Latest update: 2023-01-16
This Policy applies to:
Visitors of focalpay.se (the “Website”, “website”)
Participants in Focalpay sales processes, potential Focalpay customers (“Sales”)
Participants at trade shows and/or events where Focalpay is present
Potential customer prospects who submit their details for marketing purposes or other enquiries
Visitors to our third party social media platform pages
To any recruitment activity candidates and participants
Public records and company websites
Personal data is information about an identified or identifiable natural person. "Identifiable natural person" means a person who can be directly or indirectly identified specifically by reference to an identifier, e.g. name, identification number, location information, online identifier or other factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
The processing of Personal Data refers to an action or a combination of actions related to Personal Data - regardless of whether it occurs automatically or not - such as collection, registration, organization, structuring, storage, processing or modification, production, reading, use, delivery by transmission, dissemination or other provision, adjustment or combination, restriction, erasure or destruction.
We mainly process Personal Data collected directly from the individual in question, or other persons connected to the individual such as a manager or colleague. At times Focalpay collects Personal Information from third parties such as partners or social media platforms, relating to marketing, recruitment or public records.
Focalpay collects two categories of Personal Information:
If you complete one of our online forms on our website, we collect Personal Data. We also collect information if you provide your contact details during a trade show or event. Depending on how we engage with you, Focalpay will collect and process the below information. We have outlined further how we process the Personal Data in schedule X.
Company or organization
Organization address such as street number, postal code, city, country
Information collected through custom fields, if applicable.
Data concerning place of employment, position and/or title
Preferences and interests
Email conversations with the Focalpay team
Information relating to job applications
Some types of technical information is usually collected as a standard when you visit our website. This type of information may include:
Any website your visit linked from
Pages visited on the Focalpay website
Ad banners or other digital content viewed
Information provided by your browser that may be otherwise collected with some services
Focalpay uses third party service providers to offer services to our website visitors and potential customers. Therefore, we will need to share Personal Data to provide services and information to individuals if relevant. Additionally, some third party vendors, partners or authorities may gain access to Personal Data. Vendors of sub-processors may also access Personal Data.
We may share your Personal Data with third parties, for example in the following situations:
We share your Personal Data with partners and suppliers, during shared initiatives such as digital and physical events, trade shows, in addition to co-initiated sales and marketing campaigns.
Personal Data may be used and shared as we deem appropriate or required in order to comply with legal processes, lawful requests and applicable laws, for example to reply to subpoenas or government authority requests. For example, the Swedish Tax Agency and other authorities may require Personal Data to be disclosed by Focalpay. In these instances, Focalpay will only disclose this information if there is legal ground for it.
Personal Data may be used and disclosed to government authorities, law enforcement and private parties as Focalpay deems necessary or appropriate in order to protect our own or individuals’ safety, privacy, rights or property and to protect and to investigate and discourage unauthorized, unethical, illegal or fraudulent behavior.
Mergers & Acquisitions
In connection with an acquisition, a merger with another company or a division, the acquiring company and/or its hired consultants may require access to certain personal data that we process about you. In the event of such disclosure, we will ensure that the person receiving the personal data is covered by a confidentiality agreement.
You can opt out of marketing communications by clicking the unsubscribe link in our marketing emails, or alternatively by contacting us at email@example.com. Please note we may send emails related to our services (i.e. non marketing material) if required after opting out, if this is relevant to you and you are for example a customer or partner of Focalpay.
Additionally, we may obtain Personal Data from other third parties, including marketing or commercial partners, data providers and public sources. For example a business partner may share Personal Information with Focalpay if an individual expresses interest in learning about Focalpay’s platform or provided services.
We collect cookies, and we may collect log files for behavioral advertising, which you can opt out of if you wish. When you visit our website, Focalpay may use an automation tool to track activity. Based on activity, we might send out marketing offers, if consent is given. Focalpay will not process Personal Data with the automation tool unless a consent has been given.
The cookies collected include information about analytics services such as IP information for performance review, Google, LinkedIn, Facebook. Please note that you can withdraw consent at any time.
On the Focalpay website, this information is gathered using cookies and browser web storage (locally stored objects). Our service providers and business partners may collect information about you automatically, over time and across third-party websites and mobile applications. This can include information about your devices, and your activity on (or through) our website.
The information collected may include the below:
Geographic area (city, state, country)
Usage and actions taken on our website (pages viewed, time spent on website, navigation paths, access time, access length)
Device version and operating system type
With regards to applicants for employment, we process Personal Data. The Personal Data is processed based on Legitimate Interest in processing the Personal Data, and this does not violate applicants’ privacy rights.
Information processed may include:
The Personal Data of job applicants is used to match experience with specific roles available at Focalpay. The data is forwarded to hiring managers and individuals involved in the hiring process. The information gathered may originate from sources such as:
The candidate’s provided information
Information provided by recruitment agency
Online resources such as LinkedIn
By references provided by the candidate
We process this Personal Data to:
Provide quotes and services when requested by potential customers
Provide support related to our website features and products
Maintain and/or Improve features and functionalities in Focalpay’s services
Manage administration, orders
Manage prospect sales and contract processes
Sensitive Data includes information about race, ethnicity, religious beliefs, philosophical beliefs, political opinions, memberships in trade unions, and health and private life information. In general, Focalpay does not process any sensitive data about individuals. If any sensitive data is provided by an individual, it is only processed by us if consent is given for this, or if processing is legally required. We limit the use of personal identification numbers, and only process these when required to ensure individuals’ identification.
When we process your Personal Data, everyone in our business is required to comply with applicable data protection legislation and what is stated in this document to maintain a high level of protection for your privacy. We are obliged to:
Prevent unauthorized access to your personal data
Prevent dissemination of your personal data
Prevent other deviations when we process your personal data
We ensure that your Personal Data is treated confidentially, that your integrity is not put at risk by our processing of it and that we guarantee access to Personal Data in accordance with applicable data protection legislation.
Focalpay has implemented appropriate technical, organizational and physical measures to protect the Personal Information collected and processed about individuals. The measures are in place to provide a level of security appropriate in relation to the risk of processing Personal Information gathered, processed and stored in the event of a potential infringement.
Focalpay ensures to:
Treat all Personal Information with confidentiality
Prevent spreading Personal Data
Prevent unauthorized access to Personal Data
Adhere to applicable data protection legislation with regards to availability of Personal Information
We continuously work to develop and assess our work concerning progressing Personal Data
We have appointed staff to manage Personal Data-related topics
We have incident management procedures to enable efficient action-taking in the event of Personal Data incidents
We enter Personal Data processing agreements with all partners, customers, suppliers and other interested parties who process Personal Data on our behalf as required
Personal Data classification to introduce security measures in relation to risk assessment
Encryption and pseudonymization to reduce Personal Data progressing risk
Restricting access to Personal Data so that only those that need access to fulfill contractual or statutory obligations have it
Using detection, prevention, recreation and reporting systems effectively
To get access to Focalpay’s premises, access cards are required. Additionally, parts of the premises are video-monitored.
Focalpay processes and stores information only for as long as it is required, in relation to the purpose of which the information was obtained. The legal basis will consequently depend on the Personal Information in question and the specific context in which we collect it.
We will keep the information in instances where Focalpay has a legitimate cause for it, for example when providing individuals with requested services and information, or to comply with tax, legal and accounting regulations.
If there is no legitimate cause to process or retain Personal Data, it will either be anonymized or deleted. If this is not possible due to Personal Data being required to be stored in archives, it will be securely retained and isolated from any processing until it can be deleted.
We always strive to keep Personal Information within the European Economic Area (EEA). Sometimes we may engage suppliers located outside the EEA, for example third party service providers or companies that assist with technical support and/or maintenance of our IT services. In these instances, we will ensure that these suppliers do not have access to Personal Data, and in case this is not possible, we will ensure regulations are followed. Any Personal Information shared will always be kept to a minimum, in relation to the purpose of which it is shared. Regardless of where the Personal Information is transferred, Focalpay takes necessary precautions ensuring that the security level and processing is in accordance with the GDPR by for example implementing the EU Commission’s Standard Contractual Clauses. This requires our non-EEA members to protect Personal Information they process from the EEA in accordance with European Union data protection laws.
If our website contains links to third party websites or material published by third parties, these links are for information only. As we have no control over the material or the processing of personal data on these pages, we assume no responsibility for the processing of personal data in connection with such pages.
All individual Data Subjects have the right to request information regarding our processing and storing of their Personal Information, if any has been collected. Individuals can contact Focalpay to access, correct, update or request deletion of their information. Please note that we may have to ask details about the individual Data Subject, to ensure that the information requested is provided to the correct person securely.
Furthermore, individual data subject can:
Correction of of Personal Data that we have processed if it is incorrect
Submit a request that Focalpay deletes the Personal Data held about the individual Data Subject. In this instance, please note that Focalpay may be required by law to decline such a request if the information is required for tax records or bookkeeping, or is necessary to defend legal claims
Request to limit Focalpay’s processing of Personal Data. In these instances, Focalpay may need to review the situation prior to reaching a final decision
Request to transfer Personal Data to another Controller, if technically possible and aligned with regulations and laws.
Object processing of Personal Data or ask for restricted processing of Personal Data
Request portability of Personal Data
Object to the processing activities of the Personal Data
Opt out of marketing communications. To opt out of email communications, please unsubscribe in the email sent from Focalpay. For opting out to all forms of marketing communications, please email firstname.lastname@example.org
Withdraw a previously given consent to processing Personal Information related to cookies. Please note that withdrawing consent does not impact the lawfulness of processing made prior to withdrawal, or impacts processing of Personal Data with regards to lawful processing grounds
Make a complaint about Focalpay’s collection or processing of Personal Information to a data protection authority: email@example.com, 08-657 61 00, Integritetsskyddsmyndigheten, Box 8114, 104 20 Stockholm, Sweden
Focalpay will answer all questions or requests from Data Subjects with regards to exercising data protection rights in accordance with applicable data protection regulations and laws.
We strive to work with individuals to ensure we reach a fair solution for any potential complaint or concern about privacy. If an individual believes that Focalpay has been unable to address and assist with a concern, question or complaint, and is located in the EEA, the individual has the right to create a complaint with the supervisory authority.
Purpose of processing
First name, Last name
The processing is necessary for us to be able to deliver the service to the website user. The personal data is used to identify the user.
The personal data is also processed so that we can defend ourselves if legal claims are made against us by users.
6.1 f) Of legitimate interest to the personal data controller.
We process the personal data to be able to communicate and to identify the individual that has contacted us.
We have determined that we have a commercially legitimate interest in processing your personal data for this purpose. We believe that our interest in being able to defend ourselves in legal proceedings outweighs the risks to your privacy, especially considering that we must be able to contact the individuals that want to interact with us.
Used so that the individual can register in our web site our at our events we can communicate with the user.
The email address is also used so that we can send commercial and marketing material about our current and future services.
We process your personal data to provide you with marketing material about our current and future services and to continue our commercial contact.
We have determined that we have a commercially legitimate interest in processing your personal data for this purpose. We do not consider that our interest in being able to market our products poses a risk to your privacy because no sensitive personal data is processed. You can also choose to opt out of receiving our marketing mailings by following the instructions we send or by contacting us.
The phone number is used so that we can contact the individual with in order to conduct sales and other marketing measures.s.
We process your personal data to provide you with marketing material about our current and future services and conduct sales activities.
Amount of transactions per year
Used so that the user can register in the service and so that we can communicate with the user.
The company name or amount of transactions per year is also used so that we can send marketing material about our current and future services.
We process your personal data to provide you with marketing material about our current and future services.
Information collected through custom fields, if applicable
Used so that the user can register in the service and so that we can communicate with the user with relevant information and offers.
We process this personal data in order to be able to perform our sales activities to you as a representative of a potential customer of us. We also need to process our email conversations with you in order to perform our sales services.
We have determined that we have a commercially legitimate interest in processing your personal data for this purpose. We do not consider that our interest in performing sales activities poses a risk to your privacy because no sensitive personal data is processed and this is something that is expected in your role within your company.
Collected for work applicants for HR-purposes, so that Focalpay can communicate with the potential employees and match with HR partners etc.
We process this data in order for us to be able to evaluate employee candidates. This information may also be shared with HR-partners.
We have determined that we have a commercially legitimate interest in processing your personal data for this purpose. We do not consider that our interest in processing data about potential employee candidates poses a risk to your privacy because all data that we process in relation to employee candidates are processed with high security standards. All material is deleted as soon as we have determined that a candidate is not a good match or if we decide to hire the person.
This information is not and cannot be used to identify any individual. It is collected automatically, anonymously via IP addresses, so that we can improve our website’s performance and analyze trends.
Cyberdesign nordics AB
All personal data processed in the services
Google Cloud EMEA Limited
Open Payments AB
The Account Information Service
Personal data related to the consumer's process in the account information service, social security number and bank account.
Focalpay is an innovative and disruptive commerce platform with cloud-native checkout (point of sale), backoffice and payment software provided to merchants and businesses across Europe. Our cost-efficient, groundbreaking infrastructure has merged the payment and retail processes in one system, enabling secure, sustainable shopping journeys both for retailers and consumers. A seamless, streamlined, secure flow is achieved by integrating Focalpay’s platform. Focalpay is headquartered in Stockholm, and is growing fast internationally.
Org. number 559312–7771
104 25 Stockholm
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