Data Protection Statement of PrimaMateria AB

Version effective as of 1st of January 2022

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.

1. Collection and Processing of Personal Data 

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).

2. Purpose of Data Processing and Legal Grounds

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.

  • providing and developing our products, services and websites, apps and other platforms, on which we are active, where our legal ground is that the processing is necessary to satisfy our legitimate interest in continuously developing our products, services, websites etc.;
  • communication with third parties and processing of their requests (e.g. media inquiries, lawyers, advisers and banks), where our legal ground is that the processing is necessary to satisfy the legitimate interests of such third parties;
  • market and opinion research, media surveillance, where our legal ground is that the processing is necessary to satisfy our legitimate interest in being able to understand the market and develop our business;
  • asserting legal claims and defense in legal disputes and official proceedings, where our legal ground is that the processing is necessary to satisfy out legitimate interest in being able to handle such claim;
  • prevention and investigation of criminal offences and other misconduct (e.g. conducting internal investigations, data analysis to combat fraud as well as arranging for background checks and screening activities in relation to parties to enter into a contractual relationship), where our legal ground is that the processing is necessary to satisfy out legitimate interest in being able to investigate whether a legal claim should be established or exercised;
  • ensuring our operation, including our IT, our websites, apps and other appliances, where our legal ground is that the processing is necessary to satisfy our legitimate interest in ensuring a secure and available operation;
  • acquisition and sale of business divisions, companies or parts of companies and other corporate transactions and the transfer of personal data related thereto as well as measures for business management and compliance with legal and regulatory obligations as well as internal regulations of PrimaMateria AB, where the legal ground is that the processing is necessary to satisfy out legitimate interest in being able to carry out corporate transactions and other corporate governance activities.

In addition, in line with applicable law and where appropriate, we may process your personal data for  the following purposes:

3. Cookies / Tracking and Other Techniques Regarding the Use of our Website

We typically use “cookies” and similar techniques on our websites, which allow for an identification of  your browser or device. A cookie is a small text file that is sent to your computer and automatically  saved by the web browser on your computer or mobile device, when you visit our website. If you revisit  our website, we may recognize you, even if we do not know your identity. Besides cookies that are only  used during a session and deleted after your visit of the website (“session cookies”), we may use  cookies in order to save user configurations and other information for a certain time period (e.g., two  years) (“permanent cookies”). Notwithstanding the foregoing, you may configure your browser settings  in a way that it rejects cookies, only saves them for one session or deletes them prematurely. Most  browsers are preset to accept cookies. We use permanent cookies in order to understand how you use  our services and content. If you block cookies, it is possible that certain functions (such as, e.g.,  language settings, shopping basket, ordering processes) are no longer available to you.

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., 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).

4. Datatransfer and Transfer of Data Abroad

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:

  • our service providers (such as e.g. banks, insurances companies, consultants, law firms and accounting/audit companies, registered agents) that act as sole controllers,;
  • suppliers, subcontractors (such as foreign and domestic lawyers and law firms or experts) and other business partners that act as sole controllers;
  • domestic and foreign authorities or courts and other parties in possible or pending legal  proceedings, for the purposes of establishing, exercising or defending a legal claim;  • the media, as part of our media communication;
  • social media platforms, within the scope of our marketing activities; and
  • affiliates of PrimaMateria AB.

5. Retention Periods for your Personal Data

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).

6. Your Rights

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:

  1. Request access: you may access and obtain a copy of the personal data we keep in order to confirm that we are lawfully processing it, including further information about the processing of your personal data.
  2. Request correction: you can request that we amend any incorrect or incomplete information.
  3. Request erasure: you may ask for deletion or removal of your personal data where there is no justifiable reason for us to continue processing it. Please note however that if PrimaMateria AB has justified purposes for further processing of your personal data, we may reject an erasure request.
  4. Object to processing: you may object to the processing of your personal data for our marketing purposes or where the legal ground is our (or a third party’s) legitimate interest.
  5. Request data portability: if the personal data has been collected directly from you and the legal ground is either your consent or that the processing is necessary to fulfil an agreement, you can request a copy of your personal data to be transferred to another party.
  6. Request restriction of the processing: under certain circumstance you may request restriction of the processing of your personal data, in which case we will only store your personal data but without processing it for any further purposes.
  7. Withdraw your consent: you may withdraw your consent at any time given to the collection, processing and transfer of your personal data for a certain purpose. Once we are notified, we will cease processing your data, unless we have a legitimate reason to do so.

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.

7. How to Contact Us

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


8. The Right to Lodge a Complaint with a Supervisory Authority

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