Privacybeleid

This Privacy Policy was updated 2018-10-15.

Index

Background
Definitions
Data controller
Compilation of the Processing of your Personal Data
Why do we Process your Personal Data?
What Personal Data is Processed on what legal ground?
Social media platforms
How long is your Personal Data stored?
Cookies
Your rights
Consent to the Processing of Personal Data
Profiling
To whom do we transfer your Personal Data?
How do we protect your Personal Data?
Supervision and compliance
Third party’s terms and conditions
Changes to the Privacy Policy
Contact us

1. Background

We care about your privacy and the security of your personal data. That you as a customer have faith in our protection of your privacy is very important to us.

This policy (“Privacy Policy”) has been designed to make you aware of how Globe Group (“Globe Group”, “we”, “us”) processes your personal data in a legal, appropriate and safe manner. The Privacy Policy explains how Globe Group processes your personal data and what rights you have according to the rules in the EU’s General Data Protection Regulation (EU) 2916/679 with associated statutes of implementation and supplementary statutes on data protection (the “Data Protection Rules”).

The Privacy Policy applies (i) when Globe Group performs customer support services (ii) when you visit our website Cramertools.com (“Cramertools.com”) (iii) to marketing carried out via e-mail, phone and social media platforms, and (iv) to all other contacts with us via social media platforms, e-mail or phone

2. Definitions

In this Privacy Policy, the term "Personal Data" includes any information which can be attributable to an identified or identifiable natural person, such as e.g. name, address, personal identification number, date of birth, credit card number, e-mail address, phone number, and purchase history.

In this Privacy Policy we describe how we Process your Personal Data. The term "Processing" includes e.g. our registering, storing, transmitting, and in other ways using your Personal Data in such a manner as is described in this Privacy Policy.

3. Data controller

GLOBGRO AB, reg. no 559065-0619, with the registered address Propellergatan 1, 211 19 Malmö, Sweden, is the data controller responsible for the Processing of your Personal Data.

4. Compilation of the Processing of your Personal Data

Below is a compilation of the Processing of Personal Data we carry out. We further describe the Processing in sections 5, 6, 7, and 8 in this Privacy Policy.

Marketing

Purpose: To market Cramer and offer you discounts and favourable offers via e-mail
Category of Personal Data: Name and contact information
Legal ground: Consent
Storage periods: Until you withdraw your consent

Customer support

Purpose: To provide customer support, service, and develop services and products
Category of Personal Data: Contact information, Records regarding purchases and possible complaints, Information from customer surveys.
Legal ground: Legitimate interest
Storage periods: 24 months after your matter has been concluded or as long as we are legally obligated

Legal obligations

Purpose: To comply with legal obligations, such as the Accounting Act or the Money Laundering Act
Category of Personal Data: Contact information, Personal identification number, Purchase history, Correspondence, Records regarding purchases and possible complaints.
Legal ground: Legal obligation
Storage periods: As long as we are legally obligated to store the data

5. Why do we Process your Personal Data?

Globe Group Processes Personal Data for different purposes. In summary, the Processing takes place in order for us to:

enable customer care and customer service, e.g. when you contact our customer support via Cramertools.com, e-mail, or phone;
be able to update our services and products, as well as the technical functionality of our systems;
give you information about events, send out newsletters and offers via mail, e-mail and phone;
give you information and come in contact with you via social media platforms;
prevent fraud and perform risk management; and
comply with applicable legislation.
provide services as promised under our offers (1. under the two-year-commercial warranty, 2. the ten year battery warranty guarantee, 3. the free robotic garage, 4. and the robotic insurance

We only collect Personal Data which is necessary for the purposes described in this Privacy Policy. What Personal Data we collect about you depends on which of our products or services you have requested, ordered, or purchased or how you have come in contact with us.

When you are asked to provide us with Personal Data, e.g. in a customer support matter, you may choose not to do so. If you choose not to provide the information necessary in order to access a specific service, this may lead to us not being able to fulfil our commitments towards you.

Further, we Process Personal Data through the use of cookies (small text files which are stored on your unit) on Cramertools.com. This is done so that Cramertools.com and our online services can function as well as possible and provide you with a pleasant customer experience. Read more on our use of cookies under section 9.

6. What Personal Data is Processed on what legal ground?

TO SEND OUT OFFERS AND NEWSLETTERS

The Personal Data we Process in order to send out offers and newsletters are:

first and last name:
address;
e-mail address;
IP-address; and
information regarding your use of Cramertools.com, e.g. which products and/or services you have shown an interest for, as well as you user history regarding our offers and newsletters (e.g. what you click on in our newsletter).

The Processing of Personal Data is based on your consent.

TO PROVIDE AGREED OFFERS

In the context of our offers (1. under the two-year-commercial warranty, 2. the ten year battery warranty guarantee, 3.the free robotic garage, 4. and the robotic insurance* (*only available in Germany)) we process personal data which you entered into this form (contact data, chosen password, product information) to fulfil our contractual obligations. Article 6 (1) sentence 1 b) GDPR (fulfillment of contract) is the legal basis for data processing.

With accepting aforementioned offers, you have committed yourself to providing this data. Without providing the data, your contractual obligations are not fulfilled and we will not proceed according to the offer.

FOR CUSTOMER SUPPORT, SERVICE, AND IMPROVING OUR SERVICES

The Personal Data we Process when you communicate with us and for improving our services are:

first and last name:
billing and delivery address;
phone number;
e-mail address;
personal identification number;
information from customer surveys; and
information you give us in contact with our customer support.

The Processing of Personal Data is necessary in order for Globe Group to be able to provide genuine service via our customer support and in order to be able to investigate potential complaints, as well as develop and improve our products and services and thereby cater to our legitimate interest of handling customer service matters and developing our business.

TO COMPLY WITH LEGAL OBLIGATIONS

Certain Personal Data Globe Group Processes is used in order to comply with legal obligations according to applicable legislation, court rulings, or authority decisions. Such obligations may refer to requirements regarding product responsibility and product safety, such as the preparation of communication and information to the public and customers regarding product recalls, e.g. upon suspicion of a defective or hazardous product. Such obligations may also follow from the Consumer Sales Act (1990:932), the Accounting Act (1999:1078) or the Money Laundering Act (2017:630). Personal Data Processed in order for Globe Group to comply with its legal obligations are normally:

first and last name:
phone number;
e-mail address;
personal identification number;
correspondence with you; and
information regarding a potential purchase, e.g. which product you purchased and any potential opinions you may have related to our products or services.

7. Social media platforms

We use Facebook, Instagram and YouTube as channels in order to come into contact with our customers, as well as to market and inform about our products and services. In connection with this, Globe Group is the data controller for publications and information on the social media platforms that contain Personal Data and are provided by you as a user in the form of e.g. comments, photos and video. Globe Group does not in any way accept any offensive material being published or made available via our channels on social media platforms. Globe Group asks our users to report unfit content to us in order for us to be able to ensure that no such content exists on our social media platforms. Globe Group may thereby also, based on what we deem necessary, remove content from the social media platforms.

8. How long is your Personal Data stored?

Your Personal Data is stored only for as long as there is a need to store it in order to fulfil the purposes for which the Personal Data was collected in accordance with this Privacy Policy. Globe Group has clear routines ensuring we do not store your Personal Data longer than necessary.

If you have consented to receiving offers from us via e.g. our newsletter, we Processes your Personal Data for that specific purpose, until you deregister or inform us that you no longer consent to having offers being sent to you. You can do this by (i) contacting us and informing us of this in writing, or (ii) following the link in the mailing.

Personal Data which we have received in through conversations with customer support is deleted 24 months after your matter has been concluded or once we are no longer obliged by law to store the Personal Data.

Personal Data which is necessary in order to fulfil potential warranty commitments as well as matters regarding complaints are stored for as long as it takes for us to fulfil our warranty commitment.

In order to enable Globe Groups’ compliance with the legal obligations stemming from applicable legislation or in order to safeguard our legal interests (in the case of a legal process), we may store your Personal Data for a longer period of time. The Personal Data is however never stored for longer than is necessary or statutory for each purpose respectively.

9. Cookies

We use cookies on our Website. More information on how we treat cookies can be found in our Cookie Policy.

10. Your rights

Globe Group wishes to be transparent in our Processing of your Personal Data. You have a right to receive information regarding the Processing of your Personal Data we carry out. Below you find a statement of the rights you can claim by contacting our data protection officer. Contact information to our data protection officer can be found at the very end of this Privacy Policy.

Right to access

You have a right to, free of charge, request information regarding our Processing of your Personal Data. You also have a right to receive a copy of your Personal Data that we Process. Such a request shall be submitted to us in writing, with a clarification regarding which information you wish to access. We will respond to your request as swiftly as possible. If we cannot grant you access to the information your request concerns, we will provide a reason as to why. The copy of your Personal Data will be sent to your registered address unless otherwise is agreed with you in writing. In order to ensure the right person will be receiving the Personal Data we may come to request more information from you.

Right to rectification

The main responsibility to ensure that the Personal Data we Process is correct lies with Globe Group, as the data controller. If you inform us that the Personal Data you have provided us with is no longer correct, we will, if that is the case, promptly rectify this.

Right to erasure

You have the right to request that Globe Group, without unnecessary delays, erases your Personal Data. Personal Data shall be erased in the following cases:

if the Personal Data is no longer necessary for the purposes for which it was collected;
if erasure is necessary in order to comply with a legal obligation.
if your Personal Data has not been Processed in accordance with the Data Protection Rules; or
if you oppose the Processing of Personal Data after a balancing of interests has been carried out and your interest outweighs ours;
if the Processing is carried out for direct marketing purposes and you object to your Personal Data being Processed for such purposes;
if you withdraw your consent and the Processing was based solely on your consent;

There may be obligations which hinder us from immediately erasing all your Personal Data. These obligations stem from applicable legislation regarding e.g. accounting. If certain Personal Data cannot be erased due to applicable legislation we will ensure that the Personal Data will be used solely for the purpose of complying with such legal obligations and not for any other purposes.

Right to restriction

You have a right to request that Globe Group temporarily restricts the Processing of your Personal Data. Such a restriction can be requested in the following cases:

if you consider the Personal Data we have about you to be incorrect and in connection with this have requested rectification;
when the Processing of your Personal Data which is carried out is not compliant with the Data Protection Rules, but you still do not want your Personal Data to be erased but rather restricted; and
when we no longer need your Personal Data for the purposes of our Processing but you need it in order to establish, exert, or defend a legal claim.

If you have objected against the Processing of your Personal Data the use of your Personal Data may be restricted during the time of the investigation. Upon the restriction of your Personal Data IST will only store your Personal Data and for further Processing obtain your consent.

Right to data portability

You have a right to, in cases where we Process your Personal Data with your consent or in order to fulfil contractual obligations towards you, require that we provide you with all Personal Data we have about you and which is Processed in an automated manner, in a machine-readable format, which may be e.g. an Excel-file or a CSV-file. If it is technically possible you further have the right to require that we transfer your Personal Data to another data controller.

Right to object

You have a right to object to our Processing of your Personal Data if the Processing is based on our legitimate interest after a balancing of interests. Globe Group may in such a case ask you to specify which Processing you object to. If you object to any Processing we will only continue our Processing of the Personal Data if there are legitimate interests for Processing which outweigh your interests.

11. Consent to the Processing of Personal Data

If you have given your consent Globe Group will send you newsletters and marketing which we believe you will be interested in via e-mail or sms depending on which kind of mailings you have requested from us.

When you consent to Globe Group sending you newsletters and marketing via e-mail you will always receive an e-mail with a link where we ask you to confirm that you wish to receive our dispatches. We do this in order to ensure as far as possible that you are making a conscious decision and that it is actually you who has requesting our dispatches.

You decide whether you want to consent to the intended Processing and when you wish to withdraw your consent. If you wish to withdraw your consent, contact us in the manner which is presented below or by following the link in the mailing.

Read more about what it means to have given consent under section 6 above.

12. Profiling

Globe Group will analyse your behaviour on Cramertools.com and how you interact with our newsletter and other mailings, in order to obtain more knowledge about you as a customer and our customers in general, as well as in order to improve out offers (this composes so-called “Profiling”). For the same purposes we may come to process potential personal wishes or preferences you have given us, e.g. information that you are interested in a certain type of product. This is done through analysing which products you have been looking at or based on what you have clicked on in our newsletter or our other mailings to you. Based on this information we provide you with customized marketing and offers.

Globe Group bases the Processing on Personal Data which is carried out for the Profiling in accordance with the Data Protection Rules on our legitimate interest of sending you offers and information which we believe you are interested in. As a ground for this we have conducted a balancing of interests where we have inter alia taken into consideration that the Processing does not concern any sensitive Personal Data, that you have requested our mailings, and that we have a clear business interest in being able to market our products and services to you as a customer in an efficient manner.

You can at any time object to the Processing of your Personal Data through Profiling. You can do this by contacting dpo@greenworkstools.eu. When we have received your message, we will seize the Processing of your Personal Data for Profiling purposes.

13. To whom do we transfer your Personal Data?

In order to provide our services and products we appoint select third parties. This entails that we share some of the Personal Data we have collected with them, e.g. to Globe Groups´ group companies and other business partners such as suppliers of card and communications services or suppliers for printing and distribution. In connection with such transfer of your Personal Data Globe Group takes organisational and technical measures in order to ensure that your Personal Data is handled in as safe and secure a manner as possible. Such transfers are only carried out in situations where Globe Group has a legitimate business interest to do so. These select third parties will only Process your Personal Data in manners which follow from this Privacy Policy and in order to fulfil one or more of the purposes which are listed in this Privacy Policy.

Globe Group may be obligated to upon request by law and authority decisions disclose your Personal Data. Such disclosure can e.g. occur to the police or Swedish Tax Authority.

In the event of changes to Globe Groups’ business or ownership, you Personal Data may also be shared with a third party. Should Globe Group sell its entire, or parts of its, business or assets, Globe Group may disclose your Personal Data to potential or actual buyers and their potential advisors.

Globe Group will not sell your Personal Data to a third party unless we have previously obtained your consent.

14. How do we protect your Personal Data?

In order to protect your personal integrity, discover, prevent and limit the risks of a hacking attack etc., Globe Group takes several technical and organisational information safety measures. Upon transmissions of Personal Data such as personal identification number, password etc. via internet, such Personal Data is protected through encryption. Globe Group also takes measures in order to protect your Personal Data against unauthorised access, misuse, reveals, changes and damages. Globe Group ensures that access to your Personal Data is only granted to employees who need it in order to fulfil their work assignments, and that they Process your Personal Data with confidentiality.

15. Supervision and compliance

If you are in any way dissatisfied with how your Personal Data has been processed or believe that your Personal Data has been Processed contrary to The Data Protection Rules you are welcome to contact us. You can also turn to the supervisory authority, which currently is Datainspektionen. You can find more information at www.datainspektionen.se.

We ensure that all new employees receive this Privacy Policy in order to protect your Personal Data in the best possible manner.

Globe Group annually reviews this Privacy Policy.

16. Third party’s terms and conditions

Globe Groups’ services may in some cases be subject to a third party’s terms and conditions. Globe Group is not responsible for such a third party’s use of your Personal Data as they themselves are data controllers and responsible for the Processing of your Personal Data. Therefore, it is important that you observe and read through the terms and conditions of the third parties, e.g. in connection with the use of our payment service at Cramertools.com or upon choosing delivery of the product you ordered from us, where potential credit institutes and shipping companies Process your Personal Data in accordance with their own terms and conditions. The same applies if there is a link on Cramertools.com to other websites.

17. Changes to the Privacy Policy

Globe Group reserves the right to change this Privacy Policy when we deem it to be necessary in order to comply with applicable legislation. Such changes are especially warranted upon potential changes in legislation, due to statements from the supervisory authority or other authorities issuing statements pertaining to the Data Protection Rules. Further, this Privacy Policy will be updated when is necessary due to changes relating to our products and services.

We will inform you in good time before such a change enters into force.

18. Contact us

If you have questions pertaining to this Privacy Policy or the Processing of your Personal Data, wish to file a request in accordance with the Privacy Policy, or wish to report a violation of this Privacy Policy etc., you are welcome to contact our Data Privacy Officer as follows below, or via our contact form which you can find at Cramertools.com.

GLOBGRO AB, reg. no 559065-0619, Propellergatan 1, 211 19 Malmö, Sweden, E-mail: dpo@greenworkstools.eu