Privacy Policy

At wintrgarden,com, accessible via https://wintrgarden.com/, one of our, Wintrgarden Group AB’s (Swedish company registration number 559067-1300) (“we”, “our”, “us”), main priorities is the privacy of our visitors. This Privacy Policy contains types of information that is collected and recorded by wintrgarden.com and how we use it. We process such personal data in the capacity of data controller.

If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us using the contact detail set forth below.

This Privacy Policy applies only to our online activities and applies for visitors to our website with regards to the information that they shared and/or collect in wintrgarden.com. This policy is not applicable to any information collected offline or via channels other than this website.

This Privacy Policy shall be interpreted in the light of the General Data Protection Regulation (EU) 2016/679 (the “GDPR”). This means that the following words and expressions shall have the meanings set forth below (however, formal definitions may be found in the GDPR);

“personal data” (or sometimes just ”data” or ”information”) refers to information about you or someone else, even if linking the information to you or someone else would require some effort.

“processing” refers to any action taken, such as use or collection, by us in relation to personal data. The processing can either be automatic or manual.

“data controller” refers to the person who is responsible for certain processing of personal data, thus determines the purpose of the processing. We, Wintrgarden Group AB, are the data controller in relation to the processing of personal data which we conduct on our own behalf, and it is such processing that is covered by this Privacy Policy. You find our contact details further down in this policy.

The personal information that you are asked to, or otherwise may, provide, and the reasons why you are asked to, or may, provide it, will be made clear to you at the point we ask you to provide your personal information. However, in most cases, your personal information will be processed for us to be able to collect leads for the purpose of our business (which is to develop and provide the talent attraction platform Wintrgarden).

If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message(s) and/or attachments you may send us, and any other information you may choose to provide.

In most cases, all your personal data which is processed by us, is collected directly from you.

We use the information we collect in various ways, including to:

• Purpose: Provide, operate, and maintain our website

Legal ground: It is necessary for us to process the data in order to fulfil the stated purpose, and we consider, after having carefully assessed the matter, that we have a legitimate interest in processing the personal data.

• Purpose: Improve, personalize, and expand our website

Legal ground: We have a legitimate interest in being able to develop our business/services etc. and that is the legal ground for our processing.

• Purpose: Understand and analyze how you use our website

Legal ground: We have a legitimate interest in being able to develop our business/services etc. and that is the legal ground for our processing.

• Purpose: Develop new products, services, features, and functionality

Legal ground: We have a legitimate interest in being able to develop our business/services etc. and that is the legal ground for our processing.

• Purpose: Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes

Legal ground: We have a legitimate interest in being able to respond to any inquires/messages by you and to be able to market and inform about ourselves etc., and that is the legal ground for our processing.

• Purpose: Send you emails (to the extent you have chosen to subscribe for newsletters) – and, as applicable, to not send you emails (should you not wish to receive emails from us and have unsubscribed) 

Legal ground: We have a legitimate interest in being able to market and inform about ourselves and that is the legal ground for our processing.

We are obliged not to continue to send newsletters and similar information to you should you not wish to receive such anymore, which is why we base the relevant processing on our legitimate interest in complying with applicable law and respecting your wishes.

• Purpose: Find and prevent fraud

Legal ground: We have a legitimate interest in not suffering from a fraudulent behaviour on our website, and that is the legal ground for our processing.

• Purpose: To be able to reconstruct, such as divide into several businesses, or if someone wishes to invest in us, acquire us or a part of us, or any of our assets, we might have to disclose your personal data to such potential investor or purchaser (who is bound by a confidentiality obligation)

Legal ground: If we process data due to the stated purpose, such processing will be based on our legitimate interest, after having carefully assessed the matter, in being able to restructure ourselves, finance our business or as otherwise stated, and thereby process your personal data.

• Purpose: Comply with applicable law and any decision of a court or competent authority

Legal ground: Such processing of personal data may take place on the basis that we have a legal obligation that requires the processing.

• Purpose: To safeguard our or someone else’s rights and/or interests in the event of a legal claim against us or someone else

Legal ground: Should we need to process personal data for the stated purpose, we consider, after having carefully assessed the matter, that we have a legitimate interest in doing so.

We process personal data only for as long as it is necessary to fulfil the purpose with the processing. When we no longer need certain personal data for the processing stated above, we delete it. Depending on the legal ground for the processing, the period during which we process the personal data may for instance be specified in legislation or be a result of our own assessment based on our legitimate interest.

Wintrgarden.com follows a standard procedure of using log files. These files log visitors when they visit websites. Normally, hosting companies do this and a part of the hosting services’ analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users’ movement on the website, and gathering demographic information.

Like any other website, wintrgarden.com uses ‘cookies’. These cookies are used to store information including visitors’ preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users’ experience by customizing our web page content based on visitors’ browser type and/or other information.

For more general information on cookies, please read our Cookie Policy.

You may consult this section to find the Privacy Policy for each of the advertising partners of wintrgarden.com.

Third-party ad servers or ad networks uses technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on wintrgarden.com, which are sent directly to users’ browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit.

Note that wintrgarden.com has no access to or control over these cookies that are used by third-party advertisers.

Wintrgarden.com’s Privacy Policy does not apply to other advertisers or websites. Thus, we are advising you to consult the respective Privacy Policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options.

You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers’ respective websites.

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request copies of your personal data. We may charge you a reasonable fee for this service if the request is manifestly unfounded or excessive.

The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.

The right to erasure – You have the right to request that we erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

The right to not be subject to automated decision-making – You have the right to not be subject of a decision that ins only based on some form of automated decision-making, including profiling, if the decision can have legal consequences for you or in a similar way affect you.

If you make a request, we will respond to you as soon as possible. If you would like to exercise any of these rights, please contact us using the contact details as set forth below. If you exercise your rights as described above, we may not be able to cooperate or have continued contact with you (or the company that you represent), or to provide our services to you. Further, the rights described above are not absolute but are subject to limitation according to applicable laws, including the GDPR.

We have taken technical and organizational measures to ensure that your personal data is protected in the best possible way (such as by introducing secure networks, instructions, when choosing our systems etc.). We ensure that your personal data is not disclosed other than when necessary (which varies depending on the type of personal data and the purpose of the processing) and otherwise ensure that it is protected from loss and unauthorized access.

The personal data that we process is available to a limited number of persons within our organisation (which varies depending on the type of personal data and the purpose of the processing) who are employees or consultants. We also share personal data with our subcontractors and, where applicable, to potential investors and purchasers according to what is set out above, to the extent necessary for us to be able to achieve the purpose of the personal data processing. We never share more information than necessary given the purpose of the sharing. We choose our subcontractors with great care and enter into data processing agreements with all of them, meaning that they may only process personal data in accordance with applicable law and our instructions.

We strive for your personal data to be processed within the EU/EEA. However, some of our subcontractors are domiciled outside the EU/EEA, and therefore personal data may sometimes be transferred and processed outside the EU/EEA where other rules on personal data processing apply. However, we will always take all necessary measures to ensure that your personal data is processed with appropriate safeguards in accordance with the GDPR and other applicable laws (such as standard contractual clauses).

If you find that we process your personal data unlawfully, you may file a complaint with the national data protection supervisory, the Swedish Authority for Privacy Protection (Swedish: Integritetsskyddsmyndigheten), for instance by sending an email to imy@imy.se. Additional information can be found on their website, https://www.imy.se/.

Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.

Wintrgarden.com does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

If you have any questions about our personal data processing or want to exercise your rights as set out above, you are welcome to contact us. The easiest way to reach us is to send an email to info@wintrgarden.com. Also, you are always welcome to send us a letter. Our address is:

Wintrgarden Group AB
Vasagatan 28
111 20 Stockholm

We may make changes to this Privacy Policy. The latest version of it is always available upon request and at wintrgarden,com. Before any material amendments to this Privacy Policy enter into force, we will inform you about them (for instance through a notice on your website or an email) before continuing the processing of your personal data.