Integrity Policy

1.0. Introduction.

This document contains information regarding business practices by Fortis Ltd, which hereafter will be referred to as “we”, “us”, etc.

This is a notice to inform you of our policy about all information that we record about you as an individual directly by us or on behalf of our clients. It sets out the conditions under which we may hold and process any information that we currently have about you, or that you have provided us with. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this policy, “process” means collect, store, transfer, use or otherwise act on information. We take the protection of your privacy and confidentiality seriously. We understand that all individuals that we hold information about are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party. Our policy complies with that required by the EU General Data Protection Regulation (GDPR). The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org.
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our platforms, system tools, software solutions, or website.

2.0. The categories on which we may process information about you. The law requires us to determine under which of six defined categories we process different types of your personal information, and to notify you of the basis for each category. If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.

2.1. The categories in which we may process information about you. The law requires us to determine under which of six defined categories we process your personal information, and to notify you of the reasons. Those categories are:
 Consent. You have given clear consent for the collection and use of your data for a specific purpose..
 Contract. You have entered into a legal contract or asked us to use the data before entering into a contract.
 Legal obligation. The organisation/company must use the data to comply with other legal obligations.
 Legitimate interests. The use is necessary for the legitimate interest of the organisation/company or of a third party. This can be overridden if there is a good reason to protect the individual’s personal data. We mainly use this as basis for using specific personal information within our organisation as well as with third party organisations who acquire personal information on our behalf.
 Vital interests. The use is necessary to protect someone’s life.
 Public task. The use is necessary for the organisation/company to perform a task in the public interest.

If the basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data. If the basis changes, then if required by law, we shall notify you of the change and of any new basis under which we can continue to process your information.

2.2. Information we process with your consent. Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website, or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information. Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies. Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply. Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website. If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful. We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists. You may withdraw your consent at any time by instructing us via [email protected] However, if you do so, you may not be able to use our website or our services further.

2.3. Information we process because we have a contractual obligation with you. When you buy a service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us. In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information. We may use it in order to:
 Verify your identity for security purposes.
 Sell products to you.
 Provide you with our services.
 Provide you with suggestions and advice on services.

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract. Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable. We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

2.4. Information we process because we have a legal obligation. We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation. For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.

2.5. Information we process for the purposes of legitimate interests. We may process information on the basis there is a legitimate interest, either to you or to us. Where this occurs, we do so after giving careful consideration to whether the same objective could be achieved through other means and whether processing (or not processing) might cause you harm. For example, we may process your data on this basis for the purposes of:
 Record-keeping for the proper and necessary administration and execution of our business.
 Responding to unsolicited communication from you to that we believe you would expect a response.
 Protecting and asserting the legal rights of any party.
 Insuring against or obtaining professional advice that is required to manage business risk.
 Protecting your interests where we believe we have a duty to do so.

3.0. Specific uses of information you provide us.

3.1. Information provided on the understanding that it will be shared with a third party. To allow us to be able to provide you with the best service possible, we do use third party technology such as S2 Communications AB and Salesforce. We store, but not limited to, your name, surname,
address, age, telephone numbers, email address, as well as information regarding services purchased/acquired from one of our clients, on their platforms, allowing us to perform our customer service obligations and/or legal obligations.

3.2. Sending a message to/contacting our customer support. When you contact us, whether by telephone, through our website, or e-mail, we collect the data you have given to us in order to reply with the information you need. We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you and provide a high quality service.

3.3. Complaints. When we receive a complaint, we record all the information you have given to us and we use that information to resolve the issue. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is. We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

3.4. Business partner information. This is information given to us by you in your capacity as a business partner.
 The information is not used for any other purpose.
 We undertake to preserve the confidentiality of the information and of the terms of our relationship.
 We expect any affiliate or partner to agree to reciprocate this policy.

4.0. Use of information we collect through automated systems when you visit our website.

4.1. Cookies. Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
 Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
 Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
 Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

We use cookies in the following ways:
 To track how you use our website.
 To record whether you have seen specific messages we display on our website.

5.0. Disclosure and sharing of your information.

5.1. Information we obtain from third parties. Although we do not disclose your personal information to any third party (except as set out in this notice), we receive data that contains your publicly available personal information from third parties whose services we use. We use third parties, such as data suppliers (Bisnode, UC, etc.) to collect personal information. We have received written guarantees from these third parties that they comply with EU´s GDRP. We also obtain information from publicly available open sources, such as SPAR (Statens Personadressregister, Sweden).

5.2. Data may be processed outside the European Union Our website is hosted in Europe via LeaseWeb. You can find out about them at: https://www.leaseweb.com/. We also use outsourced services in countries outside the European Union in other aspects of our business. Accordingly data obtained within the EU could be processed outside the European Union. We use the following safeguards with respect to data transferred outside the European Union:
 The processor abides by the same binding corporate rules regarding data processing.
 The data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union.
 We comply with a code of conduct approved by a supervisory authority in the European Union.

6.0. Access to your own information.

6.1. Access to your personal information
 At any time you may review or update personally identifiable information that we hold about you.
 After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

6.2. Removal of your information
If you wish us to remove personally identifiable information from our database, servers, and platforms, you may contact us at [email protected] Removing such information may limit the service we can provide to you.

6.3. Verification of your information When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

7.0. Other matters.

7.1. Use of site by children
 We do not sell products or provide services for purchase by children, nor do we market to children.
 We collect data about all users of our website, regardless of age, and we anticipate that some of those users and visitors will be children.

7.2. Encryption of data sent between us
 We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
 Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

7.3. How you can complain
 If you are not happy with our privacy policy, or if wish to make a complaint, then you should inform us by email. Our address is [email protected]
 If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
 If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the relevant body in your EU country of residence.

7.4. Retention period for personal data Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
 To provide you with the services you have requested and/or purchased from either us or a client we represent and/or entered a business agreement with and/or act on behalf of.
 To comply with other law, including for the period demanded by our tax authorities.
 To support a claim or defence in court.

7.5. Compliance with the law Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you. However, ultimately it is your choice as to whether you wish to use our website and/or contact us via email or telephone.

7.6. Review of this privacy policy We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records. If you have any question regarding our privacy policy, please contact us at [email protected]