Privacy Policy

Data protection is a matter of trust and your trust is important to us. In order for you to feel safe when you visit our web pages, we strictly adhere to the legal regulations when processing your personal data. We would like to inform here about our collection and use of data. The following privacy policy explains what information is collected from you on our web pages. We also describe which of these data we process and use and how this happens. You will also find out who you can turn to in this context.

In this Privacy Policy, we use the term “personal data” to describe information that can directly or indirectly identify a natural person. We do not consider personal data to include information that has been anonymized or aggregated in such a way that it cannot, either with the help of other information or in any other way, be used to identify a specific natural person. 
No data will be sold on to third parties.

Personal data controller:
The Active Brands Group Scandinavia AB (org. no. 559008-0171, hereinafter referred to as “ABG”) is the personal data controller for the processing of your personal data in relation to purchases www.nordic.varlion.com


What personal data do we collect about you as a customer and for what purpose
The purposes for processing your personal data at ABG are:

1) Be able to complete purchases at ABG

Treatments performed

  • Delivery (including notification and contacts regarding the delivery)
  • Identification and age control
  • Handling of payment (including analysis of possible payment solutions which may include a check against payment history and collection of credit information from Klarna)
  • Handling of complaints and warranty matters

Categories of personal data

  • Name
  • Social security number
  • Contact details (e.g. address, email and phone number)
  • Payment history
  • Payment Information
  • Purchase information (e.g. which item has been ordered or if the item is to be delivered to a different address)

Legal basis:
Fulfillment of the purchase agreement. This collection of your personal data is required in order for us to be able to fulfill our obligations according to the purchase agreement. If the information is not provided, our obligations cannot be fulfilled and we are therefore forced to refuse you the purchase

2) Enable targeted marketing
by e-mail, SMS and other channels based on your previous purchases or use of ABG’s channels. In order to communicate relevant information and offers to you, we analyze the data that we have collected in various ways, e.g. by sorting customers into different customer segments.

Treatments performed

  • The creation of your personal offers and general offers, customized news, product recommendations, inspiration
  • Analyzes of the data we collect for the purpose. Based on the data we collect (e.g. purchase history, age, gender and stated preferences) we perform an analysis that may result in you being sorted into a customer group (so-called customer segment)

Categories of personal data

  • Contact details (email and phone number)
  • Customer segment (information about which customer segment you belong to, e.g. age and gender)
  • Purchase and user-generated data (eg click and visit history)
  • Specified customer choices regarding products and services

Legal basis:
Legitimate interest. The processing is necessary to satisfy our legitimate interest in communicating personal and relevant information and offers to you

3) Be able to handle customer service cases 
Treatments that are performed

  • Communication and answering any questions to customer service (via phone or in digital channels, including social media
  • Identification
  • Investigation of any complaints and support cases (including technical support)

Categories of personal data

  • Name
  • Social security number
  • Contact details (e.g. address, email and phone number)
  • Your correspondence
  • Details of time of purchase, possible errors/complaints

Legal basis:
Legitimate interest. The processing is necessary to satisfy our and your legitimate interest in handling customer service matters

4) Be able to evaluate, develop and improve ABG’s services, products and systems 
Treatments that are performed

  • Customization of services to become more user-friendly (e.g. changing the user interface to simplify the flow of information or to highlight features frequently used by customers in our digital channels)
  • Production of documentation with the aim of improving goods and logistics flows (e.g. by being able to forecast purchases, stocks and deliveries)
  • Preparation of documentation to develop and improve our range
  • Production of documentation to develop and improve our resource efficiency from an environmental and sustainability perspective (e.g. by streamlining purchasing and planning deliveries)
  • Give our customers the opportunity to influence our range
  • Preparation of documentation to improve IT systems with the aim of generally increasing the security of the company and our visitors/customers
  • Analyzes of the data we collect for the purpose. Based on the data we collect (e.g. purchase history, age and gender), you are sorted into a customer group (so-called customer segment) for which analyzes are then performed on an aggregated level using de-identified or pseudonymized data, without any connection to you as an individual. The insights from the analysis are the basis for which products are purchased and how we develop the website

Categories of personal data

  • Age
  • Sex
  • Place of residence
  • Correspondence and feedback regarding our services and products
  • Purchase and user-generated data (eg click and visit history)
  • Technical data concerning devices used and their settings (e.g. language setting, IP address, browser settings, time zone, operating system, screen resolution and platform)
  • Information about how you have interacted with us, i.e. how you have used the service, login method, where and how long different pages were visited, response times, download errors, how you reach and leave the service, etc.

Legal basis:
Legitimate interest. The processing is necessary to satisfy our and our customers’ legitimate interest in evaluating, developing and improving our services, products and systems

5) To be able to implement and manage participation in competitions and/or events. 
Treatments performed

  • Communication before and after participation in a competition or event (e.g. confirmation of registrations, questions or evaluations)
  • Identification and verification of age
  • The selection of winners and the distribution of any winnings

Categories of personal data

  • Name
  • Social security number or age
  • Contact details (e.g. address, email and phone number)
  • Information provided in competition entries
  • Data provided in evaluations of events

Legal basis:
Legitimate interest. The processing is necessary to satisfy our and your legitimate interest in managing your participation in competitions and/or events.

6) To be able to fulfill the company’s legal obligations. 
Treatments performed

  • Necessary handling for the fulfillment of the company’s legal obligations according to legal requirements, judgments or authority decisions (e.g. the Accounting Act, the Money Laundering Act or the rules on product liability and product safety, which may require the production of communication and information to the public and customers about product alerts and product recalls in the event of, for example, a defect or harmful to health)

Categories of personal data

  • Name
  • Social security number
  • Contact details (e.g. address, email and phone number)
  • Payment history
  • Payment formation
  • Your correspondence
  • Details of time of purchase, place of purchase, possible errors/complaints

Legal basis:
Legal obligation. This collection of your personal data is required by law. If the information is not provided, our legal obligation cannot be fulfilled and we are therefore forced to refuse you the purchase.

Recipients of data where the recipient is a personal data processor
In cases where it is necessary for us to be able to offer our services, we share your personal data with companies that are so-called personal data processors for us. A personal data processor is a company that processes the information on our behalf and according to our instructions.

We use the help of other companies that process your personal data on our behalf and according to our instructions. This applies, for example, to companies that provide IT services and companies that help us with mailings. 
If an order is made for an item that is sent directly from the supplier, ABG will send over the information needed to be able to complete and fulfill an order from the supplier.

When you use Chat and/or FAQ, Imbox may manage and store personal data such as e.g. phone number, first and last name, address, e-mail, IP number that you provide yourself to be able to log and save history from previous chats.


Recipients of data where the recipient is an independent personal data controller
We also share your personal data with certain companies that are independent personal data controllers. The fact that the company is an independent personal data controller means that it is not us who control how the information provided to the company is to be processed. When your personal data is shared with a company that is an independent personal data controller, the company’s privacy policy and personal data management apply. Independent personal data controllers with whom we share your personal data are:

  • Government authorities (the police, tax authorities or other authorities) if we are obliged to do so by law or in case of suspicion of crime
  • Companies that offer payment solutions (card processing companies, banks and other payment service providers)

Klarna
will collect personal data about you in connection with payment. Klarna is thus the personal data controller for such personal data according to Klarna’s terms and conditions

Companies that provide general goods transport (logistics companies and forwarders). 
Freight forwarders will receive the personal data required to be able to complete and deliver an order in accordance with the fulfillment of the purchase agreement. 
Freight forwarders in this case are:

  • PostNord
  • DHL

Storage period
We only save personal data for as long as it is necessary, after which it is deleted.

We will save personal data for 36 months after your last purchase in order to help with any warranty/complaint matters. After that, we will de-identify your personal data, which means that we remove all identification possibilities so that the data that continues to be processed can no longer be linked to you as a natural person.

We will save personal data for direct marketing 12 months after your last purchase, you can choose to end direct marketing mailings before then

In addition, we save your data during the time we are obliged to do so to fulfill legal obligations, e.g. regarding accounting.

Your rights 
Right of access :
We want to be open and transparent with how we process your data. If you want to gain insight into the personal data processing that we do in relation to you, you have the right to request information about the processing. (That is, information about purposes, categories of personal data, storage period or the criteria for how the storage period is determined, information about where the data has been collected and the existence of automated decision-making including information about the logic behind and the meaning of the processing).

You also have the right to receive an electronic copy of your personal data that is processed by us if you make an application electronically.

If we receive a request for access, we may ask for additional information to ensure which information you want to access and that we provide the information to the right person.

Right to rectification:
You have the right to request that your personal data be rectified if the information is incorrect. Within the scope of the stated purpose, you also have the right to complete any incomplete personal data.

Right to deletion:
You have the right to have your data deleted, we will then remove all personal data that we have no legal requirement to save.

Right to restriction
You have the right to request that our processing of your personal data be restricted. We will inform you if the limitation of personal data processing ends.

Right to object to certain types of processing:
You have the right to object to processing based on a legitimate interest that we have if you have personal reasons related to the situation. However, we may continue to process your data, even though you have objected to the processing, if we have compelling legitimate reasons for the processing that outweigh your privacy interest.

Direct marketing (including analyzes carried out for direct marketing purposes)
You have the opportunity to object to your personal data being processed for direct marketing. The right to object also includes the analyzes of personal data (so-called profiling) that are carried out for direct marketing purposes.

If you object to direct marketing, we will cease processing your personal data for that purpose as well as cease all types of direct marketing activities.

Of course, you have the option to refuse mailings and personal offers in certain channels, e.g. you can choose to only receive offers from us via e-mail, but not SMS. In that case, you should not object to the processing of personal data, as it will then be difficult for us to assess which marketing is relevant to you, but you can instead change your preferences for mailings. You can do this by contacting customer service at nordicinfo@varlion.com

Right to data portability:
You have the right to receive a copy of the personal data concerning you in a structured, generally used format (data portability) and in some cases to have this data transferred to another personal data controller. The right to data portability only covers data that you yourself have provided to us and that we process on the basis of certain legal grounds, e.g. an agreement with you.

Withdrawal of consent
You have the right to withdraw your given consent at any time. In that case, we will not continue to collect new data for purposes that were based on your consent. However, we have the right to continue processing already collected data in accordance with the consent provided, but we will not supplement or update this data. If there is no other legal basis for which we need to save the data, we will delete it. If you wish to withdraw your consent, please contact our customer service at the email address: nordicinfo@varlion.com

Complaints to the supervisory authority
If you believe that we handle your personal data incorrectly, you can contact us. You also have the right to submit a complaint to the supervisory authority (Datainspektionen / Integritetsskyddsmyndigheten)

Source from which the data is obtained
In addition to the data that you yourself have provided to us or that we have collected from you based on which purchases you have made or how you use our services, we may also collect personal data from someone else, i.e. from third parties.

Klarna will collect personal data about you in connection with payment. Klarna is thus the personal data controller for such personal data according to Klarna’s terms and conditions

What is the easiest way to contact us with questions about data protection?

Because we take data protection very seriously, we have special employees at the company who handle these particular matters, and you can always reach them at nordicinfo@varlion.com

Cookies
Accepting cookies is not a prerequisite for being able to visit our web pages. However, we would like to point out that our website and service only have a limited functionality, if you do not allow us to set cookies.

What are cookies?

Cookies are small text files that are saved on your computer and that save certain settings and data for data exchange with our system via your browser. There are basically two different types of cookies, so-called session cookies, which are deleted when you close your browser and permanent/temporary cookies, which are saved on your computer for a longer or unlimited time. This storage helps us design our web pages and our offers and makes use easier for you. For example, some of your entries are saved in a way that means you don’t have to constantly repeat them.


Which cookies are used by ABG?
Most of the cookies we use are automatically deleted from your computer when you close your browser (end of session). That is why they are also called session cookies. Session cookies are needed, for example, to be able to offer the shopping cart function on several pages. In addition, we also use cookies that remain on your computer. On your next visit, it is automatically registered that you have already visited us before and which inputs and settings you prefer. These temporary or even permanent cookies (lifetime 1 month to 10 years) are saved on your hard drive and are automatically deleted when the set time is reached. It is these cookies in particular that are used to make our services more user-friendly, more efficient and safer. Thanks to these files, it is possible, for example, that you receive tailored information on the page.

What information is saved in cookies? 
In the cookies ABG uses, only pseudonymised data is saved. When these cookies are activated, they are assigned an identification number. A coordination with your personal data to this identification number does not take place. Your name, your IP address or similar information that enables a direct coordination between you and this cookie is not saved in it. Based on the cookie technology, we only receive pseudonymized information, for example about which pages in our online store have been visited, which products have been viewed, etc.

What is onsite targeting? 
Based on the cookie technology, data is collected on the ABG websites to optimize our advertising and our internet offers. This data is not used to identify you personally, but is simply for a pseudonymised evaluation of the use of the website. With this technology, we can present advertising and/or special offers and services to you. The content is based on the information obtained in connection with the click analysis (for example, advertising that is aimed at the fact that you have only looked at sports shoes in the last few days). Our goal is to make our online services as attractive as possible to you and to present advertising that matches your interests.

Are there also cookies from third parties (so-called third-party cookies)?
ABG uses some advertising partners that help make our internet offers and web pages more interesting for you. Therefore, cookies from partner companies are also saved on your hard drive when you visit the web pages. This is about temporary/permanent cookies, which are deleted automatically when the set time has expired. These temporary or even permanent cookies (lifetime 14 days to 10 years) are saved on your hard drive and are automatically deleted when the set time has expired. Even the cookies of our partner companies only contain pseudonyms, mostly even completely anonymous data. This is, for example, information about which products you have looked at, if something was purchased, which products were searched for, etc. In this context, some of our advertising partners also register information about which pages you visited before and which products you were interested in. The purpose is to be able to show you advertising that matches your interests as well as possible.

Retargeting
Our web pages use so-called retargeting technology. We use this technology to make our internet offer more interesting for you. This technology makes it possible to appeal to Internet users who have already shown interest in our online store and our products with advertising on our partners’ websites. We are convinced that the display of personalized, interest-based advertising is usually more interesting to the Internet user than the usual advertising, which lacks such a personal relationship. Display of these advertising materials on our partners’ pages is based on cookie technology and an analysis of previous user behavior. This type of advertising is completely pseudonymised. When using our site, cookies are used. Information about your use is thereby collected, saved and used.

How can you prevent cookies from being saved? 
You can set your browser so that the storage of cookies is only accepted when you consent and thus with future effect prevent cookies from being saved on your computer. If you only want to accept ABG cookies, but not those from our suppliers and partners, you can change the setting in your browser to “Block cookies from third parties”.

As a rule, via the help function in your browser’s menu bar, you can see how to reject new cookies and delete ones you have already received.

Web analysis
In order to constantly improve and optimize our offer, we use so-called tracking technology. For this purpose, we use services from Google Analytics

Google Analytics
This website uses Google (Universal) Analytics, a web analysis service provided by Google Inc. (www.google.se). Google (Universal) Analytics uses methods that enable an analysis of your use of the website, for example so-called “Cookies”, text files that are stored on your computer. This generated information about your use of this website is usually transferred to one of Google’s servers in the USA and stored there. By activating IP anonymization on this website, however, the IP address will first be shortened before transmission within the member states of the European Union or in other countries within the European Economic Area. Only in exceptional cases is the full IP address sent to a server in the USA belonging to Google to be shortened there.


In addition, you can prevent the registration of the data about your use of the website, which is created by cookies (including your IP address), by Google and the processing of this data by Google, by downloading and installing the plug-in in the browser, which you find using the following link: http://tools.google.com/dlpage/gaoptout?hl=en


Retargeting and data collection by third parties for banner advertising
In the context of retargeting and banner advertising, we use services from third parties, which save cookies on our site. This concerns the following providers: 
Facebook Inc 
1601 S. California Ave, Palo Alto, CA 94304, USA; https://www.facebook.com/about/privacy 

Last updated: 2022-01-20