Privacy Policy 🧐

Last updated May 23rd, 2018

1. Introduction

We enable real estate agents to become real estate heroes by reaching new, relevant customers through social media marketing. In doing so, we need to process some personal data about you. In this Privacy Policy, the terms “we”, “us”, “our” refers to Adfenix AB, and our affiliates and subsidiaries.

Here at Adfenix, we are committed to being transparent about the data that we process and respecting the privacy of every person whose data we might come across. It is important to us that you understand what data we collect about you, how we use it and your rights.

If you have any questions, please send us an email to privacy@adfenix.com and we are happy to assist!

1.1   Some Great-To-Know Notions

Controller. Means the company or the organisation that determines how personal data is to be processed and the purposes of the processing. The controller is the entity responsible for the processing of your personal data and shall make sure that you are being given information about the processing and that your rights are guaranteed. We are the controller of the processing of personal data according to this Privacy Policy.

GDPR. Means the new European General Data Protection Regulation which regulates the protection of personal data and privacy for all European citizens.

Personal Data. Means any information that directly or indirectly (indirectly indicates data that together with other information, such as an IP-address) can be related to an identifiable private individual, such as name, personal security number, picture, email address and IP-address.

Processor. Means for example a company which processes personal data on behalf of the controller. In relation to our customers, we are the processor and they are the controller since we process personal data on their behalf.

2. How This Privacy Policy Is Applied

This Privacy Policy is applied when we are the data controller. That means this Privacy Policy is directed to you who visit our website and you who communicate with us. It also applies to you who are employed by, or a representative of, our customers, suppliers, business partners or other organisation we interact with.

If you are a user of our services, such as a real estate agent or a homeowner - it is the real estate agency that gave you access to the services who is the data controller and we are the processor. So if you have any question regarding the data processed by our customers through our services, please contact your real estate agency, and they will help you.

In case you are interested in joining the Adfenix family by applying for a job here - we have written a specific privacy policy just for this.

3. Changes To This Privacy Policy

Since our business and organisation most likely will change over time, we may modify this Privacy Policy. If we make any significant changes, we will provide you with a notice by email, text message or by publishing a new version on our website to give you the opportunity to review such changes before they become effective. We encourage you to consider this Privacy Policy from time to time, to stay up to date with changes (if any).

4. What Personal Data We Collect And Why

We have divided our collection of personal data into two categories:

i) If you are a website visitor or someone who contacts us without having a contractual relationship with us - go to section 4.1.

ii) If you are an employee or representative of any of the organisations we interact with and have a contractual relationship with, or are an organisation we are likely to enter into a contract with  - go to section 4.2.

4.1 If you visit our website or communicate with us

4.1.1 What personal data we collect and process about you

Depending on the circumstances, we may process the following types of personal data about you:

  • Contact details, such as name, email address, telephone number and postal address.
  • Individual data, such as name, birth date, personal identity number, preferred language, photos and hobbies.
  • Organisational data, such as company name, job position, place of work and country.
  • Correspondence data, such as personal information provided by email, by forms, by post or similar means.
  • Data related to events, such as information related to which events you sign up for, including allergies and other food preferences.
  • Technical data, such as IP address, device ID or other device identifier.
  • Traffic information data, provided by your web browser such as browser type, language, the address of the website from which you arrived and your general geographic location.
  • Preference or behavioural data, such as website clickstream behaviour (which links you click on and when), which posts you show interest in and how you interact with emails sent.
  • Other data. We may also collect and process any other relevant information you share with us, for example through your interactions by email, phone or in person, such as date, time and the subject of conversation.
  • Sensitive data. We will only collect sensitive personal data about you (such as racial or ethnic origin, trade union membership, political opinions, health, or the like) if there is a clear reason for doing so. We encourage you not to include sensitive data in your communications with us and to not include it in emails since email communication is not always secure.

4.1.2 How we collect your personal data

Information you give to us. Most of the information we collect comes directly from you, for example when you write to us in forms on the website or contact us via email. You can always choose not to provide us with certain information.

Information we collect about you. Sometimes we obtain information in other ways. For example from publicly available sources such as contact information service providers or through our use of cookies (see section 11 below and our Cookie Statement). You can always opt-out of our use of cookies.

4.1.3 How we use your personal data and the legal bases

We process your data for the purposes and based on the legal foundations listed below. Please note that the examples are not exhaustive and that they may vary depending on the circumstances.

To communicate with you. We will administer and answer your inquiries and communicate with you via email, via our website forms, by phone or on our social media channels.

To promote and market our services. For example, when we send informational or promotional communications to you via email, such as our latest insights and articles, information of our services and new products, promotional and advertising material and invitations to events. If you no longer wish to receive such communications, you can follow the unsubscribe instructions in those emails or contact us at privacy@adfenix.com.

To target, online advertising of our services. We may target our own ads to you on third party websites such as Facebook if you have visited our website and consented to our use of cookies or by using your contact details. If you no longer wish to receive such advertising from us, contact us at privacy@adfenix.com. You can also adjust how ads are targeted to you on Facebook by changing your ad preferences, read more here.

To track email-interactions. If we have obtained your prior, informed consent for such use, we may send you emails with tracking pixels/web beacons that collect data regarding if you open the email sent and what links you click. We do this in order to gain better knowledge and understanding of your interest in Adfenix and our services.

To compile statistics and make analyses. We will compile statistics on an anonymised basis related to, for example, website interactions and marketing activities to improve and gain a better understanding of the use of our services.

To conduct polls and surveys. We may contact you to ask how you have experienced the website, or our communications with you to improve our services.

To protect our legitimate business interests and legal rights. Where required by law, or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.

Legal bases

Legitimate interests. We process your personal data to pursue our legitimate interests when we handle your inquiries and communications, when we market our services to people that have shown interest in our services, and when we use your data for statistical and survey purposes. Our legitimate interests include, for example, to manage our daily operations according to lawful and fair business practices and to market our services.

When we use your information because we, or a third party (e.g. your employer/the organisation you represent), have a legitimate interest to do so, you have the right to object to such use.

Legal obligation. We process your personal data based on legal obligation when we are required by law.

Consent. If we track your email interactions, we do this based on your consent, and if we process your personal data in other ways that require your consent, we will obtain such consent prior to the processing.

4.2 If you are an employee or representative of our customers, suppliers, business partners or other organisation we interact with

4.2.1 What personal data we collect and process about you

Depending on the circumstances, we may process the following types of personal data about you:

  • Contact details, such as name, email address, telephone number and postal address.
  • Individual data, such as name, birth date, personal identity number or other identifier, gender, preferred language and photo.
  • Correspondence data, such as information provided by email, by forms, by post or similar means.
  • Contractual data, such as information of past and current contracts, orders and other agreements between us and you or the company you represent.
  • Financial data, for example if you are a sole trader interacting with us, we may collect and process credit or payment information and bank account details.
  • Organisational data, such as company name, job position, place of work and country.
  • Data related to events, such as information related to which events you sign up for, including allergies and other food preferences.
  • Other data. We may also collect and process any other relevant information you share with us, for example through your interactions by email, phone or in person, such as date, time and the subject of conversation.
  • Sensitive data. We will only collect sensitive personal data about you (such as racial or ethnic origin, trade union membership, political opinions, health, or the like) if there is a clear reason for doing so. We encourage you not to include sensitive data in your communications with us and to not include it in emails since email communication is not always secure.

4.2.2 How we collect your information

Information you give to us. Most of the information we collect comes directly from you, for example when you communicate with us on your behalf or on behalf of the organisation you are employed by or represent.

Information we collect about you. Sometimes we obtain information in other ways. For example, we may collect information from your employer or from the company that you represent, from social networks such as LinkedIn and publicly available sources such as contact information service providers.

4.2.3 How we use your personal data and the legal bases

We process your data for the purposes and based on the legal foundations listed below. Please note that the examples are not exhaustive and that they may vary depending on the circumstances.

To enter into and manage the business relationship. Your personal data will mainly be used to manage and take care of the business relationship between us, you and the company you represent. For example, we need to process personal data to fulfil our contractual obligations towards you or the company you represent, including taking the steps necessary before entering into a contract with you or the organisation you represent.

To communicate with you. We will administer and answer your inquiries and communicate with you/your employer by email, by our website, by phone or on our social media channels.

To promote and market our services. For example, when we send informational or promotional communications to you via emails, such as our latest insights and articles, information of our services and new products, promotional and advertising material and invitations to events. If you no longer wish to receive such communications, you can follow the unsubscribe instructions in those emails or contact us at privacy@adfenix.com.

To target, online advertising of our services. We may use your contact details such as email address to target you with our advertising on third party websites such as Facebook. If you no longer wish to receive such advertising from us, contact us at privacy@adfenix.com. You can also adjust how ads are targeted to you on Facebook by changing your ad preferences, read more here.

To compile statistics and make analyses. We may compile statistics of our communications and marketing activities to improve and gain a better understanding of the use of our services.

To conduct polls and surveys. We may send out surveys such as end customer satisfaction surveys, dealer satisfaction surveys, product quality surveys, and/or process improvement surveys to improve our services.

To track email-interactions. If we have received your prior, informed consent for such use, we may send you emails with tracking pixels/web beacons that collect data regarding if you open the email sent and what links you click. We do this to gain better knowledge and understanding of your interest in Adfenix and our services.

To protect our legitimate business interests and legal rights. Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.

Other purposes with your consent. We also use information about you when you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer/business partner stories to promote our services, with your permission.

Legal bases

Contractual obligation. We process your personal data based on the contractual obligation when we are required to do so to fulfil the terms of the agreements we have entered into with you or the organisation you’re employed by or represent.

Legal obligation. We process your personal data based on the legal obligation when we are required by law, for example when we report transactions to tax authorities.

Legitimate interest. We process your personal data to pursue our legitimate interest when we communicate with you for reasons other than to fulfil the terms of agreements and when we send you promotional communications with relevant marketing. We also process your personal data based on legitimate interest when we compile statistics and conduct surveys. Our legitimate interests include, for example, to manage our daily operations according to lawful and fair business practices, to market our services, to nurture our business relations and to keep you informed about our business. These interactions usually are also in the interest of the company you represent.

Where we use your information because a third party (e.g. your employer/the organisation you represent), or we have a legitimate interest to do so, you have the right to object to such use.

Consent. If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time. Please note that this will not affect any processing that has already taken place.

5. How Long Do We Save Your Personal Data?

We only keep your personal data as long as it is necessary to fulfil the purposes for which we collected the data. The duration depends on the type of information. We review our need to keep personal data on a regular basis, taking into account applicable legislation and contractual obligations.

Generally, we need to keep most of your information during our contractual or business relationship with you or the company you are employed by or represent. Typically, we also need to keep your information for a period after that because of warranty or liability requirements related to a contract. We may need to keep your data for a more extended period if we are required to do so by applicable statutory retention periods, such as tax and accounting rules. After that, we erase or securely anonymise your personal data.

6. How Do We Share Your Personal Data?

To provide excellent services in what we do, we need to work with third parties who offer exceptional services in what they do. When we use their services, it is sometimes unavoidable to share your personal data with them. We select our suppliers and partners carefully and will only share information with them when we are confident that they will protect it. To ensure this, we enter into a specific agreement regarding the processing of personal data with them.

We may share your personal information with our employees, our consultants, with companies within our company group and other parties when needed, when it comes to providing our website with content and when communicating with you:

Employees and consultants. We share your personal information with our employees and consultants, but we restrict the access to those who need it to perform their jobs.

Group Companies. We sometimes share your personal information with affiliated companies within the company group for purposes connected with our relationship with you, or the company you are employed by or represent.

Suppliers and subcontractors. We may transfer or share your personal data in our ordinary course of business, only to the extent necessary, with our suppliers and subcontractors that provide services to us. For example, we may engage marketing agencies, database and website service providers, hosting and backup service providers, email service providers, legal and other professional advisers.

We only transfer personal data to third parties with the purpose to deliver our products and services. Our suppliers and subcontractors are not authorised to use or disclose your personal data except as necessary to perform services on our behalf or to comply with legal obligations.

Business Transfers. We may share or transfer information we collect under this Privacy Policy in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Legal obligations. Sometimes legal obligations may require us to share information about you, for example, if we are required by law or a legal process or due to law enforcement agencies following an appropriate request.

With your consent. We may share your personal information where you ask us to, for example where we make a referral to another company. We may also share information about you with third parties when you have given us your consent to do so. For example, we sometimes publish personal testimonials of satisfied customers on our website.

7. Do We Transfer Your Personal Data Outside of the EU?

We always strive to process and store your data within the EU/EEA. However, your data may in some cases be transferred to, and stored at, a destination outside of the EU/EEA by companies within the Adfenix company group, suppliers or subcontractors. Please note that the privacy laws in countries outside of the EU/EEA may not be the same as, and in some cases may be less protective than, privacy laws in your country.

Before transferring personal data outside of the EU/EEA area, we will make sure to protect your data by taking all steps reasonably necessary to ensure that adequate safeguards (e.g. Binding Corporate Rules, EU standard Model Clauses and/or Privacy Shield) are in place to protect your personal information and to make sure it is treated securely. You can contact us for details of the applicable safeguards.

8. How Do We Protect Your Data?

We have great respect for your integrity and protecting your privacy is a key objective for us. We work continuously with the GDPR and guidelines from authorities to protect your personal data. We conduct routine vulnerability scans and penetration tests of our platform and systems. We also have thorough internal rules and policies in place to protect your data. For example, we take technical safeguard measures on all technical devices, monitor that all information is sent in secure manners and we apply access control in order only to allow staff access to data on a need-to-know basis. We also educate our employees and consultants on a regular basis on the topics of security, privacy and applicable laws and regulations.

9. Your Rights

This is a short summary of your rights:

  • Your right to object. You have the right to object to our processing of your personal data based on our legitimate interests, meaning we may not process your personal data any longer unless we can demonstrate compelling legitimate grounds for the processing which override your interests. You can always contact us to receive more information about the balance test we have made.
  • Your right to access and to move your data. You have the right to request a transcript of your personal data processed by us and additional information on how the data have been collected, processed and shared. The first transcript may be requested free of charge. You also have the right to move your personal data from us to another data controller.
  • Your right to rectification. You have the right to correct inaccurate or incomplete personal data about you.
  • Your right to erasure. You have the right to request that we delete personal data about you, for example, if the information is no longer necessary in relation to the purpose for which it was collected, or if we no longer have a legal basis to process the data.
  • Your right to restriction. You have the right to request that our processing of your personal data should be limited until we have corrected inaccurate or incomplete data about you or until we have handled an objection from you.
  • Your right to withdraw your consent. You have the right, at any given time, to withdraw any consent you have given us. Please note though, that it will not affect any processing that has already taken place.

Please note that our legal rights or obligations, such as privacy and confidentiality legislation, may prevent us from disclosing or transferring all or a part of your information, or from immediately deleting your personal data.

10. How Do You Object To Direct Marketing?

As described above, we may use your contact details such as email address for direct marketing. If you do not want us to use your email for direct marketing purposes, you have the right to object to such use at any time. Please contact us at privacy@adfenix.com, and we will block you from such marketing activities. Remember to write your name, the email to which the marketing is directed and what kind of marketing you do not wish to receive.

Please note that we may need to save and process such email or your email address, to ensure that you are blocked from future direct marketing activities.

11. What About Cookies?

Like almost every other company in the world, we use cookies, pixels and similar technologies to provide you with a pleasant online experience, personalised advertising and to analyse the traffic to our site. To get more information about the cookies that we use – please read our Cookie Statement.

12. How Can You Complain?

If you feel that we have not complied with the requirements of applicable laws and the GDPR when it comes to your personal data, please contact us first, and we will help you in every way that we can. Please observe that you also have the right to reach out to the Swedish Supervisory Authority- Datainspektionen.

13. Contact Us

Adfenix AB, company registration number 556951-2451, is a Swedish liability company incorporated under the laws of Sweden, with its registered office at Vallgatan 14, 411 16 Gothenburg, Sweden. We are the responsible legal entity (controller) of your personal data as described above. We comply with Swedish personal data protection laws, including the General Data Protection Regulation (GDPR).

We have an operations team devoted to working with privacy and personal data protection. Please contact them with any question you may have about this privacy policy or our processing of your personal data by sending an email to privacy@adfenix.com, and they will get back to you promptly.