Privacy policy

May, 3 2018

PRIVACY POLICY - SACCNY 1. Swedish-American Chamber of Commerce, New York 1.1 Purpose The Swedish-American Chamber of Commerce, New York (“SACCNY”, “our” or “we”) is a non-governmental organization with the mission to promote, advance and protect commercial and professional relations between Sweden and the United States while acting as an important support agent for Swedish businesses internationalizing into the U.S. market (the “Purpose”).

1.2 Services To fulfill its Purpose, SACCNY offers several services and products, including but not limited to consulting services to Swedish businesses seeking to enter the U.S. market, events and conferences for networking and professional development, publications such as SACCNY´s In New York magazine, newsletters, information pamphlets, flyers and other printed and digital material with market updates, access to SACCNY´s website which includes blog posts and other information about our services (the “Services”).

Members of SACCNY (“Members”) and other users of the Services are collectively referred to as “Users”, “you” or “your” in this Privacy Policy.

For more information about SACCNY, please follow this link.

2. SACCNY´s Privacy Statement This Privacy Policy puts forth our policy (the “Privacy Policy”) with respect to information that can be associated with or which relates to a person and/or could be used to identify a person ("Personal Data") that is collected from Users on, through or in connection with the Services. We take the privacy of your Personal Data very seriously and have therefore created this Privacy Policy, which sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed. We ask you to please read this Privacy Policy as it includes important information regarding our treatment of your Personal Data and other information.

We may also collect non-personal data, which shall be understood as any information that does not relate to a person and/or cannot be used to identify a person, when Users use the Services. Kindly note, that the limitations and requirements in this Privacy Policy only applies to Personal Data and thus, does not apply to non-personal data.

May, 3 2018 3. Collection of Personal Data When you use or otherwise interact with us through the Services or Events, we may collect Personal Data in accordance with what is set out in this section 3.

3.1 Information you give us You may provide us with Personal Data about yourself by using our Services, filling in forms on our Site or by corresponding with us by phone, e-mail or otherwise. This includes but is not limited to information you provide when you register to become a Member, subscribe to our Services, make an enquiry about our Services or otherwise email us, request information from us, participate in discussions in our social media, request a magazine or newsletter, enquire about our events or membership benefits, enquire, book or attend events and conferences, and when you report a problem with our Site. The information you give us may include your name, address, e-mail address and phone number, credit card information, copy of correspondence, interests and preferences, professional information (such as, but not limited to, your job title and details of your employer) and any other information relevant to your enquiry or request for information or services which we may request and/or you may choose to provide to us from time to time.

3.2 Information we collect about you When you visit our Site, we may automatically collect technical information (including the Internet protocol (IP) address used to connect your computer to the Internet), browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, information about your visit (including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time)), information you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

3.3 Information we receive from other sources We may receive and collect information about you if you use any other websites we operate or websites that are otherwise connected to the Services (such as third-party websites including, for example our business partners’ websites.

3.4 Information we receive from your employer/colleagues If your employer is a business Member, we may also in some cases receive information about you from your employer/colleagues. Such information will in general include your name, work e-mail address and phone number, and other professional information such

May, 3 2018 as your job title. In these cases, we will only collect Personal Data that is relevant with regard to you being a representative of your employer.

4. How do we use your Personal Data We collect and use the Personal Data we collect in a manner that is consistent with this Privacy Policy. We may use the Personal Data as described below in this section 4. The relevant legal basis for each purpose is presented within brackets.

4.1 All Users We will use the Personal Data held about you to (i)

carry out our obligations arising from any contracts entered into between you and us (which is based on fulfilment of the agreement between us);

(ii)

notify you about changes to our service (which is based on fulfilment of the agreement between us);

(iii)

provide you with information, publications, surveys, event details, assistance, and services that you request from us (which is based on our legitimate interest in providing you with relevant information and services as part of our business);

(iv)

enquire about whether you would like to join as a member and provide you with information about our services, this includes the use of Personal Data to deliver relevant marketing information to you, enable selected third parties to provide you with relevant marketing information or services, and to make suggestions and recommendations to you and other Users of our Site about goods or services that may interest you or them, including but not limited to suggestions and recommendations about events, membership benefits and offers, newsletters and publications (which is based on our legitimate interest in marketing our services and products);

(v)

ensure that content from our Site is presented in the most effective manner for you and for your computer and that you are able to use the various features of the Site. This includes administering our Site and conducting internal operations, including troubleshooting, data analysis, testing, research and using Personal Data for statistical and survey purposes to improve our Site. Your Personal Data is also processed to allow you to participate in interactive features of our Site, when you choose to do so and as part of our efforts to keep our Site safe and secure (which is based on our legitimate interests in ensuring the functionality of our Site, improving our services and enhancing safety and security);

May, 3 2018 (vi)

respond to inquiries you have submitted to us or otherwise fulfill the purposes for which you submitted such information to SACCNY (which is based on our legitimate interest in responding to inquiries as this is an important part of our business activities); and

(vii)

provide you with information about services we feel may interest you, including but not limited to speaker and other exposure opportunities at our conferences (which is based on our legitimate interest in expanding our network as well as providing you or the company that you represent with opportunities to take part in events and conferences).

In relation to purposes (iii) to (vii), we keep our processing of Personal Data to a minimum and we have conducted a balance of interests test with the result that our legitimate interests overweighs your interest in not having your Personal Data processed for these purposes. You are always entitled to object to this assessment. You can read further about your rights below.

You can unsubscribe from any and all marketing from SACCNY at any time. For more information about how to opt in and out from our marketing communication and your rights in this regard, please see section 7.2 below.

4.2 SACCNY Members If you are a SACCNY Member, in addition to the above, we will use information held about you to (i)

carry out our obligations arising from membership and any contracts entered between you and us (which is based on fulfilment of the agreement between us);

(ii)

display it in our Member Directory which is available for all Members and advertisers (which is based on your consent thereto);

(iii)

provide you with benefits relating to your membership or the membership of the company that you represent (which is based on our legitimate interest to administer membership services); and

(iv)

Personal Data that we receive from your employer/colleagues will only be used to contact you in your capacity as a Member representative in matters relating to membership and thereto related services and opportunities (which is based on our legitimate interest in administrating your employer’s membership).

May, 3 2018

In relation to purposes (iii) and (iv) above, we keep our processing of Personal Data to a minimum and we have conducted a balance of interests test with the result that our legitimate interests overweighs your interest in not having your Personal Data processed for these purposes. You are always entitled to object to this assessment. You can read further about your rights below.

Information displayed in the Membership Directory may be used to facilitate contact and interaction between our Member companies provided that they adhere to the same restrictions regarding treatment of Personal Data as set out in this Privacy Policy. This interaction is not controlled by SACCNY. 5. Disclosure and transfer of your Personal Data 5.1 No sale of Personal Data SACCNY is not in the business of selling Personal Data. However, there are certain circumstances in which we may disclose, transfer or share your Personal Data with certain third parties without further notice to you, as set forth below. In the event that we disclose, transfer or share your Personal Data, we will take reasonable steps to make sure that your Personal Data will not be treated less favorably than as set out in this Privacy Policy.

5.2 Internally We may share your Personal Data with our group companies: The Swedish-American Fund, Inc., The Swedish-American Chamber of Commerce AB and GatewayUSA LLC for purposes consistent with this Privacy Policy. Our group companies will be bound to maintain the shared Personal Data in accordance with this Privacy Policy.

5.3 Third Parties and Partners We may share your Personal Data with our service providers who process Personal Data on behalf of SACCNY to perform certain business-related functions. These currently consist of our email service provider Mailchimp, our payment solutions provider Shopify and Eventbrite, which provides a service to sign up for events. When we engage another company to perform such functions, we may provide them with information, including Personal Data, in connection with their performance of such functions. Such third parties do not include advertisers or marketers that would contact or solicit you. We may also share your Personal Data with business partners that we co-organize events with. If we plan to share your Personal Data with such business partners, we will notify you about that in connection with you registering for the event. We will only disclose Personal Data about you to such third parties and partners provided that they adhere to

May, 3 2018 the same restrictions regarding treatment of Personal Data as set out in this Privacy Policy.

5.4 Legal requirements etc.

We may disclose your Personal Data if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation or if required for SACCNY to be able to defend itself against a claim. This includes exchanging information with other companies and organizations for purposes of fraud protection and credit risk reduction.

6. Storage of your Personal Data SACCNY and its servers are located in the U.S. (i.e. outside the EEA, Switzerland and the UK). We may store Personal Data on SACCNY servers and it may be processed by third parties to whom we have transferred it in accordance with this Privacy Policy. Such processing by third parties take place in the U.S and in Canada.

When transferring Personal Data to countries outside the EU/EEA, we use standard contractual clauses approved by the European Commission to ensure a sufficient level of protection for your Personal Data. The standard contractual clauses can be found via the following link: http://ec.europa.eu/justice/data-protection/internationaltransfers/transfer/index_en.htm. We take all steps reasonably necessary to ensure that your Personal Data is treated securely and to protect the Personal Data collected as set out in this Privacy Policy from loss, unauthorized use, inadvertent disclosure, alteration and destruction. However, kindly note that no network, server, database or Internet or e-mail transmission is ever fully secure or error free. Thus, you should take special care in deciding what information you send to us electronically. We ask you to please keep this in mind when disclosing any Personal Data.

7. Your choices and rights 7.1 Limit the Personal Data You can browse our Site and use some of the Services without providing any Personal Data or with limiting the Personal Data you provide. If you choose not to provide any Personal Data or limit the Personal Data you provide, you may not be able to use certain functionalities of the Services.

7.2 Electronic marketing communications.

If you are receiving e-mails from SACCNY that means you have subscribed to our lists, attended an event, spoken at an event or been a member. Other contacts may also have been accumulated. As a subscriber of our email-list, we will send you electronic marketing communication. You may opt out of receiving these electronic marketing

May, 3 2018 communications at any time by clicking on the "Unsubscribe" link at the bottom of any electronic communication.

Kindly note, that it may take up to forty-eight (48) hours for us to process an unsubscribe request. Even after you opt out of all electronic marketing communications, we will retain your Personal Data in accordance with this Privacy Policy, however, we will no longer use it for direct marketing purposes.

7.3 Access, Update, Correct or Delete Your Personal Data You are entitled to know what Personal Data we are processing regarding you, and you can request a copy of such data. You are entitled to have incorrect Personal Data regarding you corrected, and in some cases you may request that we delete your Personal Data (if, for example, the Personal Data is no longer necessary for the purpose for which it was collected). You also have the right to withdraw your consent or object to certain processing of your Personal Data, and request that the processing of your Personal Data be limited. Please note that limitation or deletion of your Personal Data may result in us not being able to fulfil our commitments. You are also entitled to extract your Personal Data in a machine-readable format and to transfer the Personal Data to another controller.

You can exercise any of these rights by contacting us directly by email info@saccny.org or at the address below under section 10. Please make sure to specify in the email which right(s) you wish to exercise.

Please note that we will consider and respond to all requests in accordance with applicable law. All requests to exercise data protection rights will be assessed by us on a case-by-case basis. There may be circumstances where we are not legally required to comply with your request because of the laws in your jurisdiction or because of exemptions provided for in data protection legislation.

If you have a complaint about how we handle your Personal Data, please get in touch with us on any of the addresses set out in section 10. You also have the right to lodge a complaint with the relevant local data protection authority.

7.4 How Long We Retain Your Personal Data We will not keep your Personal Data longer than necessary. We will store Personal data related to your Membership for the entire duration of your membership. After a membership cancellation, your Personal Data related to your membership will be removed from our system within 30 days. Personal data collected on our website as described in section 3.2 will be automatically deleted after 12 months and Personal Data stored in our systems due to subscriptions to our mailing list will remain in our systems until you decide to unsubscribe from our mailing list. Your Personal data (e-mail address

May, 3 2018 and Name) will be deleted from our e-mail and CRM system within 72 hours after unsubscribing. If you represent your employer, we will process your Personal Data until we receive information that you no longer represent your employer. The time period will vary between different Users and the kind of Personal Data being processed by us in accordance with what is permitted under applicable law. Even if we delete your Personal Data it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.

8. Limitations and disclaimers 8.1 Links on SACCNY´s website This Privacy Policy applies to all our services and communication. Our Site and the Services may contain links to other websites that are not operated or controlled by us.

Please note, that if you follow these links, this Privacy Policy will not be applicable. We do not accept any responsibility or liability for the treatment of Personal Data on these websites and we recommend that you check their respective privacy policies before submitting any Personal Data to these websites. Please contact the websites directly for information on their respective privacy policies.

8.2 Children under 16 years old We do not knowingly collect Personal Data from children under the age of sixteen (16).

If you are under the age of sixteen (16), please do not submit any Personal Data through the Services.

We encourage parents and legal guardians to monitor their children's internet usage and to help enforce our Privacy Policy by instructing children never to provide Personal Data through the Services without their permission. If you have reason to believe that a child under the age of 16 has provided Personal Data to us through the Services, please contact us (see section 10 below) and we will delete that information from our databases.

9. Changes to this Privacy Policy It may be necessary for us to make changes to this Privacy Policy due to for example that the Services and/or SACCNY´s business may change from time to time. We reserve the right, in our sole discretion, to update, amend or otherwise change this Privacy Policy at any time and will notify you in advance of changes to this Privacy Policy via email [you will also find it uploaded on our website].

We ask you to please review this Privacy Policy periodically, and particularly before you provide any Personal Data.

May, 3 2018 10. Contact For further information regarding the treatment of your Personal Data by SACCNY and its group companies, please feel free to contact us at our address: 570 Lexington Avenue, 20th Floor, New York, NY10022, by e-mail: info@saccny.org or call us at Tel: +1 212 838 5530