Realforce Privacy Policy

: Monday, 20 March 2023

1. Introduction

At Realforce we are committed to being transparent about the personal data that we process and respecting the privacy of every person whose data we process. It is important to us that you understand what data we collect about you, how we use it and your rights.

In this Privacy Policy, the terms “we”, “us” and “our” refer to Realforce AB, and our affiliates and subsidiaries.

If you have any questions, please send us an email to privacy@realforce.com and we will be happy to assist.

1.1   Terms used in the policy

Data controller. Means the company or the organization that determines how personal data is processed and the purposes of the processing. The data controller is the company responsible for the processing of your personal data and shall make sure that you are given information about the processing and that your rights are guaranteed. We are the data controller of the processing of personal data described in this Privacy Policy.

‍GDPR. Means the General Data Protection Regulation (EU) 2016/679 regarding the processing of personal data and the free movement of such data including the United Kingdom’s application of the regulation in accordance with the UK Data Protection Act 2018.

‍Personal data. Means any information that directly or indirectly can be related to an identifiable private individual, such as name, picture, email address or IP-address.

‍Data processor. Means a company or organization that processes personal data on behalf of the data controller. In relation to our customers, we are normally the data processor and they are the data controller since we process personal data on their behalf.

2. How this policy is applied

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

Our customers (e.g. real estate agencies) may process personal data in connection with their use of our platform or services. In such cases, our customer is the data controller while we are data processor. We ensure appropriate safeguards for all information shared to our platform. We also enter into data processing agreements with all our customers. We propose that, as a first step, you contact the relevant real estate agency if you have questions regarding any personal data that they may process about you in connection with our services.

3. Changes to this policy

Since our business might change over time, we may also change how we process personal data. For this reason we may update this Privacy Policy from time to time. Such updates are always published in the most recent version of our Privacy Policy, available here: https://www.realforce.com/docs/privacy-policy.

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 - please see section 4.1.

‍ii) If you are an employee or representative of any of the organizations we interact with and have a contractual relationship with, or an organization we are likely to enter into a contract with - please see 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 birth date and preferred language.
• Organizational data, such as company name, job position, place of work and country.
• Correspondence data, such as personal information provided by email, by forms, post or similar means.
• Data related to events, such as information related to which events you sign up for and information in connection with such events.
• Technical data, such as IP address and 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 (if geolocation is enabled in your web browser).
• Preference or behavioral data, such as 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.

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 10 below and our Cookie Statement). 

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 these are the main examples but not entirely exhaustive and that there might be slight variations depending on the circumstances.

To communicate with you. We will administer and answer your inquiries and communicate with you via email, 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@realforce.com.

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

To track email-interactions. We may send you emails with tracking pixels/web beacons that collect data regarding your interaction with our emails. We do this in order to gain better knowledge and understanding of your interest in Realforce 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 (except where your consent is required - see below), 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. The data processed  is not of sensitive nature in these cases.

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

Consent. If we process your personal data in any way that requires your consent we will obtain such consent prior to the processing. If you have consented to our use of personal data about you for a specific purpose, you have the right to change your mind at any time. If you take back your consent we will stop the processing that was based on your consent. Please note that this will not affect any processing that has already taken place.

4.2 If you are an employee or representative of our customers, suppliers, business partners or other organization 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 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.
• Organizational 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 food preferences.
• Preference or behavioral data, such as 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.

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 e-mails or other communications with us.

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 organization 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 these are the main examples but not entirely exhaustive and that there might be slight variations 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 fulfill our contractual obligations towards you or the company you represent, including taking the steps necessary before entering into a contract with you or the organization 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@realforce.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 and LinkedIn. For example, if you sign up for our newsletter or download e-books from our website and consent to such use. If you no longer wish to receive advertising from us, contact us at privacy@realforce.com. You can also adjust your ad settings and change your ad preferences on Facebook, read more here, and on LinkedIn, 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. We may send you emails that collect such data described in section 4.1.3 above.

‍To protect our legitimate business interests and legal rights. Where required by law or where it is necessary to protect our legal rights, interests and the interests of others, we may 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 fulfill the terms of the agreements we have entered into with you or the organization you are employed by or represent, or in order to take necessary steps prior to entering into a contract.

‍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 and for accounting purposes.

‍Legitimate interest. We process your personal data to pursue our legitimate interest when we communicate with you for reasons other than to fulfill 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. The data processed based on our legitimate interest is not of sensitive nature. 

Consent. We may process your personal data based on your consent, in the situations described above. 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. If you take back your consent, we will stop the processing that was based on your consent. 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 fulfill the purposes for which we collected the data. The duration depends on the type of information and purpose of processing. 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 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 (e.g. accounting materials which are kept for 7 years). After that, we erase or securely anonymise your personal data.

6. How do we share your personal data?

To provide our services, we work with third parties who offer complimentary services. When we use third party services we sometimes share your personal data with them. We select our suppliers and partners carefully and will only share information with companies that are committed to ensure appropriate security measures. We also enter into a specific agreement regarding the processing of personal data with them (a data processing agreement).

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, or when communicating with you:

‍Employees and consultants. We share your personal information with our employees and consultants, but we restrict  access to those who need it for the purposes described in this Privacy Policy.

‍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 suppliers of IT services (such as database-, website-, hosting-, backup- and email service providers), marketing agencies, accountants, legal and other professional advisers.

We mainly transfer personal data to third parties with the purpose to deliver our products and services. Our suppliers and subcontractors are not authorized to use or disclose your personal data except as necessary to perform services on our behalf or to comply with legal obligations. We never sell your personal data to any third parties.

‍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 government 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 Realforce company group, suppliers or subcontractors.

Before transferring personal data outside of the EU/EEA area, we make sure to protect your data by taking all steps reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely. Examples of safeguards are transferring of data to countries that the European Commission has determined ensures an adequate level of data protection, applying EU standard Model Clauses or Binding Corporate Rules. You can contact us for details of the applicable safeguards.

8. Your rights

• Your right to object. You have the right to object to our processing of your personal data. In many cases we are obligated to fulfill your request, but it may depend on what data is concerned and our reasons for processing it (e.g. sometimes we have a legal obligation or other strong interest to process certain data about you). Please note that we might not be able to fulfill our other obligations towards you, in whole or in part, if you object to our processing of your personal data since personal data may be necessary to fulfill such obligations.
• Your right to access and to move your data. You have the right to request a transcript of your personal data processed by us. 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 (so-called data portability).
• 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. We might need to keep some of your personal data similarly to what is stated regarding ‘Your right to object’ above.
• Your right to restriction. You have the right to request that our processing of your personal data should be limited, e.g. 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. If you withdraw your consent, we will immediately stop the processing that was based on your consent. 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, transferring or deleting all or a part of your information.

9. Objections 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 use the unsubscribe link provided in the direct marketing emails. You may also use the contact details provided in section 12 below.

Please note that we may need to save and process your email address internally, but only to ensure that you are blocked from future direct marketing.

10. Cookies

We use cookies, pixels and similar technologies to provide you with a pleasant online experience, personalized advertising and to analyze the traffic to our site (depending on what you consent to). To get more information about the cookies we use – please read our Cookie Statement.

11. Complaints

If you consider that we have not complied with the requirements of applicable laws when it comes to your personal data, please contact us first, and we will help you in every way that we can. Please note that you always have the right to reach out to the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten).

12. Contact us

Realforce AB, company registration number 556951-2451, is a Swedish liability company incorporated under the laws of Sweden, with its registered office at Storgatan 53, 411 38 Gothenburg, Sweden. We are the responsible legal entity (data controller) for the processing of your personal data described in this privacy policy.

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