With this Data Protection Statement, we, PrimaMateria AB (559273-1433) describe how we collect and further process personal data. This Data Protection Statement is not necessarily a comprehensive description of our data processing. It is possible that other data protection statements are applicable to specific circumstances, in which case you will receive such statements when relevant.
PrimaMateria AB is the controller of the data processing described in this Data Protection Statement. However, if you are interacting with any of PrimaMateria AB’s subsidiaries (set-up as an investment vehicle), the subsidiary you are interacting with will be the controller for the processing of personal data, in accordance with what is set out herein. Whenever this Data Protection Statement refers to PrimaMateria AB, this should also be understood as a reference to the relevant subsidiary which you interact with, as applicable.
The term "personal data" in this Data Protection Statement shall mean any information that identifies or could reasonably be used to identify any person.
If you provide us with personal data of other persons (such as family members, work colleagues), please make sure the respective persons are aware of this Data Protection Statement and only provide us with their data if you are allowed to do so and such personal data is correct.
We primarily process personal data that we obtain from our business partners and companies in which we have invested in as well as other individuals in the context of our business or investment relationships with them or that we collect from users when operating our websites, apps and other applications.
Insofar as it is permitted to us, we obtain certain personal data from publicly accessible sources (e.g., debt registers, land registries, commercial registers, beneficial owner registers, press, internet) or we may receive such information from affiliated companies of PrimaMateria AB, from authorities or other third parties (such as e.g., business partners, providers of background checks, courts, service providers, etc.).
Apart from data you provided to us directly, the categories of data we receive about you from third parties include, but are not limited to, information from public registers, data received in connection with administrative or court proceedings, information in connection with your professional role and activities (e.g., in order to conclude and carry out contracts with your employer), information about you in correspondence and discussions with third parties, credit rating information (if we conduct business activities with you personally), information about you given to us by individuals associated with you (family, consultants, legal representatives, etc.) in order to conclude or process contracts with you or with your involvement (e.g. references, your delivery-address, powers of attorney), information regarding legal regulations such as anti-money laundering and export restrictions, bank details, information regarding insurances, our distributors and other business partners for the purpose of ordering or delivering services to you or by you (e.g., payments made), information about you found in the media or internet (insofar as indicated in the specific case, e.g. in connection with media reviews, marketing/sales, etc.), your address and any interests and other socio-demographic data (for marketing purposes), data in connection with your use of our websites (e.g., IP address, MAC address of your 1 smartphone or computers, information regarding your device and settings, cookies, date and time of your visit, sites and content retrieved, applications used, referring website, localization data).
In the context of our business relationship, you must provide us with any personal data that is necessary for the conclusion and performance of a business relationship and the performance of our contractual obligations. As a rule, there is no statutory requirement to provide us with data. Without this information, we will usually not be able to enter into or carry out a contract with you (or the entity or person you represent). In addition, the website cannot be used unless certain information is disclosed to enable data traffic (e.g. IP address).
We primarily use collected data in order to conclude and process contracts with our business partners when investing, in particular in connection with retrieving data and information about potential investments and also in connection with negotiating and executing investment agreements and similar documentation. in order to comply with our domestic and foreign legal obligations. You may be affected by our data processing in your capacity as an employee of such business partner or investment party.
In addition, in line with applicable law and where appropriate, we may process your personal data for the following purposes:
We may use Google Analytics or similar services on our website. These are services provided by third parties, which may be located in any country worldwide (in the case of Google Analytics Google LLC is in the U.S., www.google.com) and which allow us to measure and evaluate the use of our website (on an anonymized basis). For this purpose, permanent cookies are used, which are set by the service provider. The service provider does not receive (and does not retain) any personal data from us, but the service provider may track your use of the website, combine this information with data from other websites you have visited and which are also tracked by the respective service provider and may use this information for its own purposes (e.g. to controlling of advertisements). If you have registered with the service provider, the service provider will also know your identity. In this case, the processing of your personal data by the service provider will be conducted in accordance with its data protection regulations. The service provider only provides us with data on the use of the respective website (but not any personal information of you).
In the context of our business activities and in line with the purposes of the data processing set out in Section 3, we may transfer data to third parties, insofar as such a transfer is permitted and we deem it appropriate, in order for them to process data for us or, as the case may be, their own purposes. In particular, the following categories of recipients (together “Recipients”) may be concerned:
We process and retain your personal data as long as required for the performance of our contractual obligation and compliance with legal obligations or other purposes pursued with the processing, i.e. for the duration of the entire business relationship (from the initiation, during the performance of the contract until it is terminated) as well as beyond this duration in accordance with legal retention and documentation obligations. Personal data may be retained for the period during which claims can be asserted against our company (which is generally ten years) or insofar as we are otherwise legally obliged to do so. As soon as your personal data are no longer required for the above-mentioned purposes, they will be deleted or anonymized. In general, shorter retention periods of no more than twelve months apply for operational data (e.g., system logs).
You have a number of rights under the GDPR which you may exercise. Once we confirm your identity as the authorized data subject, you have the right in certain circumstances to:
You may exercise your rights by contacting us on the below contact details. No access fee will be charged in cases you want to access your personal data or make one of the requests set out above. Where the request is manifestly unfounded or excessive, we may refuse to fulfil your request.
If you have any questions or concerns about our privacy practices, how we handle your personal data or to file a complaint please contact us at:
Mailing address: PrimaMateria AB, Berga Allé 3, 254 52 Helsingborg, Sweden
You have the right to lodge a complaint with a supervisory authority. Please contact in such case Integritetsskyddsmyndigheten, Box 8114, 104 20 Stockholm, or by e-mail email@example.com.