Data Protection Policy

VHD Media Group AB

Processing of personal data at VHD
VHD Media Group AB

VHD Media Group AB (company registration number 556776-3429 with a subsidiary, hereinafter also called VHD) is responsible for storing and processing personal data on behalf of individuals and organizations. VHD shall process personal data in accordance with the applicable laws and regulations. This data protection policy provides information about VHD's processing of personal data.

Terminology

A data subject is an identifiable natural person.

A personal data controller is the organization that defines the purpose of the data processing's purpose (s) and has an agreement with the data subject.

A personal data processor processes personal data on behalf of the personal data controller. The processing is regulated by a personal data processing agreement between the personal data controller and the personal data processor.

• Personal data is all information directly or indirectly linked to an individual (data subject).

• Traffic data is data generated by using a network. An example may be when an individual uses the cellular network, which generates information about who sends and receives a message or phone call, start and end times, and the location of the cell phone. If traffic data is directly or indirectly linked to you as an individual, it is classified as personal data. For example, traffic data can be used for billing purposes.

• Anonymous tasks are tasks where all identifying elements have been deleted, so that it becomes impossible to link the data to an individual.

• Processing of personal data is any use of personal data, including collection, storage, modification, transfer, or deletion.

VHD as a personal data processor

How VHD processes personal data as a personal data processor is defined and described in the agreement between VHD and our customer, the personal data controller, and in the description of the respective services. The information about an individual (data subject) that we process as a personal data processor depends on which of our services are used by the personal data controller. Further information can be found in the customer agreement's product-specific terms and conditions.

VHD's processing on behalf of the customer is regulated by a personal data processing contract, and VHD will only process personal data for the purpose of providing our services to the customer, and in accordance with the data processing agreement and the customer's instructions. Upon termination of the agreement or instructions from the customer, we will delete or return the personal data processed under the agreement, unless otherwise required by mandatory law.

Examples of data processing activities

• Sending messages, such as SMS or email, from our customer (personal data controller) to the end user (data subject).

• Creating message logs, statistics, and reports.

• Providing directory services

• Monitoring traffic to ensure that messages are delivered and the system is stable.

• Enriching personal data with data from third-party sources (e.g., economic and demographic data from public sources) prior to anonymization and segmentation for use in marketing and reporting analysis. Please note that VHD or VHD's customer does not use supplementary data until it has been anonymized.

• Managing consent from the data subject

Depending on the service and the customer's use of the service in question, we may, as a personal data processor, process personal data in the following categories

• Basic personal information (such as name), contact details (such as email address, phone number, etc.).

• Location data, such as GPS data, Wi-Fi location data, and location data from the Personal Data Processor's network (which does not constitute traffic data as defined below).

• Trafikdata: Personuppgifter som behandlas i samband med överföring av kommunikation via ett elektroniskt kommunikationsnätverk eller fakturering därav.

• Data related to the use of our customer services, such as transaction history or message logs.

• Tasks associated with content in communications such as email, voice messages, SMS/MMS, web data, etc.

In some cases, VHD will be able to link personal data collected through multiple services as long as the data has been collected for the same purpose.

VHD as personal data controller

How VHD processes personal data as a personal data controller is defined and described in the terms of the agreement between VHD and our end user (registered). The information about the end-user we process as a personal data controller depends on which of our services are used.

Examples of data processing activities

• Managing end user profile.

• Managing end user consent.

• Managing membership

• Fulfilling individual rights.

• Notifying end users of changes to services, terms and conditions, or this privacy statement.

• Replying to requests or questions regarding services, terms and conditions, or this data protection policy.

• Providing information and membership offers.

Depending on the service and the customer's use of the service in question, we may, as a personal data controller, process personal data in the following categories

• Basic personal information (such as name), contact details (such as email address, phone number, etc.).
telefonnummer osv.).

• Location data, such as GPS data, Wi-Fi location data, and location data from the Personal Data Processor's network (which does not constitute traffic data as defined below).

• Trafikdata: Personuppgifter som behandlas i samband med överföring av kommunikation via ett elektroniskt kommunikationsnätverk eller fakturering därav.

Tasks associated with content in communications such as email, voice messages, SMS/MMS, web data,
etc.

In some cases, VHD will be able to link personal data collected through multiple services as long as the data has been collected for the same purpose.

The legal basis for VHD's processing is as follows:

• To fulfill the agreement for the use of a service provided by VHD to the end user, e.g. in connection with the management of user profile or membership, and to notify end users of changes to or respond to requests for services, terms of use or this data protection policy.

• To promote VHD's legitimate interests (always provided that the interests of the data subject are not greater than such interests), such as in terms of improving the services or user experience, in order to determine, claim or defend a legal claim, to prevent loss or damage to VHD or third parties, or to prevent any actions that may jeopardize the property of VHD or a third party or personal data belonging to the other users of the services.

• Consent, e.g. in connection with the promotion of VHD services.

• To comply with a statutory obligation that VHD has, for example, continued storage due to statutory rules for storage for accounting purposes

The end user can at any time

• withdraw consent to data processing activities that are based on consent.

• access personal data.

• change personal data.

• request deletion of personal data.

• request limitation or opposition to processing.

• request the export of personal data.

• terminate the contract.

VHD will keep your personal data for as long as necessary to fulfill the data processing purposes, as defined in the general terms of the agreement or in the Main Agreement between VHD and our end user, and as a rule, to maintain personal data until the Agreement is terminated or until the end user requests deletion. Note that legal obligations, such as statutory rules regarding storage for accounting purposes may necessitate the storage of personal data after the agreement's termination. Continued storage may also occur when such storage is necessary for VHD's legitimate interests, including but not limited to, the determination, enforcement, or defense of legal claims.

With whom do we share information?

VHD may disclose personal data to third party vendors and host partners providing services for VHD in order to provide services. Such third party providers shall only use the personal data for the purposes for which they have been collected and for the purpose of performing their services to VHD. The relationship with such third party providers shall be regulated by a data processing agreement.

The disclosure of personal data to public bodies may be done as and to the extent required by law and current regulations.

How do we use cookies?

VHD uses cookies and similar techniques on our site. Cookies help us determine which parts of our site are most popular, which pages are visited, and how long the visits last. This data is used to develop and analyze services as well as targeting site ads in services provided by partners. For further information, please refer to the VHD website.

How do we use Google Analytics and Google Adwords?

We use Google Analytics to see which sections of our site are most popular, which pages are visited, and how long visits last. The information is automatically deleted every 38 months. We are not interested in knowing who visits us and as soon as Google releases a tool to remove such data, we will enable it.

We use Google Adwords to market us through Google's channels. We can see when a click results in a visit, purchase, or order with us. But it is not until you actively become a customer that we can see who it is.

How do we protect personal data?

Personal data protection is of utmost importance to VHD. Therefore, we are constantly working to protect personal data. Our security policy includes protection for personnel, data, IT infrastructure, internal and public networks, office buildings, and technical facilities. Particular attention is paid to information such as personal data.

Our security work aims at balancing risk exposure, business value, available technology, vulnerabilities, and threats in order to comply with applicable laws, regulations, and contractual requirements.

VHD strives to implement security measures by setting appropriate privacy levels, thereby preventing personal data from being disclosed to unauthorized parties, both externally and internally.

Right to lodge a complaint with a supervisory authority

If you believe that the processing of personal data carried out by VHD is in violation of the relevant data protection provisions, you are entitled to file a complaint to the supervisory authority for the location you reside, work, or where the alleged infringement has taken place, or any other relevant regulatory authority.

Changes to this data protection policy

VHD reserves the right to make sporadic changes to this security policy. The latest revision will replace all previous versions. The current version of the privacy statement will always be available on the VHD website or available on request. We recommend that you check the data protection policy from time to time for the latest updates. We will notify you of any changes to the data protection policy for which you are entitled to obtain information about or which require your consent.

Contact information

If you are a direct customer of VHD, please contact our customer support via email for general questions: support@vhdmedia.se

NOTE: If you do not have general questions but have a personal data matter, you must send your matter via the form at the following link: https://www.vhdmedia.se/personuppgiftsarende

If you are an end user of one of VHD's customers, please contact the customer or sender directly.