously given consent to the processing.

 

We store your personal data until you choose to revoke your consent. You have the right to revoke your consent at any time, either by contacting us by e-mail to info@adtraction.com or by unsubscribing according to the instructions in the mailing you have received.

 

 

When you interact with Adtraction’s ads

Adtraction has developed a cookie for tracking Internet traffic and provides a service that allows advertisers to pay commission to publishers that, via clicks on hyperlinks, direct traffic to the advertiser’s website. We use various technologies to collect and store information about views and interactions with ads. This includes cookies, pixel tags, databases and server logs. We do this so that we can provide aggregated reports to advertisers, like telling them whether we served their ad on a page and whether the ad was clicked by a viewer. We also measure conversions, for example a purchase you have made after clicking the link, that occur after interacting with an ad. In order to provide the service, we may process the following data:

• IP address
• Technical data such as browser settings

 

Personal data is processed based on our legitimate interest to provide our service. We have, after careful consideration, assessed that your interests or fundamental rights and freedoms do not override and require the protection of personal data. The data is stored up to 12 months.

 

 

Security measures

Adtraction has taken appropriate technical and organizational measures to protect personal data against unauthorized access, destruction and change as well as ensuring that only personal data which is necessary for each specific processing purpose is processed.

 

 

Transfer of personal data and disclosure of personal data

Adtraction will never rent or sell personal data to third parties and does not divulge your personal data without your prior written consent. However, data may in some cases be transferred in order for us to comply with legal inquiries, when it is required by law or otherwise when it is necessary to detect and prevent criminal activity.

 

A transfer may also be necessary for us to share your personal data with other companies that are subcontractors to us. These subcontractors are called personal data processors. A processor is a company that processes personal data on our behalf and according to our instructions. We have processors who help us with

• IT services: to these services we may transfer your device data and contact information.
• Recruitment services: Your contact information and personal identity number.

 

Moreover, if you have chosen to register for our newsletter, we may transfer your contact information to the supplier of our newsletter.

 

If we share your personal data with our processors, it will only be for the purposes we have specified. We control all processors to ensure that they can provide sufficient guarantees for security and confidentiality regarding personal data. We have also written agreements with all processors where they guarantee the security of the personal data that is being processed, and where they undertake to comply with our security requirements as well as restrictions and requirements that apply to the international transfer of personal data.

 

Transfer of personal data to other countries

If you are located within the EU/EEA

In some cases, we may transfer personal data outside the European Union (“EU”) or European Economic Area (“EEA”), a so-called third country transfer. This could be the case if we use a personal data processor who is established in a third country. As a main rule, publishing on social media also involves such a transfer, mainly transfer of data to the USA. This means that your personal data, for example your photo and name, can be transferred to third countries if you contact Adtraction on social media.

 

We always transfer personal data in accordance with current privacy protection legislation, including the GDPR. In the third country, however, the GDPR does not apply, which may entail an increased risk in terms of privacy with regard to, among other things, the possibility for authorities in the third country to gain access to your personal data and for your opportunities to exercise control over personal data. However, the transfer is necessary for you to be able to contact us on social media.

 

We transfer data to the following third countries:

• USA: We support transferring of data to the USA on the basis of Standard Contractual Clauses (“SCC”) issued by the EU Commission. Find the SCC:s here.
• United Kingdom: Adtraction may transfer data within the company group, meaning that Adtraction’s UK headquarters may access personal data. Adtraction supports transfer of data to the UK on the basis of the EU Commission’s adequacy decision. Find the decision here.

 

 

If you are located within the UK

If you are a UK resident, we may transfer personal data within our company group meaning to entities that are located within the EU/EEA area. According to the Information Commissioner’s office (“ICO”) we may transfer data to this area.

 

As described above, if you interact with us in social media this means a transfer of your data to the USA. We support transferring of data to the USA on the basis of Standard Contractual Clauses (“SCC”) issued by the EU Commission.

 

 

Use of cookies

To give our website visitors the best experience, we use cookies. A cookie is a small data file stored in your browser. Adtraction's usage of cookies is handled within the framework of the GDPR and other applicable legislation. For more information about how we handle cookies, please find further information on our use of cookies below.

 

If you do not want to receive cookies, you can change your settings in your browser. However, this can cause websites to stop working properly. For instructions on how to block cookies, please refer to your browser's help pages.

 

 

Your privacy rights

If Adtraction processes your personal data, you have the following privacy rights in accordance with the GDPR:

 

 

Right to information and access

You have the right to obtain confirmation as to whether or not your personal data is being processed. Furthermore, you have the right to receive a copy of the personal data that we process about you.

 

A request for an extract from the register must be made in writing to info@adtraction.com. Once we receive a request for access, we may ask for additional information to ensure that the information is provided to the right person.

 

Correction of data

If your personal data is inaccurate, you can request to have the data rectified. You can also request the data to be completed if it is incomplete. Such request can be sent to info@adtraction.com.

 

Right to be forgotten

In some cases, you can ask us to delete your personal data in whole or in part. This means that you can, for example, object to a balance of interest assessment we have made or claim that the information is no longer necessary to fulfil the purpose for which it was collected.

 

To the extent that it is necessary for us to continue the processing of your personal data, for example to fulfil our legal obligations, we are not obliged to delete the data. This means that certain data can be stored until we are no longer obliged to process them.

 

Right to restriction of processing

Under some circumstances, you can ask us to stop processing all or some of your personal data or to limit our use of it. A restriction can be made for several reasons.

• In case you dispute that the personal data we process is correct, you can request a limited processing during the time we control whether the personal data is correct.
• In case you demand that we delete your personal data but we cannot meet the request, you may request restriction of processing. This could be because we need the data we have about you in order to establish, assert or defend legal claims. In these cases, you can request limited processing of the data from us.
• In case you have objected to a balance of interest assessment that we have made as a legal basis for processing, you may request limited processing during the time we work to control whether our legitimate interests outweigh your interests in having the data deleted.

 

If the processing has been restricted as described above, we may only store your personal data and process it to establish, assert or defend legal claims or to protect someone else's rights or because you have given your consent.

 

 

Right to object

At any time, you have the right to object to our processing of your personal data based on a balance of interests as a legal basis. A continued processing of your personal data requires that we can show that we have a justified reason for the processing. If we cannot prove a justified reason, we may only process the data to establish, exercise or defend legal claims. You also have the right to object to direct marketing, including profiling.

 

 

Automated individual decision-making

If applicable, you have the right not to be subject to a decision based solely on an automated processing.

 

 

Right to withdraw consent

For processing where your consent forms the legal basis, you have the right to withdraw your consent to our further processing as described in this Privacy Policy. However, if you withdraw your consent, we may no longer be able to provide you with the services you have requested. We may be required to continue to process or store your personal data to fulfil legal and regulatory obligations.

 

 

Data portability

Under some circumstances, you have the right to transfer the data to another controller. This however requires that the processing is based on consent or contract and that it has been carried out by automated means.

 

 

Right to refrain from marketing mailings

At any time, you have the right to refrain from receiving marketing mailings that we send to you via e-mail. To refrain from such mailings, you can either unsubscribe by following the link directly in the mailing or by writing to us at info@adtraction.com.

 

 

Right to complain

You have the right to lodge a complaint with the Swedish Authority for Privacy Protection if you are not satisfied with how we process your personal data.

 

Integritetsskyddsmyndigheten
Box 8114
104 20 Stockholm
imy@imy.se
+46 (0)8 657 61 00

 

 

Amendments to this policy

Adtraction reserves the right to update, change or replace any part of this Privacy Policy at any time in order to keep it compliant with applicable laws such as the GDPR. The latest version can always be found on our website www.adtraction.com.

 

 

Security

Adtraction has taken appropriate technical and organizational measures to protect personal data against unauthorized access, destruction and change as well as ensuring that only personal data which is necessary for each specific processing purpose is processed.

 

 

Cookies

A cookie is a small data file stored in your browser. The cookie contains no personal information and no connection is made between such information and a visitor's identity.

 

Adtraction's usage of cookies is handled within the framework of the GDPR and other applicable legislation.

 

If you do not want to receive cookies, you can change your settings in your browser. However, this can cause websites to stop working properly. How to disable cookies depends on which browser you use. Read the "Help" or equivalent menu in your browser for further instructions.

 

 

Interaction with ads

We use various technologies to collect and store information about views and interactions with ads. This includes cookies, pixel tags, databases and server logs. We do this so that we can provide aggregated reports to advertisers, like telling them whether we served their ad on a page and whether the ad was clicked by a viewer. We also measure conversions (for example, a purchase) that occur after interacting with an ad.

 

 

Web analysis with Google Analytics

Adtraction's website uses Google Analytics, a web analysis service of Google Inc. (Google). Google Analytics uses cookies, i.e. text files stored on your computer to enable analysis of website usage by you. Information generated by the cookie about your use of Adtraction's website is usually transmitted to a Google server in the United States and stored there. In case of activated IP anonymization on Adtraction's website, however, your IP address is previously truncated by Google within member states of the European Union or in other states which are party to the agreement on the European Economic Area. Only in exceptional cases is a full IP address transmitted to a Google server in the United States and truncated there. On behalf of Adtraction, Google will use this information to evaluate your use of the website, compile reports about website activities, and provide the website's operator with further services related to website and Internet usage. The IP address sent from your browser as part of Google Analytics is not merged with other data by Google. You can prevent storage of cookies by appropriately setting your browser software; in this case, however, please note that you might not be able to fully use all functions offered by Adtraction's website. In addition, you can prevent data generated by the cookie and relating to your use of the website (including your IP address) from being collected and processed by Google, by downloading and installing a browser plug-in.

 

Adtraction's website uses Google Analytics with the extension "anonymizeIP()", IP addresses being truncated before further processing in order to rule out direct associations to persons. The legal basis for the use of Google Analytics is Article 6 (1) sentence 1 lit. f GDPR.

 

 

Web analysis with Microsoft

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

 

 

Social plug-ins from Facebook

We use social plug-ins from facebook.com, operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA. The plug-ins can be recognized by way of the Facebook logo or the supplement "Facebook Social Plug-in". For example, if you click on the "Like" button or leave a comment, the relevant information is transmitted directly from your browser to Facebook and stored there. Furthermore, Facebook makes your likes public for your Facebook friends. If you are logged into Facebook, it can assign the invocation of our page directly to your Facebook account. Even if you are not logged in or do not have a Facebook account, your browser sends information (e.g. which web pages you have called up, your IP address) which is then stored by Facebook. For details about handling of your personal data by Facebook and your related rights, please refer to the data privacy policy of Facebook. If you do not want Facebook to map data collected about you via Adtraction's web sites to your Facebook account, you must log out of Facebook before you visit Adtraction's web pages. The legal basis for the use of plug-ins is Article 6 (1) sentence 1 lit. f GDPR.

 

 

Contact information

If you have any questions about Adtraction's handling of personal data, please contact Adtraction at info@adtraction.com.

 

Last updated 2022-11-07