PRIVACY POLICY

PRIVACY POLICY

INTRODUCTION

MnO International AB 556497-9457, (the “Company“) imports and sells shoes, clothes, and bags, as well as related business. The sales and marketing of shoes, clothes, and bags, are also conducted through the website. (the ”Service”). The Company is the data controller for certain processing made regarding your personal data in connection with:

You as a customer is provided the Service;
You as the supplier, or representative of these, enter into cooperation with the Company; and
You apply for a position at the Company.

The Company is responsible for ensuring that all personal data is processed correctly and in accordance with applicable data protection legislation.

This privacy policy (hereinafter referred to as the ”Privacy Policy”) describes the Company’s processing of your personal data and has the purpose of assuring you that the Company is processing your information in accordance with applicable data protection legislation.

Personal data means all types of information that may, directly or indirectly, be associated with a living natural person. Within the scope of the Company’s activities, there may occur personal data relating to, e.g., given names and surnames, personal ID numbers, telephone numbers, addresses, postal codes, e-mail addresses, etc. (hereinafter collectively referred to as ”Personal Data”).

If you cannot find answers to your questions, please contact the Company. Information on how to contact the Company may be found under the heading “Contact Information” below.

Our website address is: https://www.mno.se

PROCESSING OF PERSONAL DATA

In this section, we describe how we process your Personal Data more in detail.

Customers or and potential customers

PurposeType of processingCategories of Personal DataCategories of Data Subjects

Processing orders from customers.This includes processing for delivery (including notifications and contacts concerning the delivery), processing of orders from customers, identifying customers, processing payment and processing complaints and warranty claims.Name.

Personal ID number.

Contact information (such as e-mail address
and phone number).

Payment information.

Purchase information (i.e. which product has
been ordered or whether the product should be delivered to another address).

Customers.

Source: Customer.

Lawful Basis: Completion of order. This gathering of your Personal Data is required in order for us to fulfill our commitments as agreed. If the information is not provided, our commitments cannot be fulfilled and we may terminate the contract.

Automated decision-making: This processing does not imply that decisions will be made based on the automated processing of Personal Data.

Data Retention: Until the contract has been performed (including delivery and payment) and for a time of up to 36 months thereafter with the purpose of processing any complaints or warranty claims.

PurposeType of processingCategories of Personal DataCategories of Data Subjects

In order to fulfill the Company’s legal obligations regarding the purchase of
goods or services.This includes the necessary processing for fulfilling the Company’s legal obligations according to law, court rulings (e.g. the Book-keeping Act) or decisions by authorities.Name.

Personal ID number.

Contact information.

Payment history.

Payment information.

Customers.

Source: Customer.

Lawful Basis: Legal obligation.

Automated decision-making: This processing does not imply that decisions will be made based on the automated processing of Personal Data.

Data Retention: Until the purchase has been completed (including delivery and payment) and for a time of up to 7 years thereafter.

PurposeType of processingCategories of Personal DataCategories of Data Subjects

Processing customer service matters.The processing includes communication and answering of potential questions related to customer service (via telephone or in digital channels, including social media, including
social media), identifying the customer and investigation of potential complaints.Name.

Personal ID number.

Contact information. Correspondence with the customer of customer’s representative.

Information on purchase time, potential defects/complaints.

Customers.

Source: Customer.

Lawful Basis: Legitimate interest. The processing is necessary in order to meet ours and the Data Subject’s legitimate interest in processing information regarding customer service matters.

Automated decision-making: This processing does not imply that decisions will be made based on the automated processing of Personal Data.

Data Retention: Until the customer service matter has been settled.

PurposeType of processingCategories of Personal DataCategories of Data Subjects

MarketingThis includes e.g. marketing mailings regarding our products and services via
e-mail and by post.Name.

Contact information.

Professional title.

Customers, potential customers.

Source: Customer or representative of customers, potential customers.

Lawful Basis: Consent and legitimate interest. The processing is necessary in order to cater to our interest in marketing our products and services.

Automated decision-making: This processing does not imply that decisions will be made based on the automated processing of Personal Data.

Data Retention: One year from the last contact. Longer after consent.

Suppliers

PurposeType of processingCategories of Personal DataCategories of Data Subjects

In order to communicate with contact persons for suppliers and partners.This includes e.g. processing deliveries and cooperation, as well as providing
organizational chart and telephone lists
in order to cooperate internally at the
Company. Supplier directory for easier
access to contact information.Name.

Contact information.

Suppliers and their representatives.

Source: From suppliers.

Lawful Basis: Legitimate interest. The Company has a legitimate interest in processing the Personal Data necessary in order to communicate with contact persons for suppliers and partners.

Automated decision-making: This processing does not imply that decisions will be made based on the automated processing of Personal Data.

Data Retention: Until we have received information that the contact person has quit or changed contact information, or for as long as the contractual relationship remains.

Job seekers

PurposeType of processingCategories of Personal DataImpacted Data Subjects

In order to administer a recruitment process.This includes e.g. to review the application and communicate with the applicant.Name.

Personal ID number

Contact information.

Proof of identity.

Information on job seeker’s
performances and prior work
experience.

Job seekers.

Source: Job seeker and the job seeker’s employer.

Lawful Basis:

Until the position is appointed: completion of an agreement.

After the position has been appointed: legitimate interest (or consent).

Automated decision-making: This processing does not mean that decisions will be made based on the automated processing of Personal Data.

Data Retention: Up to two years from when the position was appointed. Following the completed recruitment process, the information is filed in order to be used at a potential appeal of the recruitment in accordance with e.g. non-discrimination legislation. When there is no longer a possibility to appeal, the information will be destroyed unless there is consent for continued processing.

RECIPIENTS OF PERSONAL DATA & TRANSFERS TO COUNTRIES OUTSIDE THE EU/EEA

In our capacity as Personal Data Controller, we may assign the processing specified above to a partner or supplier. Such processing will not be done for other purposes than what is described above. Some partners and suppliers may have parts of their businesses in countries outside of the EU/EEA (so-called Third Countries). Transfer of Personal Data will only be made to such countries that offer an adequate level of data protection, as decided by the EU Commission, or if the supplier has a legally binding and enforceable instrument that guarantees the safety of the Personal Data.

YOUR RIGHTS AS DATA SUBJECT

You have the right to:

Request information about what type of Personal Data we process and you may request a copy of these (extract from registry);
Have incorrect Personal Data corrected and, under certain circumstances, ask us to erase your Personal Data;
Have your Personal Data transferred to another controller (right to data portability);
Withdraw your consent to the processing of your Personal Data; and
Object against the processing of certain Personal Data and request that the processing of your Personal Data is limited.

If you are unhappy with the way we process your Personal Data, you may file a complaint with the Data Inspection Board, which is the supervisory authority.

See contact information for asserting your rights under ”Privacy Disclaimer and Contact Information”. However, please note that such limitation or deletion of your Personal Data may result in the Company not being able to provide the Service.

AMENDMENTS TO THIS PRIVACY POLICY

The Company retains the right to revise this Privacy Policy from time to time. The date of the latest amendment is indicated at the end of this Privacy Policy. If the Company amends this Privacy Policy, the Company will publish these amendments at www.drylake.com. You are therefore recommended to regularly review this Privacy Policy in order to be updated on any amendments. If this Privacy Policy is substantially amended compared to what was stated when the Company obtained your consent, the Company will notify you of these amendments and, if necessary, obtain new consent to the Company’s processing of your Personal Data.

CONTACT INFORMATION

If you have any questions regarding the Privacy Policy or our processing, please contact:

MnO International AB, reg, no 556497-9457
dataskydd@mno.se
Ljusslingan 4
120 31 Stockholm, Sweden
+46 (0)8 587 916 00

The Privacy Policy was adopted on 2018-05-25