Privacy & cookie policy

Privacy policy

1. INTRODUCTION

Eastnine recognizes the importance of protecting the privacy of your personal data. We have instituted strict policies and security measures to protect the information you provide us.. 

The purpose of this privacy policy is for you to learn how Eastnine handles your personal data and for you to be able to feel secure that the processing is being carried out in accordance with the General Data Protection Regulation and other applicable data protection law. The privacy policy also describes your rights vis-à-vis us and how you can enforce those rights.

This privacy policy is aimed towards the following categories:

a) Tenants

b) Website users

c) Contact persons of Collaborators

2. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?

The Swedish company Eastnine AB (publ), reg. no. 556693-7404 (“Eastnine”, "We", "Us"), is the controller of your personal data. Eastnine’s affiliated companies (including other companies within the Eastnine group, joint ventures, franchisees and licensees) and selected suppliers may process your personal data on Eastnine’s behalf and in accordance with Eastnines’ instructions as stated below and are thereby processors of your personal data.

You may contact Eastnine at any time, please find our contact details below.

Address: Box 7214, 103 88 Stockholm
Phone: +46 8 505 97 700
E-mail:  [email protected]

3. CATEGORIES OF DATA PROCESSED, PURPOSE AND LEGAL BASIS FOR PROCESSING

3.1 General

Below is a summary of the categories of data that we process, the purposes of processing the data and on what legal basis we are processing your data.

3.2 Tenants

3.2.1 Contact person of tenant

In your role as the contact person of one of Eastnine’s tenants, Eastnine will collect and process your name, work title, email address, and phone number for the purpose of enabling Eastnine to manage the relationship with the tenant, meaning e.g. administering and exercising its rights and obligations under the agreement with the tenant and to otherwise communicate with the tenant and to conduct its business. The legal basis for the processing is a balancing of interests, where Eastnine’s legitimate interest is to be able to contact its tenants and otherwise administer the tenancy.

Furthermore, Eastnine may process your personal identification number, passport information and a copy of your passport for the purpose of ensuring your identity and to prevent illegal activities in relation to the tenancy, for example money laundering. The legal basis for the processing is that it is necessary for Eastnine’s compliance with a legal obligation.

Eastnine may also process your e-mail address and phone number for direct marketing purposes, namely to keep you informed of services, special events or promotions. This processing is based on the “balancing of interests” legal basis, where Eastnine’s legitimate interest is to be able to market its products and services with relevant marketing to its existing customers.

3.2.2 Tenants being physical persons

If you are a tenant at one of Eastnine’s premises, Eastnine will process your name, address, phone number, e-mail and bank account in order to enable Eastnine to contact you, receive payment and otherwise administer the tenancy. The legal basis for the processing is that it is necessary for the performance of the tenancy agreement.

Eastnine may also process your e-mail address and phone number for direct marketing purposes, namely to keep you informed of services, special events or promotions. This processing is based on the “balancing of interests” legal basis, where Eastnine’s legitimate interest is to be able to market its products and services with relevant marketing to its existing customers.

3.2.3 Key tags/Personal access code

If you use a personal key tag/access code to enter Eastnine’s premises, Eastnine may process your name, employee-ID and access clearance for the purpose of enabling Eastnine to assign a personal key tag/access code to you as an employee. Furthermore, Eastnine may process the time and extent of your visits to the premises for the purpose of enabling Eastnine to maintain security at its premises. The processing is based on a balancing of interests, where Eastnine’s legitimate interest is to maintain security at its premises.  

3.2.4 Person visiting the premises

If you visit our facilities, Eastnine may process your image through the use of security cameras, so called CCTV. The purpose for this processing is to enable Eastnine to control access to and to ensure the security of its facilities, ensure the safety of visitors as well as property and information located or stored on the premises and to prevent, detect and investigate illegal activities, such as theft and damages to property. The processing is based on a balancing of interests, where Eastnine’s legitimate interest is to enable Eastnine to monitor the access and safety of its facilities and any person and property located at such facilities.

Please note that CCTV is not used for any other purpose, such as to monitor visitors or in order to obtain evidence in internal evaluations or disciplinary procedures.

3.3 Website Users

If you contact us using the contact information available at the website, we will process your email address, as well as any information provided in such communication, e.g. your name. The purpose of the processing is to enable Eastnine to communicate with persons interested in its services. The processing is based on a balancing of interests, where Eastnine’s legitimate interest is to be available for inquiries from persons interested in Eastnine’s services. 

If you visit the website www.eastnine.com and consent to the placing of cookies, we may process your IP-address to locate from where in the world you are visiting from. The purpose of the processing is to gather data for statistical purposes and to enable security. The legal basis for the processing is a balance of interests where our legitimate interest is to improve our services through the use of statistics over visitors of the website and to facilitate the security of the website and its visitors.

Please note that your IP-address does not directly identify you as an individual. However, by cross-referencing your IP-address with additional available information, your identity may be revealed. Eastnine will not seek to identify you as a website user.

3.4 Contact persons Collaborators

As the contact person of one of Eastnine’s suppliers, resellers, company customers or other legal persons with whom Eastnine collaborates (“Collaborators”), Eastnine will process your name, telephone number and email address. Eastnine processes the personal data for the purpose of being able to manage the relationship with the Collaborator, meaning e.g. administering and exercising its rights and obligations under the agreement with the Collaborator, place or manage orders or provided services, and to otherwise enable Eastnine to communicate and conduct its business. The processing is based on a balancing of interests, where Eastnine’s legitimate interest is to administer its contractual obligations and rights, communicate with and otherwise maintain a good relationship with the Collaborator.

If you work with Eastnine as a sole proprietorship (Sw. Enskild firma) Eastnine processes your name, telephone number, email address and personal identity number (since it is the same as the sole proprietorship’s registration number). Eastnine processes the data for the purpose of being able to manage the relationship with the Collaborator, meaning e.g. administering and exercising its rights and obligations under the agreement with the Collaborator, place or manage orders or provided services, and to otherwise enable Eastnine to communicate and conduct its business. The legal basis for the processing is that it is necessary in order for Eastnine to fulfill its contractual obligations towards the sole proprietorship.

3.5 Anonymized data

It can be noted that we may also use anonymized data for statistical purposes.

4. DOES EASTNINE SHARE YOUR INFORMATION WITH OTHERS?

Eastnine does not sell or license our customers’ personal data to any other entity.

We may share your data with affiliated companies including other companies within the Eastnine group, joint ventures, franchisees and licensees. Eastnine may also share your data with selected suppliers who perform functions on our behalf such as providing technical measures for our online services, delivery of orders, processing payments, carrying out promotional services or data management, to maintain our website, to distribute e-mails, to send out our newsletter, to provide client communications and to manage our customer database. As necessary, the personal data you provide to us may be processed by these third parties, solely on Eastnine’s behalf and in accordance with Eastnine’s instructions to the data processor. We do not authorize any of our suppliers to make any other use of your personal data.

If Eastnine and/or its subsidiaries are subject to an actual or potential merger or acquisition or similar transaction, we may share your data with potential and actual buyer(s) and their financial and legal advisers, subject to such third parties undertaking appropriate confidentiality.

Eastnine may also disclose your personal data to a public authority where Eastnine is obligated to do so by law. In the event all or part of Eastnine’s operations are sold, Eastnine may transfer your personal data to a potential purchaser of the business.

5. WHERE IS YOUR PERSONAL DATA PROCESSED?

Your personal data will be processed primarily within the EU/EEA, but may be transferred to countries outside of the EU/EEA if the service providers that process data on behalf of Eastnine transfer the data to such locations.

Please note that countries outside of the EU/EEA may not provide an adequate level of protection for your personal data. Eastnine has however taken appropriate safeguards to ensure that the receiving parties of your data in countries outside of the EU/EEA shall provide an adequate protection of your data. Such safeguards may be that the receiving party has signed so called standard data protection clauses adopted by the EU Commission together with an assessment of whether the safeguards in the applicable standard contractual clause, in relation to the recipient’s country’s applicable law, grants the data subject its rights in accordance with GDPR.

Please contact us at [email protected] if you want further information on what safeguards have been taken and if you want a copy of such safeguards.

6. HOW LONG DO WE KEEP YOUR DATA?

6.1 General

Notwithstanding anything to the contrary herein, Eastnine reserves the right to keep and process your personal data in accordance with this policy to the extent necessary to defend ourselves in a dispute or to fulfil a legal obligation.

6.2 Tenants

6.2.1 Contact person of tenant

a) Eastnine will retain your name and contact information in our register of contact persons during the tenancy or if we otherwise require the data for any matter related to the tenancy. If you notify us that you no longer is the contact person of the tenant, we will delete your data from our register of contact persons within one month.

b) Your data (for example your name) may be found in agreements, correspondence or other documentation regarding the tenancy which Eastnine needs to save for commercial, business or legal reasons. The processing is based on Eastnine’s legitimate interest to store such documentation to the extent it is of commercial, business or legal significance to Eastnine’s business operations. This data will be stored for as long as it is necessary for the reasons mentioned.

6.2.2 Tenants being physical persons

Eastnine will retain your name, contact information and payment details during the tenancy or if we otherwise require the data for any matter related to the tenancy. Your personal data (for example your name) may be found in agreements, correspondence, or other documentation regarding the tenancy which Eastnine needs to save for commercial, business, or legal reasons. The processing is based on Eastnine’s legitimate interest to store such documentation to the extent it is of commercial, business, or legal significance to Eastnine’s business operations. This data will be stored for as long as it is necessary for the reasons mentioned.

6.2.3 Key tags/Access codes

Personal data used to assign a personal key tag/access code to you is stored for as long as you are entitled to a key tag/access code. Personal data in relation to your visits to Eastnine’s premises is stored for up to 2 months in order to enable Eastnine to maintain access logs to its premises in the event of any accidents, damages etc.

6.2.4 Person visiting the premises

Images from the CCTV surveillance will be stored for up to 2 months. After such time, the footage will be automatically deleted.

However, Eastnine may store the footage for a longer period of time if it is necessary to establish, enforce or defend against legal claims, for example in relation to damages to the property or persons visiting the premises.

6.3 Website users

Your IP-address will be deleted no later than six (6) months after your last visit on our website or be anonymized in order to be used for statistical purposes. It is necessary to store the information in order to produce event-logs in the event of security incidents, to maintain the website’s quality and to analyse how the website is used in order to focus improvement work.

6.4 Contact persons Collaborators

Eastnine will retain your name and contact information in our register of contact persons while our contractual relationship with the Collaborator is active or if we otherwise require the data for any matter related to our contractual relationship with the Collaborator. If you notify us that your employment with the Collaborator has terminated or that you should no longer be the contact person, we will delete your data from our register of contact persons within one month.

Your data (for example your name) may be found in agreements, correspondence or other documentation regarding Eastnine’s relationship with the Collaborator which Eastnine needs to save for commercial, business or legal reasons. The processing is based on Eastnine’s legitimate interest to store such documentation to the extent it is of commercial, business or legal significance to Eastnine’s business operations. This data will be stored for as long as it is necessary for the reasons mentioned.

Eastnine may also save your personal data for a longer period of time where necessary in order to fulfill a legal obligation which requires processing according to applicable law or in order for Eastnine to be able to establish, enforce, or defend against legal claims, for example in relation to confidentiality and liability provisions that outlive the termination of the contract with a Collaborator.

7. YOUR DATA SUBJECT RIGHTS

In this section 7, we have summarized your data subject rights to request access, portability, rectification, erasure of your personal data, to restrict the processing of your personal data, to object to processing, and your right to lodge a complaint with the supervisory authority.

If you want to exercise your rights, please send us an e-mail to [email protected]. Please note however that if you want to lodge a complaint with the supervisory authority, you need to contact the authority directly.

7.1 Right of access

You have the right to obtain confirmation of whether personal data concerning yourself is being processed and, where that is the case, access to the personal data and information regarding, inter alia, the purpose of processing, the categories of personal data concerned, the categories of recipients to whom your data have been or will be disclosed, and the envisaged period of time for which personal data will be stored (or the criteria for determining this).

7.2 Right of rectification

You have the right to request rectification of inaccurate personal data concerning yourself, and to complete incomplete data.

7.3 Right of erasure and right of restriction

Under certain circumstances you are entitled to request that we erase your personal data or restrict our processing of your data, namely in the following events.

a) When it is no longer necessary for us to process your data taking into consideration the purposes for which it was collected. 

b) When our processing is based on your consent and you have withdrawn your consent, and there is no other legal basis for the processing of your data.

c) When our processing of your data is based on a legitimate interest legal basis and you object to such processing, and there is no overriding legitimate ground for our processing.

d) When you have objected to our processing of your data for direct marketing purposes.

e) When your personal data has been unlawfully processed.

f) When the personal data must be erased for compliance with a legal obligation that applies to us.

g) When the personal data collected concerns a child (under 13 years of age) in relation to the offer of information society services.

7.4 Right to objection

Under certain circumstances you have the right to object to our processing of your data, whereupon we shall no longer process your data unless we can demonstrate compelling legitimate grounds for the processing. 

7.5 Data portability

If our processing is based on your consent or if the processing is necessary for our performance of a contract with you, you have the right to request that the data which you have provided to us shall be provided to you in a structured, commonly used and machine-readable format and you also have the right to transmit such data to another controller.

7.6 Right to lodge a complaint with supervisory authority

Please note that if you consider the processing of your data to be in violation of applicable data protection laws, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence or the place of the alleged infringement (see http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm).

8. COOKIES AND SIMILAR TECHNIQUES

As already mentioned, we use cookies on our website. Please see our separate policy about the placement of cookies, which you can find on our website.

9. MODIFICATIONS

Eastnine reserves the right to occasionally make changes to our privacy policy or practices. We will post the updated policy on our website, and thus we encourage you to review this page from time to time.

10. RESPONSIBILITY

Responsibility for implementation of this policy: CEO

Responsibility for implementation control: CFO

Responsibility for review: Board of Directors

Time for review: Annually or as needed.

11. DISTRIBUTION

Internally within the Group and externally.

---