Processing Personal Data

Information regarding processing of personal data

(APPENDIX TO Terms & Conditions)

This document aims to inform you of Universum’s processing of your personal data. You (the “User”) receive this information in your capacity as a natural person employed and/or in any other way working for, or representing, a customer of Universum (the “Partner”), and thus have access to the services provided by Universum. The information provided through this document is applicable for all services provided by Universum for Partners and their Users, and serves as an integrated part of the terms and conditions entered into between Universum and the Partner.
Any reference to “Universum” or “us” in this document shall mean any applicable company with Universum Communications Sweden AB as the parent company. Its subsidiaries inter alia include Universum Communications Ltd, Universum Communications SA (PTY) LTD, Universum Communications Norway A/S (NO), Universum Business Consulting Shanghai Co. Ltd, Universum Communications Switzerland AG, Universum Communications SARL, Universum Communications Pte. Ltd, Universum Communications Holding Inc, and Universum Communication Inc.
Universum always processes personal data in accordance with the General Data Protection Regulation (GDPR) as well as any national (mainly Swedish) legislation, regulations etc. applicable to the processing of personal data.

  1. What is personal data?

Personal data is any kind of information that directly or indirectly refers to an identified or identifiable natural person. Typical examples of personal data are names, e-mail address, and civic registration numbers, but also information such as phone numbers, photographs and postal address may constitute personal data.

  1. Who is the Data controller/ processor of personal data?

According to the EU regulation on the protection of personal data (the “GDPR”), the Data Controller is the entity that decides the purpose and means for the processing of personal data. TheController has the ultimate responsibility to ensure the legality of the processing of personal data. The Data Controller may employ other entities to process parts of or the entire processing on behalf of the controller. Said entity is called the Data Processor.
Subject to the services provided by Universum, including but not limited to Activation, Research and Consulting (collectively referred to as the “Services”), Universum acts as Data Processor and the Partner as Data Controller.

  1. Universum’s processing of your personal data

When accessing and using the Service, you as a User will be asked to provide personal information. The information can include your telephone number, e-mail address, name, and sometimes pictures, career profile information, technical data as well as any other information you choose to provide (“Personal Data”).
In order to perform the Service ordered by the Partner, Universum processes the Personal Data, as part of the assignment agreed upon between the Partner and Universum. Universum cannot perform its obligations to conduct the Service in accordance with the Agreement without Users’ Personal Data. For this reason, Universum’s processing of Personal Data is necessary for the fulfillment of the Agreement with the Partner. It is not mandatory for you to provide your Personal Data, but if you chose not to, you will not be able to access and take part in the Service.
Universum will process your Personal Data until the complete delivery of the Service has been made. This may vary depending on the Service in question.

  1. Security measures

For Universum, guaranteeing proper safety for Personal Data is of utmost importance. Personal Data is protected by both technical and organizational measures, including computer safeguards such as firewalls and data encryption. We urge you to always keep passwords secret and to avoid any unauthorized access to user accounts.

  1. Transfer of personal data

Universum uses third party servers located in the EU/EEA and the USA for storage of personal data and for sub-processor-services related to and incorporated as part of the Service. Transfer of Personal Data is only performed after careful consideration and with suitable data processing agreements in place with the receiver of data on our behalf. For the transfer of Personal Data outside of EU/EEA, Universum will always secure the same level of protection of Personal Data as if processed within the EU/EEA by entering into standard contractual clauses in accordance with GDPR, or in other ways ensuring that there is a legal basis for the transfer or processing in accordance with GDPR, such as the EU Commissions Standard Contractual Clauses. We may transfer Personal Data to our technical subcontractors and partners for the explicit purpose of fulfilling our Agreement. All subcontractors and sub-processors have undertaken to process Personal Data under confidentiality.

  1. Aggregated data

Anonymous and aggregated User information may be used to generate statistics and comparison data for the benefit of our users. The aggregated results can also be used for the purpose of market research surveys and marketing and may be sold or forwarded to Universum business partners and customers. Universum never transfers or sells Personal Data. In aggregated form or anonymized, the once personal information no longer constitutes Personal Data, and the information is thus not traceable to an identifiable individual and cannot be used to identify the person from whom the information came.

  1. Your rights

Users have the right to obtain an extract of the information processed about the User. If you want to obtain such a statement, or wish to correct information or data, object to, or request that the processing of your Personal Data is restricted, you are welcome to contact Universum at contact@universumglobal.com. Universum will also assist you, if requested in an email sent to the aforementioned e-mail address, with the deletion of information regarding you and your use of the Service. However please be aware that if you ask Universum to delete all your information it may affect your usage of the Service, which in turn may affect the Partners of the same.

  1. Contact details

Universum Communications Sweden AB (“Universum”), Swedish company registration no. 5565875993, Jakobsbergsgatan 22, 111 44 Stockholm, Sweden, email address: contact@universumglobal.com.
Stockholm, June 2018