Personal Data Policy
Radonova Laboratories AB, corporate ID number 556690-0717 (“Radonova”, “we”) respect your privacy and your right to have control over your personal data.
This personal data policy describes the data we collect, the aim and purpose for which it is collected, the legal basis for our processing, the way in which you can have control over your own data and how you can contact us. This personal data policy applies when you use our website and/or web application and our services/products supplied by telephone, email, our website and/or via My pages (e.g. radon measurement of indoor air or provision of a user account) which are managed by Radonova (“the Service”). Radonova is the personal data controller in accordance with these conditions and is responsible for ensuring that data is processed in accordance with current legislation. It is important that you should read and understand our personal data policy before you make use of the Service.
All processing of personal data within Radonova takes place in accordance with applicable data protection legislation. What is referred to as the Data Protection Regulation (GDPR) applies within the EU/EEA from 25 May 2018.
Personal data is information that, along with other information, can be directly or indirectly linked to a natural living person. Examples of personal data include a person’s name, address, telephone number, personal identity number and e-mail address. Information on IP addresses and your user behaviour when you use the Service can also constitute personal data.
Processing of personal data includes all management of personal data, for example collection, analysis, alteration, registration and storage.
A personal data controller is a person that, either alone or with another person, determines the purpose for which and the means by which the personal data is processed and is responsible for ensuring that such processing takes place in accordance with applicable legislation.
Data that is processed
Radonova collects and processes the following personal data on you as a user of the Service:
- Telephone number
- E-mail address
- Invoicing address
- IP address
- Housing type
- Land registry reference
- Technical building information (e.g. type of ventilation)
- Geographical information
- and any other information that you yourself provide within the context of the Service.
Radonova needs the above information to enable it to fulfil the agreement with you and carry out the Service (e.g. a radon measurement). If you choose not to provide certain personal data, this can result in Radonova being unable to carry out the requested Service or in the Service not being carried out completely.
Certain information is obtained automatically when you use the Service, including:
- Information on your use of our website, e.g. how you navigate and what pages you have visited
- Technical data on the devices you use to gain access to the Service such as IP Address, Hardware Type, Operating System and Browser Version
- Geographical information
If you do not want us to collect data on how you use our website, you can install the browser plug-in “Google Analytics Opt-out”. You can find more information here: https://support.google.com/analytics/answer/181881
Purpose of the processing and legal basis
We process the personal data for the purposes set out below and for any other purposes specified at the time of collection:
- To provide the Service and manage our agreement with you, including drawing up and managing your results from the Service;
- To enable us to deliver everything included in the Service to the specified delivery address;
- To enable you to make use of the Service, we may disclose your personal data to a distributor of the Service and parties ordering the Service in order to fulfil the contents of the Service;
- To enable us to communicate with you by post, telephone, electronic communication (such as text message, e-mail, e-mail form or social media account) or in any other way, e.g. through contact via customer services, to send notifications and inform you of our updates of the Service and user conditions;
- To ensure that the Service is functional in technical terms;
- To improve and develop the Service and new services and products, to continuously improve the security of our network and information systems and to analyse your and other users’ use of the Service (e.g. what mobile device or equipment you use) in order to better understand how our customers interact and use the Service;
- To send notices (e.g. a reminder that it is time to end the radon measurement) by post, e-mail or text message;
- To send information on your results from the Service by post or e-mail;
- For marketing purposes, including marketing of our products and services, by e-mail (that you can opt out of via a link in each mailing we send out by e-mail);
- To control, prevent, investigate or adopt other measures in connection with misuse of the Service or in connection with use of the Service in breach of the user conditions for the Service or in connection with legal measures, suspected fraud or potential threats against Radonova or others’ rights;
- To fulfil a legal obligation.
Legal basis for Radonova’s processing of your personal data
Necessary processing in order to fulfil our agreement with you
Radonova processes your personal data to enable it to fulfil our agreement with you (e.g. for the purposes set out in points 1–5 above).
Necessary processing for purposes that relate to Radonova’s or third parties’ legitimate interests (balancing of interests)
In the event that the processing is necessary for purposes relating to Radonova’s or third parties’ legitimate interests, we can process your personal data on the basis of a balancing of interests. Such interests include our commercial interest in maintain good customer relations with you, providing you with information that is of relevance for your use of the Service, improving and further developing the Service and marketing our products and services (e.g. for the purposes set out in points 3–11 above). “Legitimate interest” therefore means our interest in carrying on and managing our business to enable us to provide you with the best possible Service and a satisfactory, secure user experience. For example, we have a legitimate interest in guaranteeing that marketing is relevant to you and we can therefore process your personal data in order to adapt our marketing according to your interests, e.g., suited to the type of housing you live in. Legitimate interest can also mean processing that is in your own or a third party’s interest. We can process your personal data to protect you (and other customers, suppliers and partners) and the results of the Service against fraud, intrusion and other irregularities in the use of our Services to guarantee that our Services, procedures and systems are secure. When we process your personal data on the basis of a balancing of interests, we guarantee that we take into consideration and balance the possible effects of the processing on you (both positive and negative) and your interest and rights under applicable data protection legislation. If you have any comments or objections against our processing based on a balancing of interests, you are entitled to object to such processing at any time. For more information on your rights, please see the information under the heading “Your rights and choices” below.
Processing on the basis of express consent
Radonova can also process personal data on the basis of express consent from you (e.g. for the purposes specified in points 7–9 above).
Processing that is necessary to fulfil a legal obligation
Radonova may need to process personal data to enable it to fulfil legal obligations, e.g. for accounting purposes or as a consequence of a decision by a court or public authority (i.e. for the purposes specified in point 11).
It may be the case that the same personal data is processed for multiple purposes and/or pursuant to more than one of the legal bases specified above.
Security and Transfer of personal data
Transfer of personal data to third parties
We will not share, sell, transfer or otherwise disclose personal data except as set out in this personal data policy unless we are required to do so in accordance with the law or as a consequence of a court order or unless we have obtained your consent for such disclosure or unless you have purchased the Service through a third party (e.g. from one of our retailers or through your municipal authority).
Radonova may disclose personal data to a third party such as the police or other public authority if it relates to an investigation of a suspected crime or if we are otherwise required to disclose such information pursuant to a law or a decision by a public authority.
Radonova may engage external suppliers to transfer data on behalf of Radonova, e.g. to supply IT services or supply the Service. The performance of these services can mean that Radonova’s suppliers, both within the EU/EEA and outside the EU/EEA, have access to your personal data. These suppliers process personal data on our behalf in accordance with a personal data processing agreement and our instructions. Personal data processors that have access to your personal data are not granted any right to use your personal data for purposes other than those specified in this personal data policy. The data will primarily be used to the extent required to enable them to provide the Service (e.g. send notices or deliver radon measurements to you).
Transfer of personal data to third countries
Radonova only cooperates with partners that process personal data within the EU/EEA. If Radonova chooses to engage suppliers outside the EU/EEA, e.g. cloud service providers, Radonova will, in such cases, adopt special protection measures such as signing agreements that include standardised model clauses for data transfer which have been adopted by the European Commission and which are available on the European Commission’s website or by engaging companies that maintain the same level of protection as within the EU/EEA by, e.g., having adhered to what is referred to as the Privacy Shield agreement between the EU and the USA.
Security for protection of personal data
Radonova safeguards your privacy and maintains a high level of security for your personal data. Radonova has adopted applicable security measures to protect your personal data from unauthorised access, alteration, dissemination or destruction. All processing of your personal data takes place under strict secrecy.
Storage and weeding of personal data
The processing takes place in accordance with current legislation and means that personal data is not stored for a longer period than is necessary taking into consideration the purpose of the processing. We will store your personal data until the Service you chose to use has been completed. The Service is considered to have been completed four years after the results of the Service have been approved. This is because SWEDAC requires Radonova to save information on the Service for four years. If you register for our newsletter, your contact details are saved for as long as you choose to continue receiving the newsletter. Only necessary contact details are used for marketing purposes. This means in practical terms that data is weeded out and deleted when it is no longer current or necessary for the purposes for which it was collected. Certain data can be kept for longer periods when so required under other legal requirements such as the Bookkeeping Act.
The same personal data can be stored in several different places for different purposes. That can mean that data that has been weeded out of one system because it is no longer necessary can remain in another system where it is stored on another legal basis or for another purpose for which the personal data is still required.
Your rights and choices
With regard to processing of your personal data, you have a series of rights deriving from applicable data protection legislation. In order to exercise your rights, you are welcome to contact Radonova via the contact details specified at the end of this Personal Data Policy.
Right to access
You have a right to request and obtain confirmation on whether Radonova processes personal data on you. If Radonova processes personal data on you, you have a right, on one (1) occasion per year, free of charge, to obtain information on the processing and a report on the personal data that is being processed. For any further reports, Radonova is entitled to charge a reasonable fee based on Radonova’s administrative costs for such copies. If the request is clearly unfounded or unreasonable, Radonova may, in accordance with the provisions contained in applicable data protection legislation, charge a reasonable fee for the request or refuse to accede to the request.
Right to correction of inaccurate personal data
You have a right, without unnecessary delay, to have inaccurate personal data on you corrected. Depending on the purpose of the processing, you also have a right to supplement incomplete personal data.
Right to deletion (“right to be forgotten”)
In certain circumstances, you have a right to have your personal data deleted, e.g.
- if the personal data is no longer necessary for the purposes for which it was collected;
- if the processing is based on your consent, you have a right to withdraw that consent at any time and you have a right thereafter to deletion of the data (provided there is no other legal basis for the processing);
- if you object to processing based on a balancing of interests and there are no legitimate reasons for the processing that weigh more heavily (you nevertheless have a right at all times to deletion of personal data that is used for direct marketing based on a balancing of interests);
- if the personal data has been processed in an unlawful manner or if it must be deleted due to a legal obligation;
The right to deletion nevertheless does not apply in certain cases, e.g. if the processing is necessary to enable Radonova to fulfil a legal obligation or to enable Radonova to establish, file or defend a legal claim.
Right to restriction
In some cases you have a right to ask Radonova to restrict the processing of your personal data, e.g. if you do not consider that the personal data is accurate, so that Radonova has time to check this, if the processing is unlawful and you do not want us to delete the data, if Radonova no longer needs the data but you need it for a legal claim or if you object to Radonova’s processing based on a balancing of interests awaiting a check on whether Radonova’s or a third party’s legitimate reasons outweigh your legitimate reasons.
Right to file objections
You have a right at any time to file objections against processing of your personal data based on a balancing of interests, including profiling. Radonova may not continue to process such personal data unless Radonova can present imperative legitimate reasons for such processing that outweigh your interests, rights and freedoms. Radonova may nevertheless continue the processing for establishment, exercise or defence of a legal claim. If you object to processing for direct marketing that takes place based on a balancing of interests, Radonova may no longer process your personal data for such purposes. You may at any time opt out of receiving marketing communications from us by clicking on Unsubscribe in an mailing that we send you by e-mail.
Right to data portability
In some cases you have a right to transfer your personal data to another personal data controller, e.g. if the processing is based on consent or on an agreement between you and Radonova and provided that the processing takes place in an automated manner. When technically possible, such transfer must take place directly from Radonova to another personal data controller.
Write to submit a complaint to the Data Protection Authority
If you consider that your rights are not respected by us, you are welcome to contact us and you also have a right to submit a complaint to the Data Protection Authority.
Links to other websites and social plug-ins
In the event that the Service refers (links) to a website or material that belong to a third party, such a reference is only intended as a service for the user and Radonova accepts no liability for it or for any personal data processing carried out by it.
In the Service, you may sometimes receive an offer to share information from the Service on social media such as Facebook or Twitter via an implemented social plug-in (such as a share button). We have no influence over the information collected by social media with the aid of these plug-ins if you choose to use them. We therefore encourage you to keep yourself informed of the purpose and scope of the collection of data that takes place through social plug-ins.
Changes to the personal data policy
If we make changes to this personal data policy, we will publish the updated version here:
Choice of law and resolution of disputes
Processing of your personal data according to this personal data policy and your use of the Service must be interpreted in accordance with Swedish law. Disputes must be settled by a Swedish general court, unless otherwise stipulated in an imperative law.
For more information on management of personal data or if you have any questions, you are welcome to contact us at:
Radonova Laboratories AB
754 50 UPPSALA
E-mail address: firstname.lastname@example.org
Telephone number: +46 (0) 18 56 88 00
This personal data policy applies from 25/05/2018.