Privacy Policy

1. Introduction

1.1 Purpose of the Policy

This Privacy Policy outlines how Sareq AB ("Sareq," "we," "us," "our"), with organization number 559147-1619, as the data controller, processes personal data when you use our website (”www.sareqinvest.se”), when we perform our services, or when you contact us regarding this privacy policy.

1.2 Scope and Applicable Laws and Regulations

Sareq is responsible for ensuring that we handle your personal data in compliance with relevant laws, particularly the General Data Protection Regulation (EU) 2016/679, Directive (EU) 2002/58/EC, and other applicable data protection legislation in Sweden (referred to collectively here as "applicable data protection laws"). We will provide an updated version of the privacy policy in case of significant changes to our privacy practices or data security procedures.

2. Collection of Personal Data

2.1 Types of Personal Data Collected

Sareq processes the following categories of personal data:

  • Contact information such as name, address, phone number, email address, title, and position, company name.
  • Recruitment information such as CVs, cover letters, and other information related to recruitment or the start of a consultancy assignment.
  • Personal data obtained in connection with the acquisition and management of companies ("Acquisition Data"). This may include names, titles, personal identification numbers, contact details, billing information, or other business-related information.
  • Other information you provide when communicating with us regarding the Website or otherwise.

Please note, only share necessary personal data for your inquiry.

2.2 Purposes and Legal Basis for Collection and Processing of Personal Data

Sareq processes the above categories of personal data for the following purposes and legal bases:

  1. Recruiting staff and commencing consultancy assignments. This includes general information, contact details, and professional information such as applications, degree certificates, interview forms, personality tests, creditworthiness, pre-employment screening, and other relevant information to assess qualifications. The legal basis for this processing is GDPR Article 6(1)(b) as processing is necessary for the preparation of employment contracts.
  2. Assessing suitability and qualifications for the position. For certain positions, this may include information about bankruptcy proceedings, fines, criminal investigations, prosecutions, convictions, and tax status. The legal bases for this processing are GDPR Article 9(2)(b) and Article 6(1)(b) as processing is necessary for the obligations and exercising of rights in the field of employment law. Such data is considered special categories of personal data under GDPR, and specific measures will be taken to ensure adequate data protection.
  3. Conducting acquisitions and managing companies. Personal data processed in this context mainly relates to employees, board members, customers, sellers, and other individuals. The legal basis for this processing is GDPR Article 6(1)(f) as it is necessary for our legitimate interests in acquiring and managing companies.
  4. Ensuring our legal obligations. Such personal data may include information related to AML/KYC, proprietary trading, gifts, and agreements with suppliers and service providers. The legal basis for this processing is GDPR Article 6(1)(c) where processing is necessary to comply with our legal obligations.
  5. Assisting potential or existing investors in due diligence processes. This may involve collecting personal information such as individuals' names, roles, education, age, experience, contact details, and similar. The purpose is to facilitate financing and investment decisions. The legal basis for this processing is GDPR Article 6(1)(f).
  6. Marketing our business and contacting potential suppliers, partners, and other stakeholders. Personal data processed in this context primarily includes contact information. This processing is necessary for our legitimate interests in marketing our business.
  7. Sending newsletters, press releases, and financial reports to you if you subscribe. Personal data processed here primarily includes contact information such as name and email address. This processing is based on your consent when you subscribe to newsletters, press releases, or financial reports.
  8. Establishing, exercising, or defending legal claims. Personal data processed in this context primarily includes contact information and other information necessary to establish, exercise, or defend legal claims.
  9. Communicating with you when you contact us. Personal data processed here primarily includes contact information and other information you provide when communicating with us. This processing is necessary for our legitimate interests in responding to your inquiry. Please do not share more personal data than necessary for your request.

2.3 External Sharing of Personal Data with Third Parties

Personal data may be transferred to countries outside the European Union/European Economic Area ("EU/EEA"). In such cases, we ensure compliance with applicable data protection laws and use adequate safeguards, such as EU Commission Standard Contractual Clauses and any additional measures.

We may have legal obligations requiring us to disclose personal data, such as involvement in legal proceedings, compliance with court orders, or responding to requests from authorities. These situations may also include preventing and investigating fraud or other illegal activities to protect our business, you, or other partners, suppliers, or stakeholders, including investigative purposes.

Sareq may choose to share selected personal data with other group companies or related parties, potential owners, shareholders, and advisors in connection with the sale of shares and/or assets of the company, listing on a stock exchange, or other corporate restructuring. Your personal data will only be disclosed if necessary and only if Sareq has a legal basis for such disclosure. Such disclosure is based on our legitimate interests in disposing of and restructuring our business, which is considered to outweigh your privacy interests. Disclosure to external parties is only made to parties who have entered into a confidentiality agreement or otherwise have a statutory obligation of confidentiality.

3. Security Measures to Protect Personal Data

Personal data processed by Sareq in recruitment contexts will be deleted six (6) months after the recruitment process is completed, unless the candidate has consented to Sareq retaining application documentation for a longer period, for example, to match the candidate with similar positions in the future, or if there is a dispute related to the recruitment process or a legal obligation requiring a longer retention period.

Sareq does not process personal data for longer than necessary for the purposes for which the personal data was collected. Personal data processed to comply with applicable law or legal obligations will be retained in accordance with the legal obligations imposed on Sareq, such as obligations under the Accounting Act (1999:1078).

Personal data concerning relationships with partners, suppliers, and other stakeholders will only be retained for as long as necessary for each relationship. When personal data is no longer needed, it will be deleted, unless further storage is required by law or otherwise in line with this privacy policy.

4. Your Rights

You have the right to request information from Sareq about the personal data we process about you, and you also have the right to access this personal data. You have the right to request correction of inaccurate personal data, restriction of processing, and deletion of your personal data. Additionally, you have the right to receive a free copy of the personal data that Sareq processes about you.

You have the right to lodge any complaints with the Swedish supervisory authority, Integritetsskyddsmyndigheten, https://www.imy.se/

5. Contact Us

If you have any questions about our processing of personal data or if you wish to exercise your rights as described above, please contact us at: info@sareqinvest.se. When contacting us to exercise your rights, please provide your full name and contact information so that we can reach you.

6. Changes to the Privacy Policy

This privacy policy may be amended or updated from time to time. The latest version of the privacy policy will be available on the website. If any changes to this privacy policy require your consent, we will provide relevant information and give you an opportunity to consent.

Adopted and issued by Sareq AB on February 20, 2024.