1. GENERAL INFORMATION 

1.1 CSV Rating AB, company registration number 556860-7468 having its registered address at Humlegårdsgatan 5, 114 46 Stockholm, Sweden (“CSV Rating” “we” or “us”). This document contains a policy statement regarding CSV Rating’s collection, use, and processing of Personal Data (“Privacy Policy”). This privacy policy is applicable when you subscribe to our newsletter or download resources (the “Community”) and become a “Subscriber” and/or when you are a “User” of the Kodiak Hub Platform (the “Platform”). 

1.2 All definitions in this Privacy Policy shall be interpreted in accordance with applicable data protection laws which refers to the Swedish Personal Data Act (2018:218), which implements the EU directive 95/46/EC, and the General Data Protection Regulation (Regulation no. 2016/679) and the Directive on Privacy and Electronic Communications (Directive 2002/58/EC), as well as the national implementations and related national legislation.

2. PROCESSED DATA 

2.1 We will process the following categories of personal data regarding Subscribers: (a) contact details such as name and email address; (b) IT-data such as IP address; (c) Subscription and Platform related data such as date of subscription; (e) Employment-related data such as job title and company name. 

 2.2 For Users we process all personal data as set forth above and also your phone number. 

2.3 We are unable to provide you with the Platform or the Community unless you provide us with the personal data above (except for the IP address and phone number).

 3. PURPOSES OF PROCESSING 

We will process the personal data set out above to provide you the Community and the Platform as well as to send relevant information via emails to you. Also, we process your IP address for maintaining and improving the functions of the Platform.

4. LEGAL GROUND 

4.1 The processing of personal data regarding Users for the purposes of providing, maintaining and improving functions on the Platform and sending information is conducted on the basis of a contractual relationship and the legitimate interest of the CSV Rating. Our legitimate interest for the processing is to provide the Platform and to send relevant information the regarding our services and related information to Users. 

4.2 By subscribing to the Community and clicking the consent-box you consent to the processing of the personal data set forth under Section 2.1 above. 

 5. DISCLOSURE OF PERSONAL DATA 

5.1 We share and disclose the following personal data: name, email address, job title, phone number, company name, IP address, to email service providers and sales service providers to be able to provide you with the information and marketing as well as to administrate the Platform. 

HubSpot USA Applied safeguard: EU-U.S. Privacy Shield https://www.privacyshield.gov/participant?id=a2zt0000000TN8pAAG&status=Active

5.2 The recipients above are located outside the EU/EEA and we are therefore applying specified safeguards for the data transfers as set forth in the General Data Protection Regulation (Regulation no. 2016/679). You can acquire further information regarding the transfer by contacting us. 

 5.3 When using the Platform you may be directed to other websites where the personal data collected is not in our control. The privacy policy of the other website will govern the personal data obtained from you on that website. 

 6. RESPONDING TO LEGAL REQUESTS AND PREVENTING HARM 

We may access, preserve and share your personal data in response to a legal request (like a search warrant, court order or a subpoena or the like), or when necessary to detect, prevent and address fraud and other illegal activity, to protect ourselves, you and other users, including as part of investigations. 

 7. RETENTION 

We store personal data regarding Subscribers for as long as there is an active subscription to the Community. We store personal data regarding Users until the termination of the contract regarding the Platform. 

YOUR RIGHTS

7.1 You have an absolute right to object to the processing of your personal data for direct marketing. You also have the right to recall your prior given consent. The withdrawal of your consent does not affect the lawfulness of the processing based on the consent before its withdrawal, and we may continue processing your personal data based on other legal grounds, except for direct marketing. 

 7.2 You have the right to request access and further information concerning the processing of your personal data or request that we correct, rectify, complete, erase or restrict the processing of your personal data. You have the right to obtain a copy of the personal data that we process relating to you free of charge once (1) every calendar year. For any additional copies requested by you, we may charge a reasonable fee based on administrative costs. 

7.3 If the processing is based on the legal grounds consent or fulfillment of contract you have the right to data portability. Data portability means that you can receive the personal data that you have provided to us, in a structured, commonly used and machine-readable format, and have the right to transfer such data to another data controllers. 

 8. CONTACT INFORMATION 

 8.1 To exercise your rights, such as revoking consent, or if you have any questions regarding our processing of your personal data, please contact us at the following address: info@kodiakrating.com or CSV Rating, Humlegardsgatan 5, 114 46 Stockholm, Sweden. In your letter/email please state your full name and email address. Note that you should sign the request to receive information of the processing of your personal data yourself. 

8.2 If you have any complaints regarding our processing of your personal data, you may file a complaint to the competent data protection authority. You can find out more about the local data protection authorities under the following link http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. 

9. NOTICE OF CHANGES TO THE PRIVACY POLICY 

If we make changes to this Privacy Policy we will notify you by email and through our website. If your consent is required due to the changes, we will provide you with additional prominent notice as appropriate under the circumstances and, ask for your consent in accordance with applicable law.