Always Summer Asset Management AB (“Always Summer”, “we”, “us” or “our”) is committed to protecting your privacy and handling personal data in a transparent, secure and responsible manner.
This Privacy Policy explains how we collect, use, store and share personal data when you visit our website, communicate with us, or otherwise interact with our business.This policy applies to personal data processed by Always Summer Asset Management AB in accordance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR).
What personal data we may collect
We may collect and process personal data such as:
Name
Email address
Telephone number
Company name and professional title
Information provided in correspondence or contact forms
Technical information such as IP address, browser type, device information and website usage data
Preferences relating to communications or website settings
We only collect personal data that is relevant and necessary for legitimate business purposes.
How we collect personal data
We may collect personal data:
Directly from you when you contact us or submit information
Through meetings, calls or business correspondence
Through the use of our website
From publicly available sources
From professional counterparties, advisers or service providers where appropriate
Why we process personal data
We may use personal data for the following purposes:
To respond to enquiries and requests
To manage business relationships and investor communications
To provide information about our services
To comply with legal, regulatory and compliance obligations
To maintain the security and performance of our website and systems
To improve our website, communications and operations
To establish, exercise or defend legal claims where necessary
Legal basis for processing
We process personal data only where permitted under applicable law. Depending on the circumstances, processing may be based on:
Your consent
Performance of a contract or steps prior to entering a contract
Compliance with a legal or regulatory obligation
Our legitimate interests, provided those interests are not overridden by your rights and freedoms
Sharing personal data
We may share personal data where necessary with:
Professional advisers such as legal, audit or compliance providers
IT, hosting and administrative service providers
Regulators, supervisory authorities or governmental bodies
Other third parties where required by law or where necessary to protect our legal rights
All third parties are expected to process personal data securely and only for legitimate purposes.
International transfers
Where personal data is transferred outside the European Economic Area (EEA), we will take appropriate steps to ensure that adequate safeguards are in place in accordance with applicable law.
Data retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, tax, accounting or reporting requirements.Retention periods vary depending on the type of data and purpose of processing.
Your rights
Subject to applicable law, you may have the right to:
Request access to your personal data
Request correction of inaccurate or incomplete data
Request deletion of personal data
Request restriction of processing
Object to certain processing activities
Request data portability where applicable
Withdraw consent at any time where processing is based on consent
Lodge a complaint with the Swedish Authority for Privacy Protection (IMY) or another competent supervisory authority
To exercise any of these rights, please contact us using the details above.
Security
We take appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration or disclosure.
Third-party websites
Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of external websites.
Changes to this policy
We may update this Privacy Policy from time to time. Any updated version will be published on this page with a revised “Last updated” date.
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