PRIVACY POLICY

At Holy Spirits AB (hereinafter referred to as Holy Spirits), we do our utmost to deliver high quality and service not only on our products but also for you as a customer. Your personal data belongs to you and taking good care of the personal data you share with us is of utmost importance to us at Holy Spirits. We want you to feel confident that your data is safe with us and that you understand how we use it to offer you a better experience.

 

CONTENT OF THE PRIVACY POLICY

Holy Spirits AB (org. nr. 559479-4033. Salongsgatan 15, 211 16 Malmö, Sweden. 0709-58 82 71. E-mail: dpo@holyspirits.se) (in this Policy “we” or “us”), is the data controller for the processing of the personal data we collect from you and it is to us that you turn for questions and to exercise your rights. Holy Spirits carries out all processing of personal data in accordance with applicable law. We care about your privacy and want to be transparent about how your personal data is processed.

We therefore ask you to take the time to read our Privacy Policy. This covers, among other things the following:

• What types of personal data we collect and for what purposes.
• When and how we may share personal data with other partners.
• How long we keep your personal data and for what purposes.
• Your rights, including how to access and update your personal data.

We have tried to make this Policy as simple as possible, but in case you are unfamiliar with terms such as controller or special categories of personal data, you can start by reading more about these and other terms under Key Terms.

 

KEY CONCEPTS

Personal data: Personal data is any information that can be directly or indirectly attributed to a living natural person, such as name, social security number, order number and IP number, if they can be linked to natural persons.

Controller: The controller is the actor who alone or jointly with others determines the purposes and means of the processing of personal data.

European Economic Area (EEA): EU Member States plus Norway, Iceland and Lichtenstein.

Online advertising: marketing messages that you can see on the internet.

Special categories of personal data: These are categories of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

PERSONAL DATA WE COLLECT AND FOR WHAT PURPOSE

When you sign up for our newsletter

In order for us to provide you with the newsletter, we collect the following personal data.

• E-mail address

When you use My Account

In order for us, and you, to administer your account under My Account on holyspirits.se, we collect the following personal data.

• Name
• E-mail address
• Company name and license numbers
• Mobile phone number
• Postal address
• And any optional information

When you search on our website

In order for us to improve your user experience and provide you with personalized services, we may collect the following personal data.

• Product preferences based on the filtering in how you search.
• Information about your browsing habits on our website.
• Information about when you click on one of our advertisements, including those displayed on other partners’ websites such as Social Media.
• Information on how you access our digital services, including operating system, IP address, network identifier and website details.
• Your social preferences, such as interests and activities.

When you buy our products in store through our retail partners or online

In order to provide you with our products, we collect the following data. When you buy our products through our agents in physical stores, no personal data is collected by us. When you buy our products in our online store, the personal data below is collected.

• First and last name
• Postal address
• E-mail address
• Mobile phone number
• Company name
• Information about your purchase, including what you bought, when you bought it, how you paid and how it was delivered or where it was collected.
• Information about your browsing habits on our website.
• Information that you click on one of our advertisements, including those that appear on other organizations’ websites.
• Information on how you access our digital services, including operating system, IP address, network identifier and website details.
• Social preferences, interests and activities.

 

When you contact us or when we contact you or when you participate in promotions, competitions, surveys or other questionnaires about our services

In order for us to be able to contact you, respond to your requests and administer competitions, promotions, etc. we process the following personal data.

• The personal data you provide when you contact us e.g. by email, letter, phone or social media. In the first instance, we collect the information we need to contact you, such as your name and email address.
• Details of emails and other digital communications we send to you that you open, including links in them that you click on.
• Your feedback and contributions to customer surveys and questionnaires.
• In case you have been informed about it before the call, we may record phone calls for training purposes when you contact us.

 

Other sources of personal data

We may use personal data from other sources, such as specialist information providers and retail partners if it is necessary for us to administer a service you have requested.

Personal data you provide about other individuals

– When another person uses your personal data to make a purchase or to contact us about a matter involving you, we use the personal data that person provides about you.

– When you provide personal data about other people, you must be sure that they consent to it and that you have permission to provide it. Where appropriate, you should also ensure that they understand how their personal data may be used by us. Further information on the purposes for which we process your personal data can be found below under the heading “Use of your personal data”.

 

THE USE OF YOUR PERSONAL DATA

In addition to what has already been set out under the heading “Personal data we collect and for what purpose” above, we use your personal data for the purposes described below. Please note that if you do not provide us with certain personal data, it may prevent us from providing you with products and services that you request or prevent us from entering into a contract with you in respect of such products or services.

 

To provide products and services at your request

We need to process your personal data to manage your account or order, provide you with the products or services you wish to purchase and assist you with any other orders or repurchases you request.

To manage and improve our products, services and daily operations

We use personal data to manage and improve our products, websites, customer loyalty programs and other services.We monitor the use of our services to protect your personal data, detect and prevent fraud, other crimes and misuse of services. We may use personal data to carry out market research, internal surveys and development and to develop and improve our product range, services, agent stores, IT systems, security, know-how and the way we communicate with you.

To connect and interact with you

We always want to improve our service to you. When you contact us, for example by email, letter, and telephone or via social media, we may therefore use personal data to help you with clarification or assistance.We need to process your personal data in order to manage promotions and competitions you choose to participate in, including those we run with our suppliers and agent partners. We may invite you to participate in customer surveys, questionnaires and other market research activities organized by us or by other partners on our behalf.

To provide marketing and personalized advertising to you

We use your personal data to provide marketing and offers to you and, based on the personal data you provide, to personalize marketing through profiling so that you receive offers that are relevant to you. You can read more about how we use your data for marketing and your rights below in the “Marketing Communications” section.

 

MARKETING COMMUNICATION

We want to ensure that all marketing communications related to our products and services from our suppliers, retail partners, including online advertising, are relevant to your interests. To do this, we may use your personal data by analyzing your previous purchases, browsing habits and search preferences when using our website. We may therefore use profiling to identify which products, services and information you may be most interested in. This allows us to tailor our communications to make them more relevant and interesting to you. You can read more about how we collect information through your browser in our cookie policy.

We would like to send you relevant offers and news about our products and services. We may therefore contact you with marketing communications via email, letterbox advertising and telephone. We may also send you information about partners’ products and services that we think may be of interest to you. We will only do this if you have previously agreed to receive such marketing communications. If you do not wish to receive marketing from us, you can opt out at any time by using the unsubscribe link provided in all offers we send to you by email or by contacting us via the contact details at the bottom of this policy. Of course, the choice is yours, but if you indicate that you do not wish to receive marketing information from us, this will prevent you from receiving great offers and promotions that may be of interest to you. You may still receive order-related information linked to your order with us, even after you have received delivery of the order. For example, in the event of a manufacturer recall or other unforeseen events related to your order that are important to communicate.

 

MARKET RESEARCH

To improve our products and services, we would like to hear your views. We may therefore contact you for market research purposes. You always have the option to choose whether or not to participate, or continue to participate, in our market research.We may take into account your responses to market research relating to products and services we offer, in order to offer you products and services that better meet your needs as a customer.

 

SHARE PERSONAL DATA WITH SUPPLIERS AND PARTNERS

In order to provide the products and services you have purchased, we may need to share your personal data with our subcontractors and partners. These include, among others transportation companies and IT providers. We only share personal data with these subcontractors and partners to the extent necessary for our suppliers and partners to provide their services to you and us, and they will only have access to the personal data that is necessary.

In the event that we transfer personal data to a supplier who is our processor, we always enter into the necessary agreements to ensure that we retain control over the personal data and that it is handled lawfully with the utmost security by our processor.

In order to develop our business and provide you with better-targeted information, services and offers, we use partners who work on information compilation, market analysis, market research and marketing. In order to do this, we share certain personal data with these partners.

In order to provide the installment service to you, we cooperate with Payson AB. If you use the service, we will share personal data with Payson AB. For information on how Payson AB processes personal data, please see information from Payson AB.

In order to administer our activities, we use various IT services and systems. Some of these systems store and process personal data. For the systems installed locally by us, the data is only processed by our staff. For the services installed at our supplier, or which consist of a cloud service, we transfer personal data to them. We do not sell your personal data to third parties. Personal data is securely stored at all times and all data communication is encrypted.

 

PROTECTION OF YOUR PERSONAL DATA AND DATA PROTECTION OFFICER

We recognize the importance of protecting and managing your personal data. We take appropriate security measures to protect your personal data against loss or unauthorized access, use, modification or disclosure. We are continuously working on “data protection by design and data protection by default”. We would also like to remind you that the security of your personal data may also depend on you. For example, when we have given you the choice, or when you have chosen a password to access certain services, then it is your responsibility to keep this password secret.

We continuously train our staff in data protection issues and our employees also have strict instructions to handle all personal data in accordance with current personal data legislation. Within Holy Spirits AB, we have a data protection officer who has overall responsibility for personal data management within the company. If you want to get in touch with our data protection officer, you can contact him at dpo@holyspirits.se.

 

TRANSFER TO A COUNTRY OUTSIDE THE EEA AREA

The personal data we collect from you may be transferred to or stored at a destination outside the European Economic Area (“EEA”). It may also be processed by organizations operating outside the EEA who work with us or for one of our suppliers. If this happens, we will ensure that your personal data is adequately protected and processed in accordance with this Policy. This protection includes, but is not limited to, appropriate contractual clauses such as standard contractual clauses approved by the European Commission and other appropriate safeguards. We may also carry out impact assessments to ensure that security has been carefully considered.

 

STORAGE OF PERSONAL DATA

We will only retain your personal data for as long as it is necessary for the purposes set out in this Policy and we will also comply with good industry practice, recommendations and guidelines. The personal data will only be used for the purposes set out in this Privacy Policy and/or to fulfill legal and administrative obligations. Thereafter, we will securely delete your personal data. However, the same personal data may be stored in several different places for different purposes. This means that we may delete data from one system when it is no longer needed there, while the data may continue to be stored in another system if the purpose remains for that particular system. If data is needed after this period for analytical, historical or other legitimate commercial purposes, we will take appropriate steps to anonymize that data so that it no longer constitutes personal data.

The personal data we collect when placing an order is stored in our customer and order database for up to three years for orders placed without a registered account, so-called guest orders. This is so that we can fulfill warranty requirements and other legal requirements that exist for distance selling. For orders placed with a registered user account, the data and order history are saved for a longer period of time, so that we can provide your order history and a good experience.

In the event of a complaint, personal data may be stored for ten years to enable us to defend ourselves against legal claims.

If you have registered to receive our newsletter, we will process the data needed to administer this as long as you do not unsubscribe from the newsletter or notify us that you no longer wish to receive it, or otherwise for three years from the time you have placed an order. You can unsubscribe from receiving the newsletter at any time.

The data in “My Account” will be stored as long as you have an active user profile there.

If you are a previous customer of ours, we will retain the personal data we need to continue to contact you with marketing communications for as long as you have an active customer relationship with us. We consider you to have an active customer relationship with us if you have purchased products and services from us in the last three years and have not otherwise unsubscribed from receiving marketing communications from us. You can unsubscribe from receiving marketing communications from us at any time.

In case your phone call to us is recorded, we will keep this phone call for 30 days. By law, we are obliged to record and keep certain data that constitute accounting information. We must therefore keep this data for around seven years.

 

COOKIES AND SIMILAR TECHNOLOGIES

Cookies are small data files that allow a website to collect and store a wide range of data on your desktop, laptop or mobile device. Cookies help us to provide essential features and functionality on our websites and mobile apps, and we use them to improve your customer experience. Please see our separate cookie policy.

 

LINKS TO OTHER WEBSITES

Our websites or mobile apps may contain links to websites operated by other organizations that have their own privacy policies. Please make sure you read the terms and conditions and privacy policy carefully before providing personal data on another organization’s website as we do not accept any responsibility for other organizations’ websites.

 

SOCIAL MEDIA

Our websites or mobile apps may include features linked to social media such as Facebook, Instagram, LinkedIn, Pinterest, TikTok, YouTube which have their own privacy policies. Please make sure to carefully read their terms and conditions and privacy policies before submitting personal data as we do not accept any responsibility for these features.

 

YOUR RIGHTS AND CONTACT DETAILS

Right to withdraw consent

Where processing is based on your consent, you have the right to withdraw it at any time by contacting us.

Right of access

You have the right to receive a copy of the personal data we hold about you. You can write to us and ask for a copy of other personal data we hold about you.

Please include information that can help us identify and locate your personal data. Access to your data will be provided free of charge. However, if you request additional copies, we may charge a reasonable administration fee.

 

Right to rectification, erasure, restriction and right to object to processing

We want to ensure that the personal data we hold about you is accurate and up to date. If any information we hold is incorrect, please inform us. You can request to have your personal data rectified at any time. You have the right to have your personal data erased, inter alia if it is no longer needed for the purpose, or if the processing is based on your consent and you withdraw it. You also have the right to request the restriction of the processing of your personal data under certain conditions and to object at any time to the processing of your personal data if the legal basis for the processing is a public interest or a balance of interests and when your personal data is processed to send you direct marketing. We will update and delete your data, except where we are entitled to continue processing it for legitimate purposes.

 

Right to data portability

If it is technically feasible and the legal basis for the processing of your personal data is consent or that the processing has been necessary for the performance of a contract, you have the right, under certain conditions, to obtain this personal data and the right to transmit it to another controller.

 

Contact and complaints

You can also contact us if you have a complaint about how we collect, store and use your personal data. We will endeavor to resolve any complaints but if you are unhappy with our response, you can take your complaint to your local supervisory authority at http://www.datainspektionen.se/.

Please submit your claims or complaints in writing to our legal department or the Data Protection Officer:

Address: Holy Spirits AB, Attn: DPO, Salongsgatan 15, 211 16 Malmö.
E-mail: dpo@holyspirits.se

Please note that we may ask you to confirm your identity before we deal with your claim or complaint. We may also ask you for more information to ensure that you are authorized to make claims or complaints when you contact us on behalf of someone else.

 

LEGAL BASIS FOR PROCESSING PERSONAL DATA

We will only collect and use your personal data if at least one of the following criteria is met:

– We have your consent;

Example: Newsletter

You give us permission to process your personal data in connection with the sending of newsletters.

Example: Contact with customer service

If you contact customer services, your personal data will be processed in order to handle your request.

Please note that where the legal basis for the processing of personal data is your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of the processing carried out before the withdrawal of consent. However, in case you withdraw your consent, it may mean that we can no longer provide a certain service to you. – This is necessary on the basis of a contract with you or to take action at your request before entering into a contract;

Example: To provide products or services that you want

We need to process your personal data to manage your account or order, provide you with products or services that you wish to purchase or assist you with orders or returns that you request.

– It is necessary for us to comply with legal obligations;

Example: Sharing personal data with authorities

In the event that authorities require personal data to be shared, we will decide after investigation whether the personal data should or should not be shared with the authority on a case-by-case basis.

– It is in our legitimate interest or in the legitimate interest of a third party and it does not infringe your interests or rights.

Example: To better adapt our offers to you

We may use your personal data to better understand your interests and try to anticipate what other products, services and information you might be most interested in. This allows us to tailor our communications to make them more relevant and interesting to you.

Where we need to process special categories of personal data, such as health data for medical reasons, we will only do so if one or more of the following additional conditions apply. For example, we have your explicit consent; it is necessary to protect your vital interests or those of another individual and/or you are mentally and legally incapable of giving consent; it is necessary for the establishment, exercise or defense of our legal rights; or it is necessary for an important public interest.

 

CHANGES TO OUR POLICY

This Policy replaces all previous versions. We may change the Policy at any time and we therefore ask you to check our website regularly for updates. In the event of significant changes, we will clearly communicate this on our website, including, if we deem it appropriate, by sending you an electronic notice of the changes to the Privacy Policy.

Last updated: August 2024