Privacy & Cookie Policy

Privacy & Cookie Policy ("Policy")

Last reviewed: 24 August 2022

Last updated: 24 August 2022

Definitions

In order to help you to understand the content of this Policy, below are listed some useful definitions:

• The EU GDPR: the European Union’s General Data Protection Regulation (2016/679).
• Personal data: any information relating to an identified or identifiable natural person, a 'data subject'.
• To process data: any operation which is performed on personal data, whether or not by automated means, such as but not limited to collection, recording, organisation, storage, and destruction.
• Data controller: a body which decides the purposes and means of processing personal data.
• Third party: a body other than the data subject and authorised data controller.
• Consent: an informed, unambiguous decision from an individual allowing specific processing of their personal data.
• Legal basis: a legal justification for the processing of personal data.
• Legitimate interest: commercial, individual, or broader societal benefits for the processing of personal data.
• Anonymised data: information that has had all personal identifiers entirely removed.

Overview

The Shrine Group, org.nr. 19950214-4810, (“Kami Compliance”, “Kami”, “we”, “us”, “our”), is a data controller of personal data (“Data”). At Kami, we take your privacy very seriously and ensure that all applicable data privacy regulations are observed. We think that it is important that you are familiar with what information we process about you, why it is needed, and how we use it to create value while protecting your rights. In this section, you can learn about how we process your Data when you use:

• consultkami.com or kamicompliance.com (“Site”, “Sites”),
• the Clearway Portal web or mobile platform (“CWP”, “Platform”, “Platforms”), or
• corresponding products and services offered by Kami (“Service”, “Services”, “Solutions”).

This Policy does not apply to third-party applications, websites, products, services, or platforms that may be accessed through links that we provide to you. These third parties are owned and operated independently from us and have their own separate privacy and data-collection practices. Any personal data that you provide to these third parties will be governed by the third party’s own privacy policy. We cannot accept liability for the actions or policies of these independent third parties, and we are not responsible for the content or privacy practices of such sites.

In the case of any discrepancy between the translations of the terms of this Policy, the English version supersedes all others.

Categories of Personal Data

Depending on your interaction with Kami, we may process different categories of your Data.

When using our Sites or Platforms, the categories of Data that we may process include:

• Full name
• Email address
• Telephone number
• Billing and contract information
• Cookie and marketing preferences
• Feedback, support, and error submissions
• Free text field entries (e.g. messaging)
• General correspondence

When using our Services or attending events, the categories of Data that we may process further include:

• Postal address
• Occupation title
• Event registration and attendance
• Event photographs

When submitting feedback, support, or error forms, you may be asked to provide your name, contact information, feedback or error message, device-specific data (e.g. hardware model, operating system, and crash data), and the identification number of the product or feature in question.

This Data is collected when you register or use our Sites, Portals, or Services, complete surveys, opt-in to cookies, opt-in to receiving marketing material, enter competitions, submit booking, feedback, or error forms, from public records, and through direct correspondence between Kami and yourself (including the Sites’ and Platforms’ messaging functions).

Kami does not knowingly collect the personal data of minors.

Purpose

Kami processes your Data in order to be able to provide to you in completion our services in accordance with your wishes, to improve and expand our Services and other offerings, for insight and research purposes, to communicate with you, to screen for potential risk or fraud, and, when in line with the preferences that you have indicated, to provide you with advertisement or promotional material.

As we develop insights and research for publication, we ensure that data is aggregated in order to prevent any individual from being identified, in effect anonymising the data set.

Our legal bases for processing are:

• Based on your consent,
• Necessary for the performance of contract,
• Due to other legal obligations, or
• Legitimate interest.

Data Retention

Unless required by law, Data is retained for up to 36 months after your last interaction with Kami, after which it is erased or anonymised. Interaction with Kami includes, for example, using our Sites, Platforms, or Services, or opening marketing communications from us.

You can at any time opt-out of receiving marketing communications or close your Clearway Portal account by following on-screen instructions, or by contacting us at help@consultkami.com. Closing your CWP account will prompt us to immediately begin processes to delete or anonymise all associated Data for which we do not have a legal requirement to retain.

Once this Data has been deleted as described above, it will no longer be accessible, and you will need to set up a new CWP account with us if you wish to use the Platforms again.

Employment Applications

For both published vacancies and open applications, our recruitment process may involve the processing of the following categories of Data of our applicants: full name; postal address; email address; telephone number; government-issued identification; references and CVs. This Data is retained for up to 5 years after the application date, or for as long as we have a legitimate business need for it. This Data is collected from public records, third-party recommendations and referrals, and through direct correspondence between Kami and yourself.

Third Parties and Countries

We may share your Data with affiliated companies with which we have partnered in order to provide to you a greater set of services, and with trusted third-party service providers as necessary for them to perform services on our behalf, such as:

• Cloud data storage
• Processing payments
• Product development and features
• Application deployment and publication
• Booking software
• Event management
• Cybersecurity and ID verification
• Market research and data analytics
• Legal consultancy
• Human resource management
• Serving advertisements and conducting surveys
• Communicating with you, such as by way of email or survey delivery
• Customer relationship management, including social media
• Support and related services

As often as is appropriate and practical, third parties are only provided with aggregated data (through which individuals cannot be identified) and are obligated not to disclose or use the information for any purpose other than those listed above.

With your consent, we may share your Data with our partner companies so that they may offer to you their own products and services. These partner companies include:

• Visslan
• The Ground
• Openli
• CookieYes

When we process orders, we may send your Data to, and also use the resulting information from, credit reference agencies in order to prevent fraudulent purchases.

Kami uses servers located within the EU; however, if we transfer Data outside of the EU, we check that the third country meets the requirements of applicable data privacy legislation and make the necessary contractual arrangements to ensure third-party compliance. Kami does not sell your personal data.

For a full list of our third parties, please send your request to legal@consultkami.com.

Cookies

A cookie is a small text file that the website or application that you are visiting requests to save on your device. They are widely used in order to make websites and applications work, or work more efficiently, as well as to provide information to the owners of the site or app.

Kami only uses essential cookies, those that allow our Sites and Platforms to work – as such, these cannot be disabled.

Should we ever update our cookie collection for other processing purposes, we will first request your consent.

PTS, the regulatory authority in the field, provides additional information about cookies on its website, pts.se.

You can learn more about cookies at allaboutcookies.org.

For information on how to manage your browser’s cookie settings, follow these links:

• Chrome
• Internet Explorer
• Firefox
• Safari

Cybersecurity

In order to keep safe your Data and all the other information that we have stored, we have implemented various security measures and taken reasonable steps to prevent unauthorised access, use, alteration, destruction, or disclosure of your Data. For example, our Site uses Secure Socket Layers (SSL), the industry standard for protecting private information sent over the Internet, and strict internal guidelines regarding the processing of Data have been implemented within our organisation. However, no data transmission or storage over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your Data, we cannot guarantee or warrant the security of any information collected through our Services.

Your Data will be stored in a secure environment and treated confidentially. To learn more about our security standards, please contact us at legal@consultkami.com.

Direct Marketing

Based on your prior consent, we may use your contact information in any commonly used method in order to provide you with information about products, special offers, and other information relating to our Services and other offerings or which we believe may otherwise be of interest to you.

You can at any time alter your communication preferences in regard to direct marketing via on-screen instructions, or by contacting us at help@consultkami.com. In addition, if you receive direct marketing from us in writing, you will be reminded in that material that you are able to alter your marketing preferences.

Rights of Users Located within the EU

If you are located within the EU, EEA, or Switzerland, under the EU General Data Protection Regulation, you have the right to transparency in how your Data is processed. A list of these rights is below. Please note that these rights are not absolute and certain exemptions apply.

• The right to access. You have the right to request copies of your Data. This right has some exemptions, which means you may not always receive all of the Data that we collect and process. When making a request, please provide an accurate description of the Data to which you want access. Please make any requests in writing to us and we will comply with your request promptly.
• The right to rectification. You have the right to ask us to rectify information that you think is inaccurate. You also have the right to ask us to complete information that you think is incomplete. You can also log into your Clearway Portal user profile and correct, amend, or delete information about yourself. You may also choose to block incorrect Data by contacting us at the address or email address at the end of this Policy.
• The right to erasure. You have the right to ask us to erase your Data under certain circumstances, including: (i) when your Data is no longer necessary for the purposes for which it was collected or processed, or (ii) your Data must be erased to comply with a legal obligation under EU Union or Member State law. If you choose to delete your Data, you understand that we will no longer be able to provide Services to you.
• The right to restrict processing. You have the right to ask us to restrict the processing of your Data under certain circumstances, including: (i) when the accuracy of the Data is brought into question, or (ii) when we no longer need the Data for purposes of the processing, but you require such Data for the establishment, exercise, or defence of a legal claim.
• The right to data portability. You have the right to request that we transfer the Data that you gave us from one organisation to another, or to give it to you.
• The right to object to processing. You have the right to object to the processing of your Data that is based on legitimate interests. If you make such an objection, we will cease to process the Data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or we can demonstrate that the processing is for the establishment, exercise, or defence of a legal claim.
• The right to revoke previously granted consent. You have the right to revoke consent previously granted for any of our Data processes, including direct marketing, cookie collection, or any other process related to the delivery of our Services. This may be possible by following on-screen instructions or by adjusting your browser settings, but you may also contact us by email with your request.

To exercise these rights, please contact us at legal@consultkami.com. For your protection, we may need to verify your identity before responding to your request. In the event that we refuse a request, we will provide for you a reason as to why.

If you believe that your rights under the EU GDPR have been violated, you have the right to file a complaint with the supervisory authority. A list of Supervisory Authorities is available here.

More information about the EU GDPR can be found at ec.europa.eu.

If you are instead located within the UK, you have similar rights under the UK Data Protection Act 2018 and can contact us as described above.

The UK’s supervisory authority is the Information Commissioner’s Office (ICO) – further information can be found on their website, ico.org.uk.

Changes to Kami Compliance's Privacy Policy

We may periodically change this Policy as we, for example, add new features and Services, as we improve our current offerings, and as technologies and laws change. You can determine when this Policy was last revised by referring to the “Last Updated” legend at the top of this page. Any changes will become effective upon our posting of the revised Policy. We may provide notice to you of any changes. This notice may be provided by email, by posting the revised Policy on our Site or App, or elsewhere in the Services, or by other means prior to the change becoming effective, consistent with applicable laws.

Contact Information

If you have questions about how we process your Data, or the contents of this Policy, you can at any time contact us using the details below.

Email address: legal@consultkami.com

Telephone number: +46 708 777 112

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