Comex - GDPR
Privacy and marketing policy
Last update: 2021-10-07
1. Generally
At Comex, we want you to feel safe when you provide us with your personal information. In this policy, we explain how we collect, use, disclose and store your personal information, as well as how we otherwise ensure that your personal information is processed in accordance with applicable legislation.
2. Contact details for the data controller
The data controller for the processing of your personal data with us is:
Comex Electronics AB (referred to as Comex in this policy)
Tumstocksvägen 11B, 187 66 Täby
Org. No.: 556314-8153
email: gdpr@comex.se
3. From which sources do we collect information about you as a customer?
To conduct our business, we need to collect personal data about you in various contexts.
Comex collects your personal information directly from you when you place an order, contact us via the website, attend our events, interact with our staff and when you otherwise have contact with Comex and provide information about yourself. Information about you is collected on these occasions so that you can enter into an agreement with Comex and so that we can provide our products and services to you.
In addition to the information that Comex collects from you, we may also collect personal information from someone else, i.e. from third parties. We obtain information from public records via third party address update services, to verify that we have the correct contact information for you. We obtain creditworthiness information from credit rating agencies, information companies or banks. We also obtain information for marketing purposes from social media.
4. What personal data do we process about you?
The personal data Comex collects and processes about you as a customer who makes purchases and uses our services is:
Contact information such as name and identification number (personal identification number, national ID or corporate registration number)
Delivery address, billing address, telephone number and email
Payment details
Order information such as order number, products or services ordered, order date, price and purchase history
Payment information such as payment method, card number, cardholder, transaction time, amount, IP address and payment history
Financial information such as credit reports
Correspondence and other information such as audio recordings of calls, notes and emails when contacting our staff
IP address and information about your use of the Comex website
5. Why do we process data about you?
Comex processes your personal data for various purposes. Mainly, Comex processes your personal data for the following purposes:
Fulfill our obligations to you as a customer, such as completing purchases, invoicing and providing support and service
Enable general customer care and customer service, such as answering questions and correcting incorrect information
Manage the customer relationship and provide our services
Provide you with relevant information and customized offers in newsletters
Improve our customer offering, for example, development of services, products and features
Prevent fraud and perform risk management
Comply with applicable legislation, such as accounting laws
The above information can also form the basis for market and customer analyses, market research, statistics, business follow-up and business and method development related to the purchase of goods and services.
6. What are the legal bases for our processing of your personal data?
Comex bases the processing of your personal data on a number of legal grounds.
a) Contractual obligations
We process your personal data, among other things, to be able to fulfill the agreement with you as a customer, such as to make purchases and to be able to fulfill our commitments to you as a customer, such as simplified administration and order history. With the support of this legal basis, we also process information about you such as your purchases, your behavior on our website, your interaction with Comex and your interest in our offers and products in order to be able to fulfill our commitment to provide you with personalized offers.
b) Balancing of interests
Some of the processing of personal data that we carry out is based on a so-called balancing of interests. This applies, for example, to the processing we carry out in order to be able to send you offers about our goods and services. Comex does not process sensitive personal data based on a balancing of interests and does not carry out any processing that constitutes profiling based on a balancing of interests.
c) Legal obligation
In certain cases, Comex may have a legal obligation to process your personal data. This applies, for example, to the processing of personal data that we carry out in order to comply with the requirements of the Accounting Act.
7. Summary of our personal data processing
|
Purpose |
Legal basis |
Categories of personal data |
|
To administer, develop and deliver our goods and services and provide support |
Contractual obligation |
|
|
To ensure compliance with legal requirements, such as the Accounting Act |
Legal obligation |
|
|
To market Comex goods and services through mail, email, telephone |
Balancing interests |
|
8. How long do we store data about you?
Your personal data will only be stored for as long as there is a need to store it to fulfill the purposes for which the data was collected in accordance with this Privacy Policy. Comex may store the data for longer if necessary to comply with legal requirements or to safeguard Comex's legal interests, e.g. if legal proceedings are ongoing. Comex stores customer data for a maximum of five years after the customer last made a purchase or otherwise integrated with Comex.
9. Who do we disclose personal data to?
Comex may disclose your information to third parties, such as Comex subcontractors or distributors of products.
Third parties to whom Comex discloses information or otherwise provides information about a customer may only use the information for the purpose of selling and marketing Comex's services and products or for the purpose of delivering services related to Comex's agreement with you as a customer. If you have chosen to take out insurance with us, personal information may also be disclosed to insurance companies. If you apply for credit when purchasing a product or service, your information may be disclosed to credit reporting agencies.
Personal data may also be disclosed by Comex if it is necessary to comply with applicable legal requirements or requirements from authorities, to safeguard Comex's legal interests or to detect, prevent or alert to fraud and other security or technical problems.
10. Privacy Policy Change
Comex has the right to change the Privacy Policy at any time. The most recently updated version of Comex's Privacy Policy is always available on our website. Our Privacy Policy applies at all times in the form and to the content published on the website.
11. The protection of your personal data
You should always feel safe when you provide us with your personal data. Comex has therefore taken the necessary security measures and procedures to protect and manage your personal data. This is achieved through several different security features such as intrusion detection, encryption, intrusion protection, protection against malware and security logging, which give our IT systems that store personal data a security capability that meets the requirements of the General Data Protection Regulation (GDPR).
12. Your rights
Comex will, at your request or on its own initiative, correct, de-identify, delete or supplement information that is found to be incorrect, incomplete or misleading.
You have the right to request:
a) Access to your personal data. This means that you have the right to request a register extract of the processing that we carry out regarding your personal data. You also have the right to receive a copy of the personal data that is processed. You have the right to receive, once per calendar year, by means of a written signed application, a register extract free of charge from which personal data is registered about you, the purposes of the processing and to which recipients the data has been provided or will be provided. Please note that when requesting access, we may ask for additional information about you to ensure that we provide the data to the right person and what information you want to see.
b) Correction of your personal data. At your request, we will correct any incorrect or incomplete data we process about you as quickly as possible.
c) Deletion of your personal data. This means that you have the right to request that your personal data be deleted if it is no longer necessary for the purpose for which it was collected. However, there may be legal requirements that we are not allowed to immediately delete your personal data in, for example, accounting and tax legislation. We will then terminate the processing that is carried out for purposes other than complying with the legislation.
d) Restriction of processing. This means that your personal data is marked so that it may only be processed for certain limited purposes. You can, among other things, request restriction when you believe that your data is incorrect and you have requested correction in accordance with point 12 c). While the accuracy of the data is being investigated, its processing will be restricted.
You have the right to data portability. This means the right to receive and transfer your personal data in a structured, commonly used and machine-readable format to another data controller, under certain conditions.
You have the right to object to personal data processing carried out on the basis of a balancing of interests. If you object to such processing, we will only continue the processing if there are legitimate reasons for the processing that outweigh your interests.
If you do not want your personal data to be processed for direct marketing purposes, you always have the right to object to such processing by sending an email to gdpr@comex.se . Once we have received your objection, we will cease processing the personal data for such marketing purposes.
13. Cookies
When you visit our website we use cookies, you can find more information about how we process cookies in our cookie policy on the website.