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Privacy policy

When you subscribe to company news, ABG Sundal Collier (“ABGSC”) may process personal data about you. Below is an explanation of which personal data ABGSC processes and how ABGSC uses your personal data.

ABGSC is responsible for your personal data as Data Controller according to applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”). 

The statements herein will be supported by internal Policies outlining further details on implemented measures and internal procedures.


Privacy, Confidentiality and Security

At ABGSC personal data shall be processed in accordance with applicable legislation and the reasonable expectations of the natural persons the personal data is related to (“Data Subjects”). ABGSC is committed to maintaining the confidentiality, integrity and security of personal information. ABGSC understand ABGSC’s obligation to keep information about you both confidential and secure at all times. ABGSC maintain procedures for the collecting, using, securing, and sharing of personal and/or non-public information.

All ABGSC staff are bound by statutory duty of confidentiality and you can be assured that ABGSC will protect your privacy.


How, why and what kind of personal information ABGSC collect

ABGSC collects the minimum amount of data necessary, limited to personal information required to facilitate and enable the use of services such as the website so that you can access information, register for subscriptions and for the marketing of ABGSC’s services, such as cookies, user information or other information that you may register yourself via the website.

Collection and processing of personal data for subscriptions to company news

ABGSC will process personal data about you when you subscribe to company news. ABGSC’s processing of personal data is necessary for ABGSC to be able to provide the selected subscription to you as a subscriber. The purpose of the personal data processing is to be able to provide the selected subscription and thereby distribute current market news. The personal data processing for subscriptions pertains to information about:

  • E-mail

Other processing of personal data

When you use ABGSC’s website for Commissioned Research and subscribe to company news, ABGSC may process personal data about you for analytical purposes. The processing of personal data is necessary for ABGSC to analyze website data in order to improve the website and its content. The personal data processing for analytical purposes pertains to cookies for statistics.

How you can exercise your rights related to your personal data

Your rights related to your personal data are protected and clarified by the GDPR. When the data subject exercises any of their rights, the data controller must ensure that they are in contact with the correct person. When there are reasonable grounds to doubt the identity of the data subject, the data controller may have the right to request additional information to confirm the identity. Below, your rights, as a data subject, are described in more detail.

Right of Access (Data Subject Access Request)

You may ask ABGSC to confirm what information ABGSC hold about you at any time, and request ABGSC to modify, update or delete such information. If ABGSC provide you with access to the information ABGSC hold about you, ABGSC will not charge you unless your request is manifestly unfounded or excessive. If you request further copies of this information from ABGSC, ABGSC may charge you a reasonable administrative cost where legally permissible. Where ABGSC are legally permitted to do so, ABGSC may refuse your request. If ABGSC refuse your request, ABGSC will always provide you with the reasons for the refusal.

Right to restrict processing

You have the right to request that ABGSC restrict ABGSC’s processing of your personal data in the following circumstances:

  • where you dispute the accuracy of the personal data that ABGSC are processing about you. In this case, ABGSC’s processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
  • where you object to ABGSC processing of your personal data for ABGSC legitimate interests. You can request that the data be restricted while ABGSC verify ABGSC’s grounds for processing your personal data;
  • where ABGSC processing of your data is unlawful, but you would prefer ABGSC to restrict ABGSAC’s processing of it rather than erasing it; and
  • where ABGSC have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.

This means that ABGSC can only continue to store your data and will not be able to carry out any further processing activities until either: one of the circumstances listed above is resolved, you consent, or further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.

If ABGSC have shared your personal data with third parties, ABGSC will notify them about the restricted processing unless this is impossible or involves disproportionate effort. ABGSC will notify you before lifting any restriction on processing your personal data.

Right to rectification

You also have the right to request that ABGSC rectify any inaccurate or incomplete personal data that ABGSC hold about you. If ABGSC have shared this personal data with third parties, ABGSC will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, ABGSC will also tell you which third parties ABGSC have disclosed the inaccurate or incomplete personal data to. Where ABGSC think that it is reasonable for ABGSC not to comply with your request, ABGSC will explain ABGSC’s reasons for this decision.

Right to data portability

You have the right to transfer your personal data between data controllers. This means that you are able to transfer your ABGSC account details to another data controller. To allow you to do so, ABGSC will provide you with your data in a commonly used machine-readable format that is password-protected so that you can transfer the data to another data controller. Alternatively, ABGSC may directly transfer the data for you.

Right to erasure (“Right to be forgotten”)

You have the right to request that ABGSC erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:

  • the data are no longer necessary for the purpose for which ABGSC originally collected and/or processed them;
  • where previously given, you have withdrawn your consent to ABGSC processing your data, and there is no other valid reason for ABGSC to continue processing;
  • the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
  • it is necessary for the data to be erased in order for ABGSC to comply with ABGSC AB’s legal obligations as a data controller; or
  • if ABGSC process the data because ABGSC believe it necessary to do so for ABGSC’s legitimate interests, you object to the processing and ABGSC are unable to demonstrate overriding legitimate grounds for ABGSC continued processing.

When complying with a valid request for the erasure of data ABGSC will take all reasonably practicable steps to delete the relevant data, however ABGSC are entitled to refuse to comply with your request for one of the following reasons:

  • to exercise the right of freedom of expression and information;
  • to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
  • for archival, research or statistical purposes; or
  • to exercise or defend a legal claim.

Right to object

You have the right to object to ABGSC’S processing your personal data where ABGSC do so for one of the following four reasons: (i) ABGSC’s legitimate interests; (ii) to enable ABGSC to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research or statistical purposes.

The “legitimate interests” and “direct marketing” categories above are the ones most likely to apply. If your objection relates to ABGSC processing your personal data because ABGSC deem it necessary for your legitimate interests, ABGSC must act on your objection by ceasing the activity in question unless:

  • ABGSC can show that ABGSC have compelling legitimate grounds for processing which overrides your interests; or
  • ABGSC are processing your data for the establishment, exercise or defence of a legal claim.

If your objection relates to direct marketing, ABGSC must act on your objection by ceasing this activity.

Right to complaint to a supervisory authority

You also have the right to file a complaint with the competent Data Protection Authority.


ABGSC’s legal basis för processing your personal data

Consent  

In certain circumstances, ABGSC are required to obtain your consent to the processing of your personal in connection with your subscription to company news. Article 4(11) of the GDPR states that consent 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". Where ABGSC have obtained your consent to process your personal data for certain activities, you may withdraw this consent at any time. ABGSC will cease to carry out the particular activity that you previously consented to, unless ABGSC consider that there is an alternative reason to justify our continued processing of your data for this purpose. In that case ABGSC will inform you of this condition.

Legitimate interests

When you use ABGSC’s website for Commissioned Research and subscribe to company news, ABGSC may process personal data about you for analytical purposes. The personal data processing for analytical purposes pertains to cookies for statistics. For this type of processing, the legal basis legitimate interest is used. This legal basis can be used when processing is necessary for the purposes of the legitimate interests pursued by the controller 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. The processing of personal data is necessary for ABGSC to analyze website data in order to improve the website and its content.

How ABGSC uses your data

ABGSC processes personal data as described above as a result of your use of the website and when you subscribe to company news. Once ABGSC has received your data, ABGSC will only process the personal data in the manner outlined in this policy.


How ABGSC stores and protects your personal data

ABGSC agrees to keep your information confidential and to adhere to this privacy policy. ABGSC commits to taking all reasonable and appropriate measures to protect your data from misuse, loss, or unauthorized access, and ABGSC maintains policies and technologies designed for this purpose.


The duration ABGSC retains your personal data

ABGSC will not retain your personal data longer than necessary to fulfill the purpose for which the personal data was collected. The exact duration of this period depends on the purpose for which the data was collected. ABGSC will delete or fully anonymize your data from its systems when ABGSC no longer has a legitimate purpose to retain it or at the end of the statutory retention period.


How ABGSC shares information about you

ABGSC may need to share your personal data with third parties, other companies within the ABG Sundal Collier Group, or other providers working on behalf of ABGSC. These third parties are carefully selected and are required to comply with applicable data protection legislation.

Personal data may also be disclosed if required by law, regulation, or a decision by a public authority.


Contact

To get in touch about your rights in respect of ABGSC’s data, please contact ABGSC at dataprotection@abgsc.com. ABGSC will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which ABGSC are lawfully entitled). Please note that ABGSC may keep a record of your communications to help ABGSC resolve any issues which you raise.

It is important that the personal information ABGSC hold about you is accurate and current. Please keep ABGSC informed if your personal information changes during the period for which ABGSC hold your data.