Privacy policy
Integrity policy
1 Introduction
We, Bergman & Beving Aktiebolag (“Bergman & Beving” or “we”), process personal data relating to individuals who visit and use our digital platforms and services and who otherwise come into contact with us. In this information policy, we explain how we handle your personal data. The privacy policy also describes your rights in relation to us and how you may exercise those rights with regard to the processing of your personal data.
2 Who is the data controller?
Bergman & Beving is the data controller for the processing of personal data that is collected.
Our contact details are set out below.
Bergman & Beving Aktiebolag, 556034-8590
Box 10024, SE-100 55 STOCKHOLM
+46 (0)10-454 77 00
If you have any questions regarding our processing of your personal data, please contact us at personuppgifter@bb.se.
3 Personal data we process about you
In your contact with Bergman & Beving, you will provide us with certain information, such as your name and contact details. Your personal data has been obtained either directly from you or from your employer in connection with the business relationship between us and your employer.
We may also obtain your personal data from other sources. For example, we obtain shareholder registers from Euroclear Sweden AB (company registration number 556112-8074) in connection with general meetings.
4 Purpose and legal basis for the processing of your personal data
4.1 General
We process your data in order to communicate with you and to send marketing communications to you. This communication includes the distribution of marketing materials and information about Bergman & Beving (such as press releases, financial reports, newsletters, and invitations to events and lectures), as well as responding to questions from you (for example, when you contact us or submit a query via forms available on our website or by email). The processing is carried out on the basis of a balancing of interests and our legitimate interest in providing information you have requested from us, maintaining a business relationship with you or your employer, and/or providing materials and/or communicating with you in your professional capacity regarding information and events that we believe may be of interest to you. If you would like more information about how this balancing of interests has been conducted, you are welcome to contact us. Where you have provided your consent, we instead process your data for the above purposes on the basis of your consent.
In accordance with the Market Abuse Regulation (EU) 596/2014, listed companies must maintain a list of persons who are employed by the company, persons who are in a contractual relationship with the company, or persons who otherwise (for example as a counterparty in negotiations) have access to inside information concerning the company. In order to fulfil our obligations relating to these so-called insider lists, we will process personal data relating to such individuals when required.
On our website, we provide a whistleblowing service in accordance with applicable laws. The service enables individuals to report suspicions of serious misconduct. You, as the reporting person, may remain completely anonymous when using the service. Where processing takes place, it is based on a balancing of interests, where our legitimate interest is that the whistleblowing service provides an opportunity to report suspected serious misconduct and constitutes an important channel for safeguarding good corporate governance and maintaining the confidence of customers and the public. Personal data relating to criminal offences is processed solely in respect of key individuals or persons in senior positions, in accordance with the guidelines of the Swedish Data Protection Authority.
In some cases, the provision of your personal data is a statutory or contractual requirement. If you do not provide us with your personal data, this may affect our ability to fulfil our obligations towards you and our obligation to comply with applicable legal requirements in relation to you.
4.2 Specifically for you as a shareholder or an employee of a shareholder (including shareholder representatives such as proxies, assistants, and nominees)
In addition to the general information set out in section 4.1, we process your personal data as a shareholder or an employee of a shareholder (including shareholder representatives such as proxies, assistants, and nominees), where applicable, as follows.
For the following purposes, we process your personal data in order to fulfil a legal obligation:
To fulfil our obligations to maintain an insider list concerning how you, as a shareholder, and your closely associated persons trade in shares under the Market Abuse Regulation (EU) 596/2014, for example if you perform duties in a managerial position. Where data relating to your closely associated persons is processed, you are responsible for informing them by email, with a copy sent to personuppgifter@bb.se. The information must include this policy.
To fulfil the requirements regarding reporting and registration of closely associated persons with the Swedish Financial Supervisory Authority (Finansinspektionen) under the Market Abuse Regulation (EU) 596/2014. Where data relating to your closely associated persons is processed, you are responsible for informing them by email, with a copy sent to personuppgifter@bb.se. The information must include this policy.
To fulfil our other obligations as a listed company, including the preparation of the share register, keeping minutes, convening general meetings, preparing voting lists, and registering voting rights.
To fulfil our obligation to maintain accounting records in accordance with the Swedish Accounting Act (1999:1078).
For the following purposes, we process your personal data on the basis of a balancing of interests:
Publication of information in accordance with rules and guidelines for listed companies that are not legally binding, for the purpose of increasing transparency and insight into our operations.
Internal and external publication of the names of certain shareholders and information about them in news items.
Publication of information regarding shareholdings on the website.
Publication of information regarding members of the nomination committee on the website.
Dividend distributions.
Personal data relating to you as an employee of a shareholder is processed in accordance with the agreement with the shareholder for the purposes of administration and performance of our agreement with the shareholder (your employer). Bergman & Beving’s legitimate interest is to administer the agreement and fulfil our obligations towards the shareholder (your employer).
Publication on the website of information from the Swedish Financial Supervisory Authority’s register of insider transactions.
Our legitimate interests include publishing information about Bergman & Beving in accordance with non-statutory guidelines for listed companies, such as the Swedish Corporate Governance Code. We also have a legitimate interest in being able to communicate internally and externally with information relating to Bergman & Beving in order to provide good service, respond to inquiries, and facilitate external contacts.
The above provisions in this section 4.2 shall, where applicable, also apply to shareholder representatives such as proxies, assistants, and nominees.
4.3 Specifically for you as a customer or an employee of a customer
In addition to the general information set out in section 4.1, we process your personal data as a customer or an employee of a customer, where applicable, as follows.
For the following purposes, we process your personal data in order to perform our agreement or take steps at your request prior to entering into an agreement:
In your contact with us as a customer and when using our services and purchasing our products, we process your personal data for the administration and performance of our agreement with you.
For the following purposes, we process your personal data in order to fulfil a legal obligation:
To fulfil our obligations to maintain an insider list concerning how you and your closely associated persons trade in shares under the Market Abuse Regulation (EU) 596/2014. Where data relating to your closely associated persons is processed, you are responsible for informing them by email, with a copy sent to personuppgifter@bb.se. The information must include this policy.
To fulfil our obligation to maintain accounting records in accordance with the Swedish Accounting Act (1999:1078).
We process personal data relating to you and your purchases in light of our obligations under applicable sales and consumer sales legislation.
For the following purposes, we process your personal data on the basis of a balancing of interests:
Personal data relating to you as an employee of a customer is processed in accordance with the agreement with the customer for the purposes of administration and performance of our agreement with our customer (your employer). Bergman & Beving’s legitimate interest is to administer the agreement and fulfil our obligations towards our customer (your employer).
4.4 Specifically for you as an employee of a supplier
4.4.1 General
In addition to the general information set out in section 4.1, we process your personal data as an employee of a supplier, where applicable, as follows.
For the following purposes, we process your personal data in order to fulfil a legal obligation:
To fulfil our obligations to maintain an insider list concerning how you and your closely associated persons trade in shares under the Market Abuse Regulation (EU) 596/2014. Where data relating to your closely associated persons is processed, you are responsible for informing them by email, with a copy sent to personuppgifter@bb.se. The information must include this policy.
To fulfil our obligation to maintain accounting records in accordance with the Swedish Accounting Act (1999:1078).
For the following purposes, we process your personal data on the basis of a balancing of interests:
Personal data relating to you as an employee of a supplier is processed in accordance with the agreement with the supplier for the administration and performance of the contractual relationship. Our legitimate interest is to administer the agreement and fulfil our obligations towards our supplier (your employer).
4.4.2 Specifically for you as an employee of our audit firm
In addition to the general information set out in sections 4.1 and 4.4.1, we process your personal data as an employee of our audit firm, where applicable, as follows.
For the following purposes, we process your personal data in order to fulfil a legal obligation:
To fulfil our other obligations as a listed company, including the handling of remarks, preparation of the annual report, preparation of the audit report, registration of the auditor with authorities, keeping minutes, and other purposes stipulated by law, including the Swedish Companies Act (2005:551).
For the following purposes, we process your personal data on the basis of a balancing of interests:
Internal and external publication of the auditor’s name. Our legitimate interest is to increase transparency and insight into our operations.
4.5 Specifically for you as an analyst
In addition to the general information set out in section 4.1, we process your personal data as an analyst, where applicable, as follows.
For the following purposes, we process your personal data on the basis of a balancing of interests:
Internal and external publication of analysts’ names. Our legitimate interests are to publish information about the company in accordance with non-statutory guidelines for listed companies, such as the Swedish Corporate Governance Code, to provide transparency and insight into our operations, and to make available information regarding the scrutiny to which Bergman & Beving is subject.
5 With whom may we share your personal data?
The personal data collected may be transferred to system providers, payroll administrators, banks, auditors, insurance brokers, insurance companies, pension administrators, and other suppliers that provide services to the Company. These recipients act as data processors and are only entitled to process your personal data on behalf of Bergman & Beving in connection with performing services for Bergman & Beving, such as delivering an ordered product to you. Bergman & Beving takes all reasonable legal, technical, and organizational measures to ensure that your data is handled securely and with an adequate level of protection when transferred to or shared with such selected third parties.
Bergman & Beving may also disclose your personal data to authorities, such as the Swedish Financial Supervisory Authority, if required to do so by law. If all or part of Bergman & Beving’s operations are divested, Bergman & Beving may transfer your personal data to a potential purchaser of the business. These recipients will act as independent data controllers for their own processing.
6 Transfer of personal data outside the EU/EEA
We and our suppliers and partners generally process your personal data only within the EU/EEA. In cases where personal data is processed outside the EU/EEA, either a decision by the European Commission exists stating that the third country ensures an adequate level of protection, or appropriate safeguards are in place, such as standard contractual clauses, binding corporate rules, or the Privacy Shield, ensuring that your rights are protected. If you would like a copy of the safeguards we have implemented or information on where they are available, you may obtain this by contacting us at personuppgifter@bb.se.
7 How long we retain your personal data
7.1 General
We never process your personal data for longer than permitted under applicable law, regulations, practice, or authority decisions. Personal data processed for the purpose of performing our agreement with you is generally processed for as long as necessary to administer the contractual relationship, exercise our rights, and fulfil our obligations towards you. However, in order to comply with legal requirements, where you have provided your consent, or where we are entitled to do so on the basis of a balancing of interests, we may retain your personal data for a longer period as set out below.
Personal data processed to fulfil the obligation to maintain insider lists under the Market Abuse Regulation (EU) 596/2014 is processed in accordance with the Regulation and general limitation rules under the Swedish Limitation Act (1981:130).
Personal data processed on the basis of consent is retained until you withdraw your consent.
Personal data processed on the basis of a balancing of interests for the purpose of communicating with you or publishing information about Bergman & Beving and its operations is retained for as long as the matter is ongoing or the purpose remains.
Personal data processed on the basis of a balancing of interests for marketing purposes is retained in accordance with applicable national law and practice and varies depending on your relationship with Bergman & Beving:
a) if you subscribe to our communications, your data is processed until you notify us that you no longer wish to receive them;
b) if you have a customer relationship with us but do not subscribe to our communications, your data is processed for a maximum of one (1) year after the customer relationship has ended or until you notify us that you no longer wish to receive communications;
c) if you are not an active customer and do not subscribe to our communications, your data is processed for a maximum of three (3) months or until you notify us that you no longer wish to receive communications.Information, images, and news items published on the website on the basis of our legitimate interest are retained as long as they have news value and the purpose remains, for example to inform the public and investors.
7.2 Specifically for you as a shareholder or an employee of a shareholder (including shareholder representatives such as proxies, assistants, and nominees)
In addition to the general retention periods set out in section 7.1, we retain your personal data as a shareholder or an employee of a shareholder, where applicable, as follows:
Personal data processed for dividend payments or other purposes required under the Swedish Accounting Act (1999:1078) is retained for seven (7) years.
Processing to fulfil our obligations to maintain an insider list under the Market Abuse Regulation (EU) 596/2014 is retained in accordance with the Regulation and general limitation rules under the Swedish Limitation Act (1981:130).
Information relating to your closely associated natural and legal persons processed to fulfil legal obligations under the Market Abuse Regulation (EU) 596/2014 is retained for five (5) years.
Personal data relating to you as an employee of a shareholder is processed as long as you are employed by the shareholder and the purpose of the processing remains. If you cease to be a contact person or employee of the shareholder, the processing will cease as soon as we are informed.
7.3 Specifically for you as a customer or an employee of a customer
In addition to the general retention periods set out in section 7.1, we retain your personal data as a customer or an employee of a customer, where applicable, as follows:
Personal data processed to perform our agreement with you or your employer is generally retained for as long as necessary to administer the contractual relationship, exercise our rights, and fulfil our obligations. If your employment with the customer ends or the assignment ceases, processing will end as soon as we are informed. Inactive agreements containing your personal data are retained for ten (10) years in accordance with general limitation rules under the Swedish Limitation Act (1981:130).
Personal data processed for purposes required under the Swedish Accounting Act (1999:1078) is retained for seven (7) years.
Personal data relating to you as an employee of a customer is processed as long as you are employed by the customer and the purpose remains.
Certain data relating to your purchase is processed in accordance with applicable sales or consumer sales legislation.
Processing to fulfil obligations to maintain an insider list under the Market Abuse Regulation (EU) 596/2014 is retained in accordance with the Regulation and general limitation rules.
Information relating to your closely associated persons processed to fulfil legal obligations under the Market Abuse Regulation (EU) 596/2014 is retained for five (5) years.
7.4 Specifically for you as an employee of a supplier
7.4.1 General
In addition to the general retention periods set out in section 7.1, we retain your personal data as an employee of a supplier, where applicable, as follows:
Personal data processed to perform our agreement with you or your employer is generally retained for as long as necessary to administer the contractual relationship, exercise our rights, and fulfil our obligations. If your employment with the supplier ends or the assignment ceases, processing will end as soon as we are informed. Inactive agreements containing your personal data are retained for ten (10) years in accordance with general limitation rules under the Swedish Limitation Act (1981:130).
Personal data processed for purposes required under the Swedish Accounting Act (1999:1078) is retained for seven (7) years.
Processing to fulfil obligations to maintain an insider list under the Market Abuse Regulation (EU) 596/2014 is retained in accordance with the Regulation and general limitation rules.
Information relating to your closely associated persons processed to fulfil legal obligations under the Market Abuse Regulation (EU) 596/2014 is retained for five (5) years.
7.4.2 Specifically for employees of an audit firm
In addition to the general retention periods set out in section 7.1 and section 7.4.1, we retain your personal data as an employee of our audit firm, where applicable, as follows:
Personal data required to fulfil our obligations as a listed company, including the handling of remarks, preparation of annual reports and audit reports, registration of auditors with authorities, keeping minutes, and other statutory purposes, including those under the Swedish Companies Act (2005:551), is retained for as long as required by law or general limitation rules under the Swedish Limitation Act (1981:130).
7.5 Specifically for you as an analyst
In addition to the general retention periods set out in section 7.1, we retain your personal data as an analyst, where applicable, as follows:
Personal data relating to you as an analyst is processed for as long as you act as an analyst in relation to us and the purpose of the processing remains.
8 Security of personal data
We safeguard a high level of security for your personal data and have implemented appropriate technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction.
9 Your rights
In accordance with applicable data protection legislation, you have the right to access information about the personal data we process about you and to request correction of your personal data.
Under certain conditions, you also have the right to request erasure or restriction of your personal data or to object to our processing. You also have, under certain conditions, the right to receive the personal data concerning you that you have provided to us in a structured, commonly used, and machine-readable format and the right to transfer such data to another data controller (data portability).
You have the right to withdraw all or part of a consent you have given for the processing of personal data at any time, with effect from the time of withdrawal. You also have the right to object at any time to the processing of your personal data for direct marketing purposes.
If you have any complaints regarding our processing of your personal data, you have the right to lodge a complaint with the Swedish Data Protection Authority or another competent supervisory authority.
To request access, data portability, rectification, erasure, objection, or restriction, please contact us at personuppgifter@bb.se.
10 Cookies
10.1 Why we use cookies
Cookies are small text files placed on your computer or mobile device when you visit a website. Cookies help our digital channels recognize your device and remember information about your visit (such as preferred language, font size, and other settings).
10.2 How to decline the use of cookies
You can refuse the use of cookies by adjusting or selecting certain settings in your web browser. Please note that doing so may result in the loss of certain useful features, such as personalization of the digital channels and “remember me” functions.