Dashy Privacy Policy

LAST UPDATED: 2023-04-13

This privacy policy explains how we collect and use your personal data, as well as the rights you have and how to exercise them.

1 Introduction

Dashy Studios respects individual privacy and values the confidence of the visitors of our websites, our customers, employees, business partners and others with whom we do business. We strive to process Personal Data in a manner consistent with the laws of the countries in which we do business. In the European Union, this includes the General Data Protection Regulation ((EU) 2016/679).

The purpose of this Policy is to inform you and explain in all transparency:

  • why and how Dashy collects, processes and stores your personal data;
  • what its role as "controller" of your personal data involves; and
  • what your rights and our obligations are in relation to this processing.

2 Definitions

For purposes of this Policy, the following definitions shall apply:

"personal data" means any information that directly or indirectly relates to an identified or identifiable natural person. Data such as names, e-mail addresses, phone numbers but also data such as photos or IP addresses can be covered if the information can be linked to a person

"processing" refers to all handling that is performed upon personal data or sets of personal data such as collection, registration, organization, structuring, storage, disclosure through transfer and deletion. The verb "to process" shall be construed accordingly.

"processor" means a natural or legal person which processes personal data on behalf of the controller. Dashy's processors may be subsidiaries, affiliates or third-party suppliers and service providers. In all cases, Dashy will conclude a data processing agreement with its processor to ensure your personal data is processed in accordance with the GDPR.

3 Responsibility

As your potential business partner, employer or supplier, we need to be able to process your Personal Data. In that context, and for the purpose of the General Data Protection Regulation ((EU) 2016/679), Dashy will act as the”data controller”, i.e. the entity responsible for the processing of collected personal data.

Dashy Studios has the following organization number and contact details:

Dashy Studios AB

Reg. No. 559393-6346

Adress: ℅ Space, Mäster Samuelsgatan 45, 111 57 Stockholm

3.1 Supervising Authorities

If you have any comments or complaints about our processing of your Personal Data, you may contact the authorized supervisory authority in the jurisdictions listed below. Each supervisory authority is responsible for monitoring compliance with the law, and if you believe that Dashy Studios handles your Personal Data improperly, you may file a complaint to the supervisory authority.

Integritetsskyddsmyndigheten

Box 8114, 104 20 Stockholm

4 Why and what types of personal data we process

4.1 Recruitment

4.1.0.1 Purpose

Dashy processes Personal Data for the purpose of finding new employees, be able to contact you and administer your recruitment process, as well as to create and conclude an employment contract. We might further process Personal Data to maintain and improve our recruitment process, to personalize it and to measure its performance. The following Personal Data may be processed in accordance with the above purpose:

  • Contact information (such as name, address, e-mail address and telephone number)
  • Government ID (such as social security number, personal number, passport copy)
  • Sex or gender
  • Date of birth
  • Information including data pertaining to your health
  • Working experience
  • Business title
  • Employment lifecycle dates (start and end dates)
  • Employee demographics (for example sex, gender and age)
  • Information regarding secondary employments
  • Additional information from CV voluntarily submitted (e.g. photos or personal interests)

4.1.0.2 Legal basis

Your Personal Data processed in accordance with this section is processed on the basis of being a necessity in order to enter into an employment agreement with you and in order to fulfill Dashys's legitimate interest of being able to respond to your application, to recruit new employees, plan work distribution and conduct staffing planning, and to review your work performance. Your Personal Data is further processed to fulfill Dashy’s legitimate interest of maintaining and improving as well as personalizing and measuring the performance of our recruitment process. For example, we use the Personal Data we collect to analyze and understand how you interact with Dashy and how you, amongst other

things, experience the recruitment process. It helps us to discover that, for example, certain measures or initiatives are more efficient than others (e.g. certain recruitment campaigns). Such discoveries help us to redesign the process and improve it for both Dashy and you.

4.2 Events

4.2.1.1 Purpose

Dashy processes Personal Data for the purpose of hosting and administrating events, for example to correspond with participants and suppliers before, during, and after the event, to manage food orders or applications. The following Personal Data may be processed within the scope of hosting and administrating events:

  • Contact information (such as name, address, e-mail address and telephone number)
  • Government ID (such as social security number, personal number, passport copy, work permits)
  • Sex or gender
  • Date of birth
  • Information voluntarily submitted (e.g. in email conversations or via applications or evaluations)
  • Business title
  • Health related data voluntarily submitted (e.g. information about allergies)
  • Emergency contact (voluntarily submitted)

Dashy will further use and store your Personal Data for sending you newsletters and emails using mailing lists, which contain information about Dashy and its upcoming events, as well as for documenting your consent. Personal Data processed for these purposes may include for example:

  • Contact details (such as name, email and phone number)
  • Notification preferences

4.2.1.2 Legal basis

Your Personal Data processed in accordance with this section is processed on the basis of Dashy’s legitimate interest of managing and administrating events as well as your legitimate interest to participate in said events and, where applicable, to fulfill Dashy’s legal obligations.

4.3 Marketing and social media presence

4.3.0.1 Purpose

Dashy will process your Personal Data for the purpose of visualizing our culture and every day work by posting photos from, for example internal and external events. We use LinkedIn, Instagram, Twitter and Youtube to maintain a social media presence with our business partners and employees. You are entitled to ask Dashy to remove any photos of you from our social media accounts at any time. Personal Data processed for this purpose may include:

  • Photos or videos of you from events, conferences and meetings

4.3.0.2 Legal basis

Your Personal Data processed in accordance with this section is processed on the basis of Dashy's legitimate interest of cultivating our network, maintaining our culture and ensuring knowledge sharing. Dashy will further process your Personal Data on the basis of Dashy’s legitimate interest to publish information about our business on our website, in printed materials and on social media as well as to market our business through such platforms. 

4.4 Client assignments

4.4.0.1 Purpose

In order for Dashy to deliver our services in accordance with both Dashy’s and our

clients’ expectations, Dashy will process Personal Data for the purpose of fulfilling our assignments and to communicate with applicable counterparties or other parties connected to the assignment. Dashy will further process Personal Data for administering payments, invoicing and bookkeeping as well as scheduling meetings. Dashy will also process Personal Data to provide efficient and accurate documentation and administration with respect to the assignment and to facilitate an efficient process. Personal Data processed for the purposes above may include:

  • Contact information (such as name, address, e-mail address and telephone number)
  • Government ID (such as social security number, personal number, passport copy)
  • Sex or gender
  • Date of birth
  • Business title
  • Information voluntarily submitted (e.g. in email conversations)
  • Financial information (e.g. invoicing details)
  • Scope of the assignment

4.4.0.2 Legal basis

Your Personal Data processed in accordance with this section is processed on the basis of Dashy's legitimate interest of fulfilling our assignments and client agreements and, where applicable, to fulfill Dashy’s legal obligations.

4.5 Client relations

4.5.0.1 Purpose

Dashy will process your Personal Data to manage client relations and to correspond with clients and prospective clients, for example to conclude and execute an agreement, evaluate assignments, participate in tenders and administrate access to our services. Personal Data processed for these purposes may include for example:

  • Contact details (such as name, email and phone number)
  • Social security relevant information (social security number)
  • Information voluntarily submitted (e.g. in email conversations)
  • Financial information (e.g. if our client is operating as a sole trader)

4.5.0.2 Legal basis

Your Personal Data processed in accordance with this section is processed on the basis of Dashy's legitimate interest of managing customer relations and corresponding with clients and prospective clients and in order to fulfill or enter into a client agreement and, where applicable, to fulfill Dashy’s legal obligations.

4.6 Supplier relation management

4.6.0.1 Purpose

Dashy will process your Personal Data to manage supplier relations and to correspond with suppliers and prospective suppliers, for example to conclude and execute an agreement and evaluate supplier services. Personal Data processed for these purposes may include for example:

  • Contact details (such as name, email and phone number)
  • Social security relevant information (social security number)
  • Information voluntarily submitted (e.g. in email conversations)
  • Financial information (e.g. if our supplier is operating as a sole trader)

4.6.0.2 Legal basis

Your Personal Data processed in accordance with this section is processed on the basis of Dashy's legitimate interest of managing supplier relations and corresponding with suppliers and prospective suppliers and in order to fulfill or enter into a supplier agreement and, where applicable, to fulfill Dashy’s legal obligations.

4.7 Cookies

4.7.0.1 Purpose

Dashy uses cookies to provide a website, which our visitors can use as intended by us and to collect statistics on site performance. The cookies make it possible for us to collect and analyze information on site performance and usage, to remember your preferences, and to improve the user experience. The cookies further allow you to navigate between pages easily. Personal Data processed through the placement of cookies may include for example:

  • IP-address
  • Length of visit on the website
  • Number of pageviews
  • Choices made while browsing the website
  • Traffic sources and website navigation (for example, which search engine is used to access the site)

Most browsers allow you to turn off cookies. To do this look at the “help” menu on your browser. Turning off cookies may restrict your use of the website and/or delay or affect the way in which it operates. Read more about how we use cookies in our Cookie Policy.

4.7.0.2 Legal basis

Your Personal Data processed in accordance with this section is processed on the basis of Dashy's legitimate interest to provide a user-friendly and well-functioning website, and to support our commercial interest of collecting statistics of the visitors on our website. 

4.8 Investor relations

4.8.0.1 Purpose

Dashy will process your Personal Data to manage investor relations and to correspond with investors and prospective investors, for example to conclude and execute an agreement or to provide and exchange information. Personal Data processed for these purposes may include for example:

  • Contact details (such as name, email and phone number)
  • Date of birth
  • Social security relevant information (social security number)
  • Financial information

4.8.0.2 Legal basis

Your Personal Data processed in accordance with this section is processed on the basis of Dashy's legitimate interest of managing investor relations and corresponding with investors and prospective investors and, where applicable, to fulfill Dashy’s legal obligations.

4.9 Legal obligations

4.9.0.1 Purpose

Dashy will process your Personal Data in order to fulfill its legal obligations, for example in the area of company law, market abuse regulations or bookkeeping and tax legislation. Personal Data processed for these purposes may include for example:

  • Contact details (such as name, email and phone number)
  • Date of birth
  • Social security relevant information (social security number)
  • Financial information

4.9.0.2 Legal basis

Your Personal Data processed in accordance with this section is necessary in order for Dashy to fulfill its legal obligations. 

4.10 Internal investigations

4.10.0.1 Purpose

Dashy will process your Personal Data for the purpose of conducting internal investigations relating e.g. to breach of laws and/or attacks on Dashy’s IT-architecture. Such internal investigations will only be conducted due to concrete suspicions and s within legally permissible limits. Personal Data processed for this purpose may include the following, whenever and to the extent necessary:

  • Contact information (such as name, address, e-mail address and telephone number)
  • Business title
  • Personal Data in e-mail correspondence
  • Internet behavior such as visited web sites and time as well as scope of access
  • Name of accessed or downloaded files and time of access
  • Technical log information and IP-address

4.10.0.2 Legal basis

Your Personal Data processed in accordance with this section is processed on the basis of Dashy's legitimate interest of identifying, investigating and preventing unlawful actions against Dashy.

4.11 Establish, exercise and defend legal claims

4.11.0.1 Purpose

Dashy will process your Personal Data for the purposes of establishing, exercising and defending potential legal claims. Personal Data processed for these purposes may include the following data, whenever and to the extent necessary:

  • Contact information (such as name, address, e-mail address and telephone number)
  • Business title
  • Personal Data in e-mail correspondence
  • Internet behavior such as visited web sites and time as well as scope of access
  • Name of accessed or downloaded files and time of access
  • Technical log information and IP-address
  • Any other information necessary to achieve the purpose of the processing.

4.11.0.2 Legal basis

Your Personal Data processed in accordance with this section is processed on the basis of a balancing of interests. Dashy has a legitimate interest to process your Personal Data for these purposes in order to be able to establish, exercise and/or defend legal claims for example in the event of a dispute or controversy between you and Dashy and, if applicable, to exercise its rights and obligations under law.

5 How we collect your Personal Data

The main part of the Personal Data we collect is derived from you, for example your name, CV and similar as well as information provided by you in e-mails or by other means whilst communicating with us. We also collect Personal Data from third parties such as social medias (for example LinkedIn) and other data controllers acting on our behalf (for example recruitment agencies).

6 Sharing your Personal Data

6.0.1 Data processors

We will normally transfer Personal Data to external parties who helps us with e.g.

recruitment, accounting services, business development and event planning. These external parties process Personal Data under the instructions of Dashy.

6.0.2 Other data controllers

6.0.2.1 Clients

‍Purpose: To conclude client agreements and comply with our obligations connected to such. 

Legal basis: To fulfill our legitimate interest of administering client relations as well as developing and maintaining our business.

6.0.2.2 Travel and hospitality companies

Purpose: To facilitate your booking and to carry out business travel, including to accommodate your requests for travel arrangements and to meet regulatory requirements of visas and other cross border travel requirements. 

Legal basis: To fulfill your and our legitimate interest of facilitating business travels.

6.0.2.3 Governmental authorities

Purpose: To fulfill legal obligations in the areas of tax, social security, anti-fraud and anti-money laundering legislation.

Legal basis: To fulfill our legal obligations.

6.0.2.4 Courts and arbitral tribunals 

Purpose: To exercise, establish or defend legal claims. 

Legal basis: To fulfill our legal obligations.

6.0.2.5 Suppliers

Purpose: To conclude supplier agreements and comply with our obligations connected to such. 

Legal basis: To fulfill our legitimate interest of administering supplier (and potential supplier) relations as well as developing and maintaining our business. 

6.0.2.6 Trade unions, work councils and employer organizations

Purpose: To fulfill our legal obligations in the field of employment law, for example consultation obligations in relation to reorganizations, mergers and acquisitions.

Legal basis: To fulfill our legal obligations in the field of employment law.

6.0.2.7 Social media companies

Purpose: To visualize Dashy’s values, culture and everyday-work. To maintain a transparent, effective and fair dialogue with our clients, recruits and employees.

Legal basis: To fulfill our legitimate interest of maintaining a transparent and fair dialogue with our clients, recruits and employees as well as our legitimate interest to publish information about our business on our website, in printed materials and on social media as well as to market our business through such platforms. 

7 How We Protect Your Personal Data

We are committed to protecting your personal data from unauthorized access, use, disclosure, or destruction. We implement appropriate technical and organizational measures to ensure the confidentiality, integrity, and availability of your data. Only the people who need to process your Personal Data to fulfill our above stated purposes have access to it. We also require our service providers and third-party processors to comply with our data protection standards.

8 How long we store your Personal Data

We store your Personal Data only as long as we need to in order to fulfill our purpose for processing it, unless a longer storage period is required for legitimate reasons or required by law. After this we will erase or anonymize your data so that it can no longer be linked to you. The data retention period is determined by:

  • as long as you have an on-going business relationship with Dashy
  • as long as you have an on-going recruitment process with Dashy
  • as required by a legal obligation to which Dashy is subject (for example to retain bookkeeping materials)
  • to meet applicable statutes of limitations, for example to exercise, establish or defend claims in litigation or investigations
  • in cases where Dashy's processing has been based on your consent only, until you revoke your consent.

9 Your rights

9.0.1 Right to access

Dashy is transparent on how we process your Personal Data. If you would like to have further insights on what Personal Data we process about you, you have the right to receive access to the Personal Data together with an extract containing information about the  purposes of the processing; the categories of Personal Data concerned; categories of recipients; envisaged storage periods; information about where the Personal Data has been collected if it has not been collected from you, and existence of automated decision making.

Please note that we may be required to ask you for additional information if you use your right to access. This must be done to ensure that the Personal Data is disclosed to the correct person and to facilitate an efficient process.

9.0.2 Right to rectification

You always have the right to correct inaccurate Personal Data. Subject to purposes of the processing, you also have the right to complete any incomplete Personal Data.

Right to revoke previously given consent with future effect

You have the right to have Dashy erase your data if you withdraw consent and Dashy's processing has been based on your consent only.

9.0.3 Right to be forgotten

You are entitled to request to have your Personal Data erased, which we process if:

  • The Personal Data is no longer necessary in relation to the purposes for which they were collected or otherwise processed
  • You object against our legitimate interest and your reasons for objecting overrides our legitimate interest
  • You object against processing for direct marketing purposes
  • The Personal Data has been unlawfully processed
  • The Personal Data must be erased for compliance with a legal obligation to which Dashy is subject to

Please note that we have the right to deny your request should there be any legal obligations, which prevents us from erasing your Personal Data immediately. Such obligations may be due to bookkeeping and tax legislation, but also due to banking and money laundering legislation. Such may also be the case if the processing is necessary for us to establish, exercise or defend legal claims. If we cannot meet your request, we will instead restrict the processing of your Personal Data so that it may not be processed for any other purposes than those that denies the request for erasure.

9.0.4 Right to restriction

You have the right to request that our processing of your Personal Data is restricted. If you believe that the Personal Data we process is inaccurate, you have the right to request that the processing is restricted during the time we need to ensure whether the Personal Data are correct or not. Further, if we no longer need your Personal Data for the described purposes, but you need them to establish, exercise or defend legal claims, you have the  right to request that we restrict your Personal Data. i.e. you have the right to request that we do not delete your Personal Data.

9.0.5 Right to objection

You may object to any processing of your Personal Data processed on the basis of a legitimate interest, on grounds relating to your particular situation.

9.0.6 Data portability

You have the right to receive a machine-readable copy of the Personal Data processed on the basis of your consent or on the basis that the processing is necessary in order to perform a contract to which you are a party, and which Personal Data have been provided to Dashy by you.

9.1 How to exercise your rights

To exercise your rights as a data subject, please send an e-mail to [email protected].

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