Your personal integrity is important to Alektum Group. To provide you with more transparent and clear 
information on how we process your personal data, we have divided the Privacy Notice into different 
chapters. Depending on if you surf our website, are a subscriber of our newsletter, or if you have 
received a letter from Alektum Group, different parts of the notice will apply to you. In each Privacy 
Note, we describe in more detail what personal data we have about you and how we use it. We have also  
extended the information concerning your rights, for example how to get access to your data, how to 
correct it, and how you can request to terminate the usage of your data.  

Privacy Policy website and newsletter

Please read this Privacy Policy to learn more about how personal data may be collected and processed 
when using our website and subscribing to our newsletter.

Alektum Group (the data controller) is responsible for all personal data. Our company information, 
phone number and contact forms can be found at the bottom of this page.

What information we collect
”Personal data” is information that can be used on its own or with other information to identify, 
contact, or locate a single person, or to identify an individual in context.
 
When interacting with our website, you may be asked to enter your full name, email address, phone 
number, company name, case number or other details to help you with your experience.

Please notice that the information you submit to us will be registered. Therefore, we ask you, 
do not submit any special categories of personal data or “sensitive data”, as defined under 
the GDPR,such as health status, racial or ethnic origin, political opinions, etc. 
 
Our products and services are not aimed at children.

How your personal data is obtained
We collect information from you in the following ways: 
•	When you provide your contact details to us when requesting information about our products or 
        services via our online inquiry forms on this website, but also over the telephone or 
        face-to-face. 
•	When you sign up for our email newsletters.
•	When you download documents from our site. 
•	When you register to attend one of our events or seminars (including webinars).
•	Via openly available public sources (e.g. LinkedIn or company websites). 

How we use your personal data
We may use the information we collect from you when you sign up for our newsletter, respond to 
a survey or marketing communication, surf the website, or use certain other site features in 
the following ways:

•	To track your use of our websites and interaction with our newsletters in order for us to, 
        for example, personalise your experience, allow us to deliver the type of content and product
        offerings in which you are most interested, and to understand which newsletter content is most
        popular with our email audience. (Please also see our Cookie Notice below). Our processing is 
        based on our legitimate interest, which we have balanced with the interests of our visitors, 
        customers, suppliers and business contacts. 
•	To fulfil a query, request for services, and/or to administer our services, including responding 
        to your requests. To administer a contest, promotion, survey or other site feature, to follow up 
        with you after correspondence (email or phone inquiries). Our processing is based on the
        performance of a contract or agreement, and our legitimate interest, which we have balanced with
        the interests of the sender of the request, customers, suppliers and business contacts. 
•	To ask for ratings and reviews of services or products. Our processing is based on our legitimate 
        interest,which we have balanced with the interests of our customers, suppliers and business 
        contacts. 
•	To administer newsletters and invitations. Our processing is based on your consent. If you are a 
        customer of ours or working for a customer of ours, we base our processing on our legitimate
        interest, which we have balanced with the interests of our customers, suppliers and business 
        contacts. 
  
About our newsletters 
If you have signed up for our newsletters, you can unsubscribe from these at any point by clicking the 
unsubscribe link in any mailing you receive from us. Alternatively, you can unsubscribe by submitting 
your request using the contact form that can be found at the bottom of this page. 

About communication via email
Please note! Communication via email involves risks from a security and confidentiality
perspective. You can compare an email to a postcard. Therefore, we ask you: Do not enter
information that is sensitive or that you do not want unauthorised persons to be able 
to see.

How the information is stored and protected and who has access to it
Your personal information is contained behind secured networks and is only accessible by a limited number
of persons who have special access rights to such systems, and are required to keep the information 
confidential. In addition, all sensitive/credit information you supply is encrypted via 
Secure Socket Layer (SSL) technology.

We implement a variety of security measures when a user enters, submits, or accesses their information to
maintain the safety of your personal information.

Third-party disclosure
We do not sell, trade, or otherwise transfer to outside parties your personal data. This does not include
website hosting partners and other parties who assist us in operating our website, conducting our 
business, or serving our users, so long as those parties agree to keep this information confidential. 
We may also release information when its release is appropriate to comply with the law, enforce our site
policies, or protect ours or others’ rights, property or safety.However, non-personally identifiable 
visitor information may be provided to other parties for marketing, advertising, or other uses.

We do not include or offer third-party products or services on our website. 

How long we store your personal data for
We will only retain personal data for as long as is necessary for the purposes we are using it for. How 
long we retain data will vary depending on the purposes it is used for. We routinely update our email 
newsletter lists to ensure those who are not engaged are removed. 

You have control over your personal information – these are your rights
You have a number of rights under the GDPR. 

•	Access: You have the right to access the personal data we may hold about you and the purposes 
        for which we are using it. We may ask for proof of your identity. Upon receipt of such a request,
        we will endeavor to respond to it as soon as possible, at most within one calendar month.
•	Rectification: You have the right to request that we amend any personal data which is incorrect
        or requires updating.
•	Erasure: You have the right to request that we delete any personal information pertaining to
        you. We will assess any deletion request on a case by case basis and will endeavour to respond
        to you as soon as possible, at most within one calendar month. If you have authored any content on
        the Alektum Group and would like this to be deleted, please let us know.
     
If you would like to exercise any of these rights, please use the contact form that can be found at the 
bottom of this page.

External links
Please remember that if you use a link to go from our websites to another website, or request a service
from a third party, this Privacy Notice will no longer apply once you have left this website. Your 
browsing and interaction on any other website is subject to that website’s own rules and policies.

How updates are communicated
You will be notified of any Privacy Notice changes on this page and through website alerts.

Are you dissatisfied with how we process your personal data?
Please let us know!  Use the contact form that can be found at the bottom of this page or email.
info@alektumgroup.com

You can also contact the supervisory authority. In Sweden it is the 
Integritetsskyddsmyndigheten: Datainspektionen, Box 8114, 104 20 Stockholm.  

Cookies
A cookie is a small data file placed on your computer by a website that you visit. The cookie 
stores and transmits information to the server of the website (re)visited from that browser/computer. 
A cookie also has a certain time stamp defining when it expires. (More information about time stamp 
and expiration is available in the section Session cookies and persistent cookies.)

Cookie categories
Cookies can be divided into four categories. Alektum Group uses all of these types of cookies on 
our website.
•	Cookie category: Necessary
        Necessary cookies help make the website useable by enabling basic functions like page 
        navigation. The website cannot function properly without these cookies. 
•	Cookie category: Preferences
        Preference cookies enable the website to remember information that changes the way it behaves
        and looks, like your preferred country/language. 
•	Cookie category: Statistics
        Statistics cookies help website owners understand how visitors interact with the website by
        collecting and reporting information anonymously. 
•	Cookie category: Marketing
        Marketing cookies are used to track visitors across websites. The intention is to display ads
        that are relevant and engaging for the individual user and thereby more valuable for publishers
        and third party advertisers. 
  
Session cookies and persistent cookiesSession cookies
        A session cookie exists only in temporary memory while you navigate the website. Web browsers 
        normally delete session cookies when you close your browser. Unlike other cookies, session
        cookies do not have an expiration date assigned to them, which is how the browser knows to treat
        them as session cookies
•	Persistent cookies
        Instead of expiring when the web browser is closed as session cookies do, a persistent cookie
        expires at a specific date or after a specific length of time. This means that for the cookie’s
        entire lifespan,its information will be transmitted to the server every time you visit the
        website that it belongs to, or every time you view a resource belonging to that website from
        another website (such as an advertisement). 
  
        Persistent cookies are used to record web browsing habits over an extended period of time and 
        keeping users logged in to their accounts to avoid re-entering login information every time 
        they visit.

Managing cookies
If you do not accept the use of cookies, you can turn off cookies through your web browser’s security 
settings. You can also set up the browser to give you an alert every time a site tries to place a cookie
on your computer. Previously stored cookies can be managed via the web browser.

Please see the browser’s help pages for more information on how to view which cookies are stored in your
web browser, how to delete them, and control settings for whether cookies should be accepted or not.
Last updated: 2018-05-24

Contact details of the personal data controller: Alektum Group AB 
(hereafter "Alektum Group"), Nils Ericsonsgata 17, 404 23 Göteborg, 
tel. : 031-730 6075, info@alektumgroup.com 

NB! E-mail carries risks in terms of security and confidentiality. It is comparable to a postcard. 
Therefore, do not give information that is sensitive or that you do not want an unauthorised person to
acquire. 

How your personal data is used. 

Have you received an invoice with the payment details of the Alektum Group? 
 
Alektum Group assists other companies, i.e. our customers, in managing the administration of invoices,
processing payments, sending reminders and, where applicable, providing customer service. In carrying out
these services, we process your personal data on the behalf of our customer. For more detailed 
information on how the personal data is processed, for what purposes, and what rights you have, we would  
ask you to contact the seller -- i.e., your contractual party. The seller’s contact details are always
given on the invoice you have received.  
 
Have you received a debt collection letter or other letter of notice?  
When carrying out debt recovery services, Alektum Group processes personal data on the categories of data
subjects given below. 
 
•	those who have a debt to pay (debtors), including their representatives,  
•	those who need to fulfil an obligation, e.g. to replace goods,  
•	those who bear joint and several liabilities for the debtor, such as an associate, a guarantor, etc. 

We process the data because you have a debt that has become due for payment to us or to one of our 
customers. We undertake so-called debt recovery measures in order to effectively ensure payment or other
discharge, claim establishment and/or enforcement, and so that we will be able to invoice and account for
this in a way that complies with the law. The processing is carried out on the basis of Article 6 b, c, e
and f of the General Data Protection Regulation. The legitimate interest is to see to it that unpaid debt
is cleared on our own or on another person’s behalf. 

“Debt recovery measures” is a collective term that we use for all of the actions we take in order to 
achieve the purpose mentioned above. This can consist of sending a debt recovery claim notice or other
letter of notice, or it can consist of administration of settlements, payments, contacts with debtors or
their representatives, contacts with the authorities,actions to establish claims, including court
proceedings, and enforcement. 

To enable us to carry out debt recovery measures, we need to process your contact and address details,
 including your personal identity number. It is important for the Alektum Group to make sure that the
information we are using is correct and up to date. For this reason, we ensure that address details are
regularly updated against population registry records, and for this purpose, we use an external 
contractor who will be able to view some of the personal data in the process. 

In the event that you live in or move to another country, the Alektum Group may hire a debt collection
agent that operates in that country. Personal data about you and the debt collection case will then be
shared with the debt collection agent. 

Moreover, we need to process data on the debt that remains unpaid, the contract, and other facts around
the purchase on which the debt is based, plus any partial payments made. In order to assess what debt 
recovery measures we are to take, we also need to know something about your financial situation, living
conditions and other debts, as well as any distraints. For this reason, we collect financial information
and debt information from external contractors, such as credit information companies and public 
authorities, for this purpose, these parties will be able to view some of yourpersonal data. On the basis
of this information, we decide what type of demand letter should be sent, and whether we should take 
legal action, such as petitioning for a payment injunction, initiating court proceedings, or petitioning
for enforcement action.In some cases, this is determined by means of methods such as profiling, and is
part of an automated process. This means that a decision on what measures to take is made automatically
based on pre-determined variables, rather than an administrator manually making decisions in each 
individual case. 

There are also other cases where we need to share personal data or make it available, in order for the
purposes of the processing to be achieved. Those with/to whom we may share this data or make it available
include e.g. the client, external contractors (such as postal and printing companies, IT support and
systems suppliers, companies serving legal papers,legal consultants and others who contribute to the
provision of our services), and public authorities.  

Apart from the personal data mentioned above, there may be isolated data concerning health or criminal
records, but only in the event that such information is necessary to enable a legal claim to be
established or exercised or defended in an individual case, or if the Alektum Group has obtained consent.
In such cases, the information is processed on the basis of Articles 9 a, 9 f, and 10 of the General Data
Protection Regulation, together with the provisions of the Data Act. 

The information is also used, to a limited extent, for business- and method development, operational
planning, statistics, monitoring, and risk management. The information is then used for the purpose of 
developing and analysing operations, and on the basis of our legitimate interest in developing our
operations and avoiding credit losses (Article 6 f of the General Data Protection Regulation). 
 
Do you work for one of our clients, contractors or collaborative partners, 
or for a public authority? 
Alektum Group processes personal data on the categories of data subjects mentioned below 

•	Contact persons and/or associates or guarantors of our customers,  
•	Contact persons for prospects (i.e., for companies that we would like to become a customer of ours), 
•	Contact persons for public authorities, including contact persons in specific matters, 
•	Contact person for contractors or other collaborative partners  

The information is used for the management of the contact, the implementation of the contract or
collaboration, and for accounting- and invoicing purposes. This information is processed on the basis of
Article 6 b, c and f of the General Data Protection Regulation. Personal data processing that is carried
out on the basis of Article 6 f is carried out for our legitimate interest in marketing our services and
in developing our customer base. 

Personal data relating to contact persons that is held by public authorities are used, moreover, for the
implementation of actions that are necessary in legal matters concerning claims, such as establishment,
enforcement, debt restructuring and dispute resolution. This information is processed on the basis of
Article 6 c, e and f of the General Data Protection Regulation. Personal data processing that is carried
out on the basis of Article 6 f is carried out in our, or our customers’, legitimate interest in
effectively securing payment of an unpaid debt that has become due. 

Personal data concerning associates, guarantors and contact persons that is held by collaborative
partners and customers is also used in cases where we need to carry out supervisory measures related to
money laundering, and for the assessment of ability to fulfil financial commitments, and otherwise of
security and economic solvency. Only the information that is necessary to achieve the purpose will be
processed, but this includes data on the person’s assets, debts and income. 

Sensitive information will only be processed if this is required for us to carry out our supervisory
measures related to money laundering. The information is processed on the basis of Article 6 b-c of the
General Data Protection Regulation and, where applicable, Chapter 5, Section 6 of the Act (2017:630) on
Preventive Actions against Money Laundering and the Financing of Terrorism. 

The information is also used, but to a limited extent, for business- and method development, marketing
analysis, statistics and risk management. The information is then used for the purpose of developing and
analysing operations, and on the basis of our legitimate interest in developing our operations and
communicating with our contacts (Article 6 f of the General Data Protection Regulation). 
 
How long your personal data is stored. The Alektum Group is
responsible for removing the personal data of its own accord when it is no longer necessary for achieving
the purposes stated. Hence, the time of storage varies, and a descriptionis given below of how Alektum
manages storage times depending on the main purpose involved.  

Personal data that has been collected during a debt recovery case is stored for 36 months after the case
is concluded.  

Personal data that has been collected in order to manage customer relationships and, if applicable, to
assess the creditworthiness of a customer, associate or guarantor, is stored for 36 months after the
customer relationship ends and the parties’ reciprocal claims have been conclusively settled, or at any
earlier time when the data ceases to be relevant for the purpose.  

Personal data that has been collected in order to carry out supervisory measures related to money
laundering is stored for five years, or for the time that is specified by law. The time period is to be
calculated from when the actions or transactions were carried out or, in cases where a business
relationship has been established, when that relationship has ended. 

Data that has been collected in order to develop, analyse and market Alektum’s operations is stored for a
period of 36 months after the last contact. If you unsubscribe from newsletters or similar, the data will
be deleted immediately. 

Regardless of the aforementioned storage times, the Alektum Group may store data for longer periods for
the purpose of defending and safeguarding legal claims. Personal data that is necessary for invoicing and
accounting for bookkeeping purposes is always stored up to and including the seventh (7) year after the
end of the calendaryear in which the accounting year ended. 
 
You are safe with us - we always protect your personal data. 
The Alektum Group is always obliged to protect your personal data, even when we hire an external party to
carry out the processing.We never disclose the personal data unless we have to in order to achieve our 
objective or unless we are obliged to by law. Moreover, we are bound by statutory confidentiality 
obligations in some of our services. 

We are also careful to limit the distribution of personal data internally within the Alektum Group, in
such a way that only thosestaff who need to see the personal data in order to carry out their work duties
have access to it.  

Furthermore, we ensure that all our IT systems and other locations where we have personal data stored are
protected against access to the information by unauthorised persons (e.g. through firewalls, virus
protection, strict requirements for passwords, logging in the systems, etc.).  

When we need to transfer personal data between ourselves and a party outside of our environment -- for
example, one of our customers -- we make sure to use a secure method of transfer.  

Finally, we make sure that backup copies of our systems and records are made in order to avoid the loss
of important information about you.  
 
You have control over your personal data. These are your rights. 
When the Alektum Group processes your personal data, you have a number of statutory rights. These are
stated below. You can exercise your rights by contacting us by using the form, or via your Plan&Pay. You
can, of course, also contact us by phone, at the number given above. 

•	You have the right to obtain information from us about the use of the personal 
        data that pertain to you, and a copy of this personal data (a so-called extract from the
        register).  
•	At your request, or of our own accord, we will correct or remove 
        information that is incorrect or no longer necessary, or alternatively, 
        we will limit the use of such information.  
•	You have the right to object to our use of your personal data for the implementation 
        of a task of public interest, or for our legitimate interest.  
•	You have the right to request that your details not be used for direct marketing 
        purposes, in the event that we undertake such actions.  
•	You also have the right to view the personal data we process in the execution 
        of a contract with you, and/or if you have given us your consent, in a machine-legible format 
        (if technically possible, we can help you to transfer this data to another party). 
•	If we use your personal data on the basis that you have given us your 
        consent to do so, you have the right to withdraw this consent at any time.  
 
Are you dissatisfied with our personal data processing? 
If so, you may make a complaint. If you are dissatisfied with the way we process your personal data, you
may contact the supervisory authority in the country in which you live. In Sweden this is the Swedish
Privacy Protection Authority(Integritetsskyddsmyndigheten). Their contact details are: 
Swedish Data Protection Authority, Box 8114, 104 20 Stockholm. 

You can always contact us if you have any queries about the above: 
tel. 031-730 00 00, or on e-mail info@alektumgroup.com

NB! E-mail carries risks in terms of security and confidentiality. It is comparable to a postcard.
Therefore, do not give information that is sensitive or that you do not want an unauthorised person to
acquire.