Personal data policy
Radonova Laboratories AB, corporate ID number 556690-0717, (“Radonova”, “we”) respect your privacy and your right to have control over your personal data.
This personal data policy describes the data we collect, the aim and purpose for which it is collected, the legal grounds for our processing of data, how you can control your own data, and how you can contact us. This personal data policy applies when you use our website and/or web application, as well as our services/products provided by telephone, e-mail, our website and/or through My pages (e.g. measurement of radon in indoor air or the provision of a user account), which are administered by Radonova (“the Service”). Radonova is the controller in accordance with these terms and conditions and is responsible for ensuring that data is processed in accordance with the applicable legislation. It is important that you read and understand our personal data policy before you use the Service.
All processing of personal data within Radonova is performed in accordance with the applicable personal data legislation. Within the EU/EEA, the General Data Protection Regulation (GDPR) applies as of 25 May 2018.
Personal data means any information that, together with other information, can be directly or indirectly linked to a living natural person. Examples of personal data are name, address, telephone number, personal ID number and e-mail address.
Information about an IP address and your user behaviour when using the Service may also constitute personal data. Personal data processing means all handling of personal data, such as collection, analysis, alteration, recording and storage.
A controller is the person that, alone or jointly with another person, determines the purposes and means of the processing of personal data, and is responsible for said processing being performed in accordance with the applicable legislation.
Radonova collects and processes the following personal data about you as a user of the Service:
- Telephone number
- E-mail address
- Invoicing address
- IP address
- Property type
- Property designation
- Technical building information (e.g. type of ventilation)
- Geographic information
- and other data you may provide within the context of the Service.
Radonova needs the above data to be able to perform the contract with you for carrying out the Service (e.g. radon measurement). If you choose not to provide certain personal data, this may result in Radonova being unable to carry out the requested Service, or in the Service not being carried out fully.
Certain information is collected automatically when you use the Service, including:
- Information about your use of our website, e.g. how you navigate and the pages you have visited
- Technical data about the devices you use to access the Service, such as IP address, type of hardware, operating system and browser version
- Geographic information
If you prefer us not to collect data on how you use our website, you can install the browser add-on “Google Analytics Opt-out”. You can find more information here: https://support.google.com/analytics/answer/181881
Purpose of the processing and legal grounds
We process personal data for the purposes set out below, and for any additional purposes specified at the time of collection:
- To provide the Service and administer our contract with you, including the preparation of and administration of your results from the Service;
- To be able to deliver everything included in the Service to a specified delivery address;
- To enable you to use the Service, we may disclose your personal data to a distributor of the Service, as well as orderers of the Service in order to fulfil the various elements of the Service;
- To be able to communicate with you by post, telephone, electronic communication (such as text message, e-mail, e-mail forms or social media accounts) or in another way, e.g. customer service contact, in order to send notifications and inform you of our updates to the Service and user terms and conditions;
- To safeguard the technical functionality of the Service;
- To improve and develop the Service and new services and products, in order to continuously improve the security of our networks and information systems, and to analyse your and other users’ use of the Service (e.g. what mobile device or equipment you use) in order to better understand how our customers interact with and use the Service;
- To send notices (e.g. a reminder when it is time to conclude the radon measurement) by post, e-mail or text message;
- To send information about your results from the Service by post or e-mail;
- For marketing purposes, including for marketing of our products and services, via e-mail (which you can opt out of by using a link in each mailing sent by e-mail);
- To control, prevent, investigate or implement other measures in connection with misuse of the Service or in connection with use of the Service in breach of the user terms and conditions for the Service, or in connection with legal action, suspected fraud or potential threats to Radonova or the rights of others;
- To comply with a legal obligation.
Legal grounds for Radonova’s processing of your personal data
Necessary processing for the performance of our contract with you
Radonova processes your personal data in order to be able to perform our contract with you (e.g. for the purposes set out in points 1-5 above).
Necessary processing for purposes concerning the legitimate interests pursued by Radonova or by a third party (balancing of interests).
In cases when processing is necessary for purposes concerning the legitimate interests pursued by Radonova or by a third party, we may process your personal data by virtue of a balancing of interests. Such interests include our commercial interest in maintaining a good customer relationship with you, providing you with information that is of relevance for your use of the Service, improving and further developing the Service, as well as marketing our products and services (e.g. for the purposes set out in points 3-11 above). The term “legitimate interests” thus refers to our interest in engaging in and managing our activities in order to enable us to provide you with the best possible Service and a good and safe user experience. For example, we have a legitimate interest in ensuring that the marketing is relevant to you. Therefore, we may process your personal data in order to adapt our marketing to reflect your interests, e.g. tailor it to the type of property you live in. Legitimate interests may also refer to processing that is also in your interest or in the interest of a third party. We may also process your personal data to protect you (and other customers, suppliers and partners), as well as the results of the Service, against fraud, infringement and other irregularities in the use of our Services in order to ensure that our Services, procedures and systems are secure. When we process your personal data on the basis of a balancing of interests, we ensure that we take into account and balance the potential effects of processing on you (both positive and negative), and your interests and rights under applicable data protection legislation. If you have views on, or object to, our processing based on a balancing of interests, you are entitled to object to such processing at any time. For more information about your rights, please see the information provided under the heading “Your rights and choices” below.
Processing on the basis of explicit consent
Radonova may also process personal data on the basis of explicit consent given by you (e.g. for the purposes set out in points 7-9 above).
Processing that is necessary for compliance with a legal obligation
Radonova may need to process personal data in order to be able to comply with legal obligations, e.g. for accounting purposes or as a consequence of a decision by a court or a public authority (i.e. for the purpose set out in point 11).
It may be the case that the same personal data is processed for multiple purposes and/or for more than one of the legal grounds set out above.
Security and transfer of personal data
Transfer of personal data to third parties
We will not share, sell, transfer or otherwise disclose personal data beyond what is stated in this personal data policy, unless we are obliged to do so by law or as a consequence of a decision by a court or if we have obtained your consent for such disclosure or you have purchased the Service through a third party (e.g. from one of our retailers or through your municipality).
Radonova may disclose personal data to a third party, e.g. the police or other public authority, if this relates to the investigation of suspected criminal offences or if we are otherwise obliged to disclose such data pursuant to a law or a decision by a public authority.
Radonova may employ external providers to perform tasks on Radonova’s behalf, e.g. to provide IT services or to supply the Service. The performance of these services may mean that Radonova’s providers, both within the EU/EEA and outside the EU/EEA, have access to your personal data. These providers process personal data on our behalf in accordance with data processing agreements and our instructions. Processors that are given access to your personal data are not given any right to use your personal data for purposes other than the purposes set out in this personal data policy. The data will be used predominantly to the extent required by the processor to be able to provide the Service (e.g. to send notices or deliver radon measurements to you).
Transfer of personal data to a third country
Radonova only cooperates with partners that process personal data within the EU/EEA. If Radonova opts to use providers outside the EU/EEA, e.g. cloud service providers, Radonova will, in such cases, take special safeguards, such as signing contracts that include standard model clauses for data transfer which have been adopted by the EU Commission and which are available on the EU Commission’s website, or working with companies that maintain the same level of protection as within the EU/EEA by, for example, signing up to the so-called Privacy Shield agreement between the EU and the USA.
Security for the protection of personal data
Radonova safeguards your privacy and ensures a high level of security for your personal data. Radonova has taken appropriate safeguards regarding your personal data against unauthorised access, modification, dissemination or destruction. All processing of your personal data is performed in strict confidence.
Storage and screening of personal data
Processing is performed in accordance with the applicable legislation, which means that personal data is stored for no longer than is necessary for the purposes of the processing. We will store your personal data until the Service you have chosen to use has been completed. The Service is deemed to be complete four years after the results of the Service have been approved; this is because SWEDAC requires Radonova to save data about the Service for four years. If you register for our newsletter, your contact details are saved for as long as you choose to continue receiving the newsletter. Only necessary contact information is used for marketing purposes. In purely practical terms, this means that data is screened and erased when it is no longer relevant or necessary for the purposes for which it was collected. Certain information may be retained for longer when this is required to satisfy other legal requirements, such as the Swedish Bookkeeping Act.
The same personal data may be stored in several different locations for different purposes. This may mean that some data that has been deleted from one system because it is no longer necessary may still be stored in another system where it is stored on another legal basis or for another purpose that still requires the personal data.
Your rights and choices
As regards the processing of your personal data, you have a number of rights arising from applicable data protection legislation. If you wish to exercise your rights, you are welcome to contact Radonova using the contact details provided at the end of this personal data policy.
Right of access
You have the right to request and to obtain confirmation as to whether Radonova is processing personal data about you. If Radonova is processing personal data about you, you have the right, once a year and free of charge, to request information about the processing, as well as a report on the personal data undergoing processing. For any additional reports requested, Radonova is entitled to charge a reasonable fee based on Radonova’s administrative costs for such copies. Where a request is manifestly unfounded or excessive, Radonova may, in accordance with applicable data protection legislation, charge a reasonable fee for such a request, or refuse to act on such a request.
Right to rectification of inaccurate personal data
You have the right to obtain without undue delay the rectification of inaccurate personal data about you. Depending on the purpose of the processing, you also have the right to have incomplete personal data completed.
Right to erasure (“the right to be forgotten”)
In certain circumstances you have to right to obtain erasure of your personal data, e.g.
- if the personal data is no longer necessary for the purposes for which it was collected;
- if the processing is based on your consent, you have the right at any time to withdraw your consent and then the right to obtain erasure of the data (provided that there are no other legal grounds for the processing);
- if you object to processing that is based on a balancing of interests and there are no overriding legitimate grounds for the processing. (However, you always have the right to erasure of personal data used for direct marketing based on a balancing of interests);
- if the personal data has been unlawfully processed or the data has to be erased because of a legal obligation.
However, the right to erasure does not apply in certain cases, e.g. if the processing is necessary for Radonova to comply with a legal obligation or for Radonova to be able to establish, exercise or defend legal claims.
Right to restriction
In certain circumstances you have the right to request that Radonova restricts the processing of your personal data, e.g. if you do not think that the personal data is correct so that Radonova has time to check this; if processing is unlawful and you do not want us to erase the data; if Radonova no longer needs the data but you need it for legal claims; or if you object to Radonova’s processing based on a balancing of interests pending the verification of whether the legitimate grounds of Radonova or a third party override your legitimate grounds.
Right to object
You have the right to object at any time to processing of your personal data based on a balancing of interests, including profiling. Radonova may not continue to process such personal data unless Radonova can present compelling legitimate grounds for such processing which override your interests, rights and freedoms. However, Radonova may continue the processing for the establishment, exercise or defence of legal claims. If you object to processing for direct marketing performed based on a balancing of interests, Radonova may no longer process your personal data for such a purpose. You can opt out of receiving marketing communications from us at any time by clicking on “Unsubscribe” in e-mails that we send you.
Right to data portability
In certain circumstances you have the right to transmit your personal data to another controller, e.g. if the processing is based on consent or on a contract between you and Radonova and provided that the processing is carried out by automated means. Where technically feasible, such transmission shall be performed directly from Radonova to another controller.
Right to lodge a complaint with the Swedish Data Protection Authority
If you think that your rights are not being respected by us, please contact us. You also have the right to lodge a complaint with the Swedish Data Protection Authority (Datainspektionen).
Links to other websites and social plug-ins
If the Service refers (links) to a website or material belonging to a third party, such a reference is only intended as a service for the user and Radonova disclaims any responsibility for this and any personal data processing carried out.
As part of the Service you may sometimes be invited to share information from the Service on social media, such as Facebook or Twitter, through an implemented social plug-in (for example, a share button). We have no influence over the information that social media platforms gather using these plug-ins if you choose to use them. We therefore encourage you to stay informed about the purpose of and scope of data collection carried out using social plug-ins.
Amendments to the personal data policy
In the event that we amend this personal data policy, we will publish the updated version here.
Choice of law and dispute resolution
Processing of your personal data subject to this personal data policy and your use of the Service shall be interpreted in accordance with Swedish law. Disputes shall be settled by a Swedish general court unless otherwise provided for under binding law.
For additional information about processing of personal data, or if you have any questions, please contact us at:
Radonova Laboratories AB
Rapsgatan 25 SE-754 50
E-mail address: firstname.lastname@example.org
Telephone number: +46 (0) 18 56 88 00
This personal data policy applies from 17-05-2018