Processing of personal data

This describes how ClearOn AB, in accordance with applicable data protection legislation including the General Data Protection Regulation (EU 2016/679) “GDPR”, processes personal data.

ClearOn is a payment institution that offers coupon and payment services for retail stores under its own auspices and through our cooperative partners. ClearOn also develops and sells cash register and POS systems. While providing these services, ClearOn may also process your personal data. This information aims to describe the type of personal data we process and why, as well as your rights in conjunction with the data processing.

ClearOn is responsible for the management of personal data processed through most of our services. We perform certain services on behalf of other organisations, and in these cases, ClearOn is normally the Personal Data Processor, while our client would be the Personal Data Controller. Find more information about the division of responsibility below under the respective services.

In both cases described above, we at ClearOn are committed to following the laws and regulations that apply to the processing of personal data. This means that we:

  • will provide clear information on when personal data will be processed and stored
  • will state the justification for storing information and provide information on the duration of the storage
  • will state whether the personal data must be handled by another party
  • will never use collected personal data for any other purpose that that which we have stated
  • will delete the data when it is no longer needed
  • will be responsive to inquiries and requests regarding stored personal data

 

Since ClearOn performs several different services for different purposes, personal data management for each specific service is described below. To learn more, click on this or other services in the list.

General terms and conditions for the processing of personal data, your rights in this regard, as well as contact information can be found further down in this document.

ClearOn services and personal data processing

In-store payment services over the counter            

 

Online payment services

 

Digital coupon services

 

Support issues

 

Company services

 

General terms and conditions for the processing of personal data

Personal data we process

ClearOn primarily receives your personal data when you submit this to us directly, or it may come from one of our clients with whom you have a customer relationship, i.e. if you request a service that we provide in a shop or through membership in a client’s customer club. Our payment services may supplement personal data with data from the Population Registry, e.g. addresses.

Personal data that may be processed to enable us to provide our services include:

  • General information about you, such as your name and contact information, as well as details regarding the services you are using.
  • Swedish personal ID number and information about your ID documents, as well as giro or bank account number and the payee when using our payment services.

 

When ClearOn processes personal data in order to provide a service that you have ordered directly from ClearOn, this processing is performed in order to fulfil ClearOn’s contractual obligations to you. If data processing is performed to ensure that you receive services based on an agreement with one of ClearOn’s clients, ClearOn will process your personal data for our legitimate interest in our ability to offer you these services, and for the legitimate interests of our client. Personal data may also be processed if this is deemed necessary for legal purposes, e.g. money laundering monitoring.

Transfer of personal data to a third party

ClearOn transfers personal data to banks, cooperative partners and other categories of recipients, including government authorities. This transfer takes place so that we can provide our services and to meet legal requirements.

When disclosing information to third parties who process your personal data on our behalf, we ensure that these actors process your personal data in a secure manner and in accordance with applicable law. In the description for each service, we state whether information will be transferred, and if so, to whom.

Collection of personal data from a third party

In cases where ClearOn is a Personal Data Processor, we receive your personal data from our client, such a company or a bank, which would then be responsible as the Personal Data Controller.

We supplement personal data in several of our services, which enables to perform the service. This involves obtaining a name and address, which is done electronically from the Population Registry.

How long is your personal data stored?

We never process or store your personal data for a longer period than that permitted by applicable law, regulations, practices or government decisions. Personal data that is processed for the purpose of completing our assignment will be stored as long as necessary to manage the customer relationship, exercise our rights, and fulfil our agreements and commitments to our clients and to you as a customer. For each service we provide, we have specified the criteria that apply to the length of time the personal data is processed or stored.

Security

ClearOn takes the appropriate technical and organisational security measures required to protect the personal data against unauthorised access, alternations or destruction. ClearOn runs its own operations and monitoring of current services. We follow the IT security standard ISO 27000, which implies, among other things, that all systems that handle personal data are protected by authorisation systems that provide access only to personnel working with each respective service. All of our business-critical IT systems are duplicated and placed in two separate IT facilities. We have network protection with firewalls and other protection mechanisms based on accepted practices.

Consent

Certain services are based on your choice to participate in campaigns, and take part in offers or marketing via web services or social media. In these cases, you will need to provide us, or our client, with your consent to allow us to process the necessary personal data for the service, and to send you newsletters or special offers.

 

Your rights

Right of access

In accordance with applicable data protection legislation, you have the right to request a free excerpt from the registry regarding the processing of your personal data performed by ClearOn. You also have the right to have inaccurate personal data rectified.

A request for the registry excerpt must be submitted in writing. Please note that this form is available in two versions.

  • Forms for those with a Swedish national ID number, click HERE
  • Forms for those who do not have a Swedish national ID number, click HERE

 

Right to erasure

Your personal data will not be retained for longer than necessary, based on the purpose of the processing. ClearOn will otherwise delete personal data in the manner specified by applicable legislation.

You have the right to demand erasure of inaccurate information, and erasure of personal data that is no longer necessary.

Right to object

You have the right to object to data processing performed for a legitimate interest, e.g. when ClearOn processes your personal data in order to provide services related to your agreement with one of ClearOn’s partners.

Right to restrict personal data processing

You have the right to request restrictions on the processing of your personal data if:
1) you question the accuracy of the personal data.
2) the processing of your personal data is not permitted, and you choose to restrict the personal data instead of demanding its deletion.
3) the personal data is longer needed for the purpose for which it was originally processed, but you need it to establish, or exercise or defend yourself against legal claims.
4) you have objected to data processing based on a legitimate interest. Restriction on personal data processing means that the personal data will continue to be stored, but will otherwise not be further processed by ClearOn without your consent.

Right to data portability

You have the right to request your personal data in a structured, generally utilised, and machine-readable format for the data given to ClearOn in cases where this data was processed with your consent, or based on an agreement.

Contact us

If you wish to speak with our data protection representative regarding our processing of your personal data, e.g. to exercise your rights noted above, you can do so by contacting Customer Support.

In the event of a disagreement

If you are dissatisfied with our processing of your personal data, you can always contact us through the above contact information to present your complaint. You also have the right to file a complaint with the Swedish Data Protection Authority, which is the supervisory authority for companies’ management of personal data.