Privacy Policy (Old Version)

1. Introduction

This General Universum Privacy Policy (also referred to as the “Privacy Policy”) provides information on the collection, use, sharing and processing of personal information by Universum Communications Sweden AB and its subsidiaries (“Universum”, “we” or “us”) in connection with your use of Universum websites, mobile applications, social media pages and/or any other digital service that links to this Privacy Policy, your interactions with Universum during in-person meetings or at competitions and events, and in the context of other offline sales and marketing activities. This Privacy Policy also explains the choices and rights you have in relation to these processing activities.

This Privacy Policy was last updated on May 8^th 2019. However, the Privacy Policy may change over time, for example to comply with legal requirements or to meet changing business needs. The most up-to-date version can be found here. In case there is an important change that we want to highlight to you, we may also inform you in another appropriate ways (for example via a pop-up notice or statement of changes on our website). To see the previous version of this Privacy Policy, please click here.

As used throughout this Privacy Policy, terms ‘personal information’ or ‘personal data’ means any and all information that relates to an identified individual or to an identifiable individual. For example, this could include among other things your name, address, email address, business contact details, title or information gathered through your interactions with us via our websites, services, competitions, surveys and/or at events. Personal information is also referred to as ‘information about you’.

Universum Company Group entities responsible for your personal information

Universum and its subsidiaries are responsible for processing your personal information described in this Privacy Policy. Information on Universum subsidiaries is available here. Please select a region and country to view the registered address and contact details of the Universum entity or entities located in each country.

Scope of this privacy policy

This Privacy Policy applies to the processing of personal information by Universum, as controller, of;

visitors and users of the various Universum websites, software, digital tools, applications, social media/network pages, event or competition sites or any other feature referring or linking to this Privacy Policy;
attendees of Universum events, surveys and competitions;
customers and prospective customers and their representatives;
subscribers to Universum news and services; and
suppliers and business partners (including prospects) and their representatives.

When interacting with Universum sites and services, you also may have the ability to link, connect or interact with non-Universum websites, services, social networks, applications or other features. Enabling these features will lead to other parties than Universum processing information about you. We do not have any control over these features of other parties and encourage you to review the privacy policies of these parties before using these features.

This Privacy Policy explains the types of information that we may collect, process and hold, how that information is used and with whom the data is shared. It also sets out how you may contact us if you have any queries, concerns or complaints about this Privacy Policy. Some of our services also have service specific privacy policies, which provide details on how your information is processed by that service. Where applicable, these service-specific policies may apply in addition to or instead of this Privacy Policy.

Universum’s Data Protection Principles

Unless provided otherwise, all processing of personal data by Universum is conducted in accordance with the data protection principles set out in the data protection laws and regulations of Sweden, in particular according to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, (hereafter referred to as the “GDPR”).

More specifically, we wish to highlight the following principles:

Lawfulness – We only process your information when we have identified a lawful basis for the intended personal data processing. These are often referred to as “conditions for processing”, for example contractual obligation, legal obligation, legitimate interest or explicit consent.

Fairness – We have made reasonable effort to ensure not to use your personal data in any unjustified way or in a manner which has an adverse effect to your privacy, and we ensure that the personal data is minimised and retained to the extent allowing us to provide our services.

Transparency – We have made our best efforts to provide you detailed information on our use of your personal information. You are encouraged to contact us whenever you have questions or seek information about our privacy procedures and security measures.

Our policies and procedures are to our best efforts designed to ensure compliance with these principles.

2. Type of personal data processed by us

Universum may process your personal data in several ways and for various reasons. As Universum’s key business and related services revolve around employer branding, career development and market research, we may collect different types of general or personal information about you both offline and online. This information may originate directly from you or indirectly shared with us by data aggregators who may or may not have a relationship with you, such as our business partners, our customers, employers and employees, educational institutions, students or student organisations etc.

The Offline information about you originates from our interactions with you during in-person meetings or at events, interviews, conferences, workshops, gatherings, competitions etc.

The Online information about you originates from your activities on our or our business partners’ sites or digital platforms, for example, in relation with user accounts; (pre-)sales inquiries; invitations or subscription to our newsletters, events, surveys or competitions; social media interactions or from your interaction with Universum’s or our business partners’ digital communication tools such as email, webforms or telephone etc.

Online information about you may also originate from the use of Cookies and similar technologies (for example, pixel tags and device identifiers) on our sites or sites of third parties. For more information on our Cookies and similar technologies, please see Universum’s Cookie Policy available here.

More specifically, we and our business partners may collect, process or retain personal information about you;

A) when you sign up or explore any of our services or sites, or when you create a user account to get access to any of Universum’s digital applications or online tools such as career or branding related contents etc.;

B) when you are invited to or participate in interviews, testimonials, surveys, events, online focus groups etc.;

C) when you contact us with questions or other inquiries or contact our sales or customer services etc.; or

D) when you sign up for marketing materials, advertisements, event invitations or any other information about our services and products etc.,

we may request for various types of information about you, your employer or your representative expressed as, inter alia, personal details (e.g. name, age, gender, photographs, audio/video, testimonials), contact details (e.g. physical address, e-mail, phone number), demographic attributes (e.g. educational level, income level, marital status, occupation, professional title, business sector, career interests), transactional details (e.g. orders, financial details, payment methods, credit card number, CVV), unique identification information (e.g. login, user account passwords, browser cookie ID, social media/network profiles), IP address and information that may be derived from IP address (e.g. demographic location), information about a device you use (e.g. browser, device type, operating system, the presence or use of “apps”, preferred language”, behavioural data of the internet connected hardware you use when interacting with sites (e.g. advertisements clicked or viewed, sites and content areas, date and time of activities, web searches used to locate and navigate sites), and/or information about you, your employer or the person you represent that is tailor-made and specific for our branding and career services, surveys and competitions, on a case-by-case basis.

We kindly ask you to exercise due care when submitting information to us. Certain of our products, services and digital contents are automated and are therefore not capable of recognising mistakes or incorrect input values related to personal data.

Please note that Universum does not control the content that you may post to our communities, forums or social networks; in some cases, such content may be publicly available on the Internet. You should carefully consider whether you wish to submit personal information to these forums or social networks and whether you wish to make your profile available to other users, and you should tailor any content you may submit accordingly.

3. How do we use your personal data?

Universum’s collection and processing of your personal data for employer branding, career development and market research is a precondition for us to develop, supply or market related products, services, tools, contents.

More specifically, we may process personal data for the following purposes:

to communicate and to send important product and service related notices, such as information about subscriptions, participations in events, surveys or competitions (including awards), purchases, information on technical service issues, support, security announcements and changes to our terms, policies, guidelines or standards;
to engage in transactions with customers, suppliers and business partners and to process purchases of our products, service, tools, and other contents, including confirming payments or receipt of the procured items;
to administer, promote and facilitate our surveys, research activities, competitions, prize draws, awards, gifts, vouchers, testimonials or events organised by us or jointly by our business partners;
to operate, analyse, develop, improve, optimise the use, function and performance of Universum’s online services, websites, surveys, competitions, webinars, newsletters and their contents, as well as to manage and monitor the security of our sites, networks and systems;
to provide user-care, warranty, returns and other after-sales services;
to enhance, update or upgrade our product and service quality and to improve Universum’s overall level of quality, compliance and social responsibility;
to seek your input and opinion about our products and services, and to conduct surveys and to collect user-input about our products and services;
to administer, facilitate and process enquiries, searches and requests for data, survey reports and other information related to our career and branding activities;
to process and manage employment requests, interviews, candidates or employment considerations at Universum;
to communicate new products, services, tools, digital applications, software updates, upcoming events, surveys and competitions, as well as to provide other sales and marketing communications;
to monitor and enforce our terms and conditions, policies, guidelines or standards related to our products, services, tools or contents, as well as to prevent and to mitigate the risk of fraudulent use of such material;
to create anonymous, aggregated statistics about the use of our website, products, services, tools and other programmes (including surveys, competitions, awards etc.), which we may share with third parties and/or make available in pseudonymised/anonymised format;
to link, publish or publicise materials and contents that you have commented on, reviewed, shared or uploaded in social networks or forums with our websites or use in marketing materials or advertisements (including pictures, audio/video material or other testimonials); and
to comply with applicable laws and regulations and to operate our business.

Universum employees are authorised to access personal information only to the extent necessary to serve the applicable purpose(s) and to perform their job functions.

Forums, blogs and online information sharing sources

Each time you create or reply to a survey, post or thread on a Universum website forum, blog, RSS or other information sharing sources, in addition to providing such online services, we may also record the forum, blog, RSS or information sharing source name and the time and date of your post or thread with your account details. We do this to better understand our users, to provide user tools and guidance and to select or tailor our products, services, marketing communications to reflect your use activity. We do not use the content of such posts or threads for any other additional purposes.

Interlinking collected information

We may link or combine the information that we collect from the different sources outlined above (including information received from our business partners and third-party developers). Information may be linked via a unique identifier, such as a cookie, plugin or other account identifiers. Alternatively, we may decide to combine two or more databases into a single database of user information.

We may do this for your and/or our convenience (for example, to allow you to more easily register for a new product or service), to allow us to provide a more seamless user support whenever you contact us and to provide you with qualitative, personalised services, content, marketing and adverts.

Minor’s Privacy

Universum considers a minor/child to be anyone under the age of sixteen (16). We do not knowingly seek or collect personal information from or about minors/children without the explicit consent of a parent or guardian. If we become aware that personal information that has been submitted to us relates to a child without the consent of a parent or guardian, we will use reasonable efforts to:

delete that personal information from our files as soon as possible; or
ensure, where deletion is not possible, that this personal information is not used further for any purpose, nor disclosed further to any third-party.

Any parent or guardian with queries and questions concerning personal data processing that may relate to their child should contact us by using the details provided in the section “Contact Details” below.

4. Conditions for processing

For personal information collected about you in the European Union (including Norway, Iceland and Lichtenstein), our conditions for processing is the following:

Contractual obligation – in order to engage in transactions with customers, suppliers and business partners, and to process purchases and downloads of our products and services, we need to process information about you as necessary to enter into or perform a contract with you.

Legal obligation – in order to comply with applicable laws and regulations, such as to comply with regulatory injunctions, administrative procedures or other legal process, or to process an opt-out request or exercise of your rights as a registered individual.

Consent – from time to time and on a case-by-case basis, we may process personal information based on your explicit consent where so indicated on our or our business partners’ sites or by way of a tailor-made privacy notice at the time your personal information was collected, or further to our legitimate interest to market and promote our products and services or invite you to participate in a survey, competition, prize draw, award, testimonial, webinar or any other ever organised, administered or managed by us or by our business partners jointly.

Legitimate interest – we may rely on our legitimate interest (preceded by a balancing assessment against the individual’s interests, rights and freedoms) to process personal information for various purposes in Section 3 above, such as (i) to administer, promote and facilitate our surveys, research activities, competitions, prize draws, awards, gifts, vouchers, testimonials or events, (ii) to communicate and to send important product and service related notices, (iii) to operate, analyse, develop, improve, optimise the use, function and performance of our online services, websites, surveys, competitions, webinars, newsletters and their contents, (iv) to manage and monitor the security of our sites, networks and systems, (v) to engage in transactions with customers, suppliers and business partners, (vi) to provide user-care, warranty, returns and other after-sales services, (vii) to seek your input and opinion about our products and services, and to conduct surveys and to collect user-input about our products and services etc.

For more detailed information about Universum’s conditions for processing for a specific processing of your personal information, please contact us by using the details provided in the section “Contact Details” below.

5. Sharing of your personal information

In general, Universum does not sell, rent, share or otherwise disclose your personal information with third parties. Notwithstanding, as a global stakeholder and in our endeavour to provide quality products and services concerning employment branding and career development, we may need to transfer your personal data to our subsidiaries, affiliates or trusted businesses partners and service providers (whom shall process the information on our instructions and in compliance with applicable laws and regulations).

A transfer of personal data is only performed after careful consideration and with suitable data processing arrangements in place with such recipients. To the extent reasonably feasible, we strive to process personal data within the European Union (including Norway, Iceland and Lichtenstein).

However, we may transfer personal data to destination and recipients outside of this territory. As Universum is committed to protect personal data, we will undertake reasonable efforts to ensure that the personal data transferred is subject to appropriate privacy protection measures ensuring an adequate level of protection that is comparable with the protection level afforded to individuals in the European Union (such as contractual, technical and organisational measures, Privacy Shield schemes, standard contractual clauses, specific controller’s instructions, explicit consent etc.).

Against this background, we may share personal information with the following category of recipients:

third-party service providers (for example, credit card processing services, order fulfilment, analytics, event/campaign management, website management, information technology and related infrastructure provision, customer service, e-mail delivery, auditing, and other similar service providers) to perform business functions on behalf of Universum;
Universum business partners for further follow-up related to your interests, specific partners that offer complementary products and services or with third parties to facilitate interest-based advertising;
relevant third parties in the event of a reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); or
as required by law, such as to comply with injunctions or other legal process, when we in good faith consider the disclosures necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to government requests, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes.

For more detailed information about international transfers to our business partners, service providers and developers outside of the European Union, please contact us by using the details provided in the section “Contact Details” below.

6. Retention Periods

We will not store your personal data for a longer period than necessary considering the purpose for which the personal information was collected. Unless otherwise provided, Universum retains personal information for the following periods:

If you have registered for a user account, your account information will be retained for as long as you maintain an active account. Your account and account information will be deleted if you do not log in for eighteen (18) consecutive months. Universum retains records of that deletion for six (6) consecutive months. Notwithstanding the foregoing, Universum and reserves the right to deactivate your account for reasons such as prolonged inactivity, fraudulent use, breach of Universum’s user terms, policies and standards, or for any other compliance reason, and cease all processing of personal data thereafter.
Information collected to engage in transactions with our customers, suppliers and business partners, and to process purchases of our products, services, tools and contents, will be retained for the duration of the transaction or services period, or longer as necessary for record retention and legal compliance purposes.

Notwithstanding the aforesaid, Universum may retain personal data for a longer period of time than considered necessary against the collected purpose, inter alia:

to ensure compliance with legal or contractual arrangements requiring retention of information for specific purposes and for an extended period of time, such as for tax and accounting purposes, financial record keeping purposes, or to prevent fraud and abuse;
to establish, exercise or defend against legal and regulatory claims; or
to ensure a maintained level of information security or to protect Universum’s sites, networks and systems against cyberbreach, (such as attacks on the website, instalment of viruses and/or malware etc.).

7. Information Security

How do we protect your information?

We have adopted and implemented a number of technical and administrative measures to protect your privacy from unauthorised access, use or alteration and unlawful destructions, including where appropriate the following steps:

Using Secure Sockets Layer (SSL) encryption when collecting, storing, processing or transferring sensitive information, such as credit card details (SSL encryption is designed to make the data unreadable by anyone but Universum).
Limiting access rights to the information we collect about you (e.g., only those of our personnel who need your information to carry out our business activities are allowed access to process your information).
Implementing physical, digital and procedural safeguards in line with relevant business standards and guidelines.

What you should do to help us in protecting your information?

As general best practice on the Internet, it is recommended that you take great care with your user account, and follow vigilantly some general safety rules:

Do not press a link that you do not expect to receive or not requested by us to press.
Do not use simple, trivial, or versatilely used passwords when creating an account or using our products and services.
Do not share your account information with any person claiming to represent Universum. For support purposes, we only need you to provide us with the email address you used when creating your user account.
Do install anti-virus, anti-phishing or anti-malware software on the hardware when using our products and services.
Always contact us if you are unsure or in doubt of a communication received from Universum or a source claiming to be associated with us.
Never use an unlicensed Universum account fraudulently created to access our products and services.

For more information, please review and accept relevant Universum terms of service and where applicable End User License Agreement (EULA) for specific services.

8. Your privacy controls and rights

With respect to personal data processed by Universum as a controller, and subject to certain limitations, you are entitled to exercise the following:

Your right of access – You have the right to ask us for copies of your personal information processed by Universum. However, you may not always receive all the information we process.
Your right to rectification – You have the right to ask us to rectify information you consider as inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.
Your right to object to processing – You have the right to object to processing if we are able to process your information because the process is in our legitimate interests.
Your right to data portability – This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated.
Your right of withdrawing consent – If you have given consent to certain processing, you are always entitled to withdraw your consent.
Your right to file a complaint – You may at any time file a complaint about our processing of your personal data to the relevant competent data protection authority in the European Union Member State of your residence or the Swedish Data Protection Authority (https://www.datainspektionen.se/other-lang/in-english/).

You are not required to pay any charge for exercising your rights. We have one (1) month to respond to you.

9. Complaint handling

If you have any complaints concerning Universum’s compliance with this Privacy Policy, please contact us first. We will investigate and attempt to resolve complaints and disputes on use and disclosure of personal information in accordance with this Privacy Policy and in accordance with applicable law.

10. Contact details

If you have any questions or enquiries about this Privacy Policy or any other matter related to privacy and data protection, please contact us at the following:

Universum Communications Sweden AB (Company No. 556587-5993)

Visiting address: Jakobsbergsgatan 22, Stockholm, Sweden

Mail address: BOX 7053, 103 86 Stockholm, Sweden

Email address: contact@universumglobal.com