PRIVACY POLICY

(S 2025:1) 

Applicable from 2025-01-01

Information about Pogona Advokatbyrå AB's (hereinafter "Pogona") processing of personal data in connection with client assignments and business contacts.

You are always welcome to contact us if you have questions or comments regarding our processing of your data.

1. Introduction

As part of our business, we, Pogona, may process personal data about you.

Personal data is information that can be used to identify you as an individual or can otherwise be linked to you. For example, name, telephone number and e-mail address. You are not obliged to provide us with personal data (except where required by law, such as a publication order), but failure to do so may mean that we cannot undertake assignments for you, cannot process your application for a job with us, cannot send you newsletters or seminar invitations, etc.

Pogona protects personal privacy and is committed to always protecting personal data appropriately and complying with applicable legislation on the processing of personal data. Our goal is to make you feel safe when we process your personal data.

Through this policy, we want to inform you about our principles for processing personal data, how personal data is collected, how it is processed, how it is shared and how to exercise your rights. This is to ensure that Pogona complies with the requirements of the General Data Protection Regulation (2016/679/EC) ("GDPR") and other relevant laws and regulations in the field of personal data.

2. Data controller

Pogona Advokatbyrå AB, with reg. no. 559498-6969 and address Box 2014, 436 02 Hovås, is the data controller for the processing of your personal data in our business.

3. collection of personal data

Pogona collects and processes personal data when we receive requests for client assignments and when we prepare, receive, perform and administer such assignments. The same applies in relation to our suppliers and other partners. Normally, the personal data we process about you comes from you or from someone within your organization in connection with the conclusion of an assignment agreement or other agreement. Where applicable, we also receive information about the persons involved within the framework of our assignments without the information coming directly from them, but for example from courts, authorities and other external sources.

We collect and process personal data when you register for courses, seminars, our networks, newsletters, and in connection with other business contacts, as well as when you express interest in or apply for employment with us.

As stated above, there is no obligation to provide us with personal data, but without doing so, we may be prevented from accepting an assignment, entering into an employment contract or entering into a supply or cooperation agreement because we are unable to carry out the necessary disqualification, background and money laundering checks. In some cases, we have an obligation to verify the information provided, in which case we may obtain information from public or private records and from other external sources.

4. Personal data processed

The personal data we will process consists of:

Personal data in the context of missions

a) For clients who are natural persons: Name, personal identity number (or other information on date of birth), contact details (such as address, e-mail address and telephone number), copy of passport or other identity document, assignment title, information on what the assignment relates to and aims to achieve, information on where the assets that will be used in the assignment come from, information on whether the client or a close relative or known associate of the client is a politically exposed person and the name and profession/position of such politically exposed person, and information on our invoicing, payment history and payment reminders to the client.

b) For a client who is a legal person: Name, social security number (or other information on date of birth), title, employer, contact details (such as address, e-mail address and telephone number) and copy of passport or other identity document of the contact person or beneficial owner of the client, information in the registration certificate or similar for the client and information on whether such beneficial owner or related person or known associate of the client is a politically exposed person and the name and profession/position of such politically exposed person.

c) For counterparties who are natural persons: name, social security number (or other information on date of birth), contact details (such as address, e-mail address and telephone number) and engagement title.

(d) for counterparties that are legal persons: the name, title, employer and contact details (such as address, e-mail address and telephone number) of the contact person of the counterparty

e) For other persons involved in the engagement (e.g. opposing counsel, other consultants engaged for the engagement and witnesses): Name, title, employer and contact details (such as address, email address and telephone number).

f) Occasional information that the client, contact person or beneficial owner of the client or someone they act for in the engagement has been convicted of a criminal offense, has been banned from trading or has had several bankruptcies, has received bad publicity regarding business relationships or can otherwise be assumed to be dishonest, or occasional information that the engagement constitutes, or is suspected of constituting, a part of money laundering or other criminal act.

g) Any other single piece of information concerning a breach of law or a single piece of sensitive personal data (i.e. information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or concerning health or sex life) where the nature of the assignment makes such personal data relevant (for example, in the case of dismissal or termination for personal reasons or alleged discrimination).

h) Personal data other than those referred to in (a) to (g) above which, by their nature, are relevant to the task.

Personal data of contact persons at client, supplier or partner

i) For client, supplier or partner contacts: Name, title, employer, contact details (such as address, email address and telephone number), details of your contact(s) with us, details of attendance at our seminars and events and notes and summaries of meetings we have had with you (other than in the context of an engagement). We do not process sensitive personal data (i.e. data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or data concerning health or sex life). In the context of an assignment, additional personal data will be processed in accordance with the paragraph on what is stated under "Personal data in the context of assignments".

Personal data related to seminars, networks, newsletters or other mailings

j) For natural persons registering for seminars, networks, newsletters or other mailings: Name, title, employer and contact details (such as address, e-mail address and telephone number) and, where applicable, allergies or other dietary preferences.

Personal data in the context of recruitment

k) For natural persons applying for a job or expressing interest in a job with us: Name and contact details (address, telephone number and e-mail address), social security number (or other information on date of birth), gender, position applied for and position of interest, information in cover letter, CV and submitted qualifications and other documents, information provided by references, your test scores, notes and summaries from interviews and conversations during the recruitment process. We do not process sensitive personal data (i.e. data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or data concerning health or sex life).

5. Purpose of processing your personal data and legal basis

Personal data in the context of missions

a) The processing of personal data in connection with assignments is carried out in order for us to be able to fulfill our obligations and safeguard our clients' interests, handle the administration (such as accounting and invoicing) in connection with the assignments we undertake and meet the requirements imposed on us by law and the rules of the Swedish Bar Association. We process the data in order to carry out mandatory disqualification and background checks and (where applicable) money laundering checks. The data is processed to fulfill the contract for the provision of legal services that we have entered into with you as a client or, as a contact person for a client, based on a balance of interests where our legitimate interest in performing the processing is to perform, document and administer the assignment. We also have a legal obligation to preserve all documents in ongoing and closed cases.

Personal data of contact persons at client, supplier or partner

b) The personal data will be processed for the purpose of administering the relationship with the client/provider/partner. The personal data will be processed for the purposes of maintaining and developing the relationship with the client/supplier/cooperating partner and, if you have not objected, marketing our services (e.g. by sending newsletters and invitations to seminars). If you have not objected, your personal data will, where applicable in accordance with the rules of the Swedish Bar Association, be processed for the purpose of conducting industry or market research (such as the Law Firm of the Year survey or the Legal 500 ranking) through the service provider engaged, to be used as a basis for analysis and development of our business. If you have given your consent, your personal data will be processed for the purpose of using you as a reference for another client/supplier/partner or potential client/supplier/partner (e.g. in connection with public procurement). The processing is done on the basis of such consent.

Personal data related to seminars, networks, newsletters or other mailings

c) The personal data will be processed for the purpose of administering the mailing of invitations to seminars and network meetings as well as newsletters and other mailings to you. The processing is based on our legitimate interest in administering mailings to you in accordance with your stated wishes. The personal data will also be processed for the purpose of administering (including arranging suitable food) the implementation of seminars or network meetings with you as a participant. The processing is carried out on the basis of our legitimate interest to administer the organization of seminars or networking events with you as a participant in accordance with your stated preferences.

Personal data in the context of recruitment

d) The personal data related to job applications and recruitment procedures are processed for the purpose of carrying out the recruitment procedure. The processing is carried out on the basis of our legitimate interest in efficient and accurate recruitment. If you have consented to our processing of your data for future recruitment, the data will be processed for that purpose on the basis of such consent.

6. storage of personal data

We retain personal data in accordance with our obligations under the law and the Code of Conduct, in the latter case for a period of ten years from the date of the conclusion of the case, or such longer period as is required by the nature of the case or the client relationship. Contact details are kept for the time necessary to maintain a business relationship with you or the organization you represent.

Personal data processed for the purpose of developing, analyzing and marketing Pogona's business is stored for a reasonable time after the last contact with you has taken place.

If you unsubscribe from newsletters or similar, the data will be deleted immediately.

All personal data we process is processed in accordance with the data protection legislation in force at the time. The personal data is stored in physical and IT environments that use security measures to prevent unauthorized access. Reasonable standards for the protection of personal data are observed. Measures are taken to prevent unauthorized or unlawful processing of your data and accidental loss or destruction of, or damage to, that data.

7. sharing of personal data

Pogona and its employees are bound by professional secrecy. Personal data may be shared with third parties in cases where it has been specifically agreed between the law firm and you, or where we have a legal obligation to share your personal data as a result of law, regulation or decision. Personal data may also be disclosed to our liability insurer, our auditor, our broker of liability insurance, agents engaged by us or such liability insurer, the Swedish Enforcement Authority, debt collection agencies, courts, arbitration tribunals or our counterparty or its agents to the extent necessary to safeguard our legal interests. Data may also be disclosed to the Swedish Bar Association to the extent that we are obliged to do so under the rules of the Swedish Bar Association. We may also share your personal data with third parties to the extent that it is required within the framework of the assignment given to us and in the event that we engage external service providers who perform assignments on our behalf. If you have not objected to this, personal data may, where applicable and in accordance with the rules of the Swedish Bar Association, be shared with service providers engaged to conduct industry or market research.

As a general rule, no personal data is transferred outside the EU/EEA. However, this happens when it is necessary in the individual case for the purpose of the processing (for example, to instruct agents in the US or other non-EU/EEA country on behalf of the client); in such case, we will ensure that the transfer is subject to appropriate safeguards in accordance with the EU Data Protection Regulation. 

8. your rights

Rights of access, objection, restriction, erasure and rectification

You have the right, subject to certain statutory exceptions, to request information free of charge from the law firm about what personal data we process and about the use of the personal data concerning you. If you believe that the information about you is incorrect or incomplete, you have the right to request rectification. We will, at your request or on our own initiative, correct or delete data that is inaccurate or restrict the processing of such data, all in accordance with the applicable regulations.

You have the right to object to the processing of your personal data that we carry out on the basis of a balance of interests. We must then, after you have specified the processing to which you object, demonstrate that there are interests that weigh heavier. You also have the right to object at any time to the processing of your personal data for direct marketing purposes.

Right to data portability

If we process your personal data on the basis of a contract with you or your consent, you have the right to receive the personal data you have provided in an electronic format. You have the right to have the data in question transferred from us to another controller, if technically possible.

Right to withdraw consent

If our processing of your personal data is lawfully based on your consent, you have the right to withdraw your consent at any time, in which case we are obliged to cease processing immediately.

9. Questions, comments and complaints

If you believe that the processing of your personal data has been handled incorrectly, please notify us as soon as possible. If you are dissatisfied with our processing, you can lodge a complaint with the supervisory authority, which in Sweden is the Swedish Data Protection Authority (IMY).

Telephone: 08-657 61 00

E-mail: imy@imy.se

Postal address: Integritetsskyddsmyndigheten, Box 8114, 104 20 Stockholm

10. Amendments to this privacy policy

This policy may be updated. The latest version is always available on our website.

11. contact details

Please contact us as set out below if you have any questions about our processing of personal data, or if you wish to exercise your rights.

Email: info@pogona.se

Address: Box 2014, 436 02 Hovås

Telephone 0725-293938, www.pogona.se.