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Sharp Cookie Advisors Privacy Notice

Sharp Cookie Advisors AB is a business law firm with a focus on tech, data protection and growth in the digital market. Sharp Cookie Advisors AB and our affiliated businesses (collectively, “Sharp Cookie Advisors”) are committed to being responsible custodians of the information you provide us and the information we collect in the course of operating our business.

This Privacy Notice describes how Sharp Cookie Advisors, as a data controller, may collect, use, and share information, particularly in association with the operation of our main website (www.sharpcookie.se) and all of our websites and HTML-formatted emails that link to this Privacy Notice (collectively, “Digital Services”). We understand and recognise that privacy is an ongoing responsibility; we will therefore update this Privacy Notice from time to time, as we undertake new practices and policies.

Personal information we collect and process

Sharp Cookie Advisors collects personal data about its clients, website visitors and candidates applying for open job positions. Personal information, or personal data, is any information that can be used to identify you or that can be linked to you. The majority of the personal information we collect and use is supplied voluntarily by (or collected by us from third party sources at the request of) our clients. We may automatically collect certain information about you when you access our website.

Information you provide to us

You can access and use most of our website without providing us with any personal information.

We collect and process information that you voluntarily provide us with. This includes when you contact us via email or other channels; when you submit information in an online form; when you submit an application for a position with us; when you sign up for or request that we send you newsletters, alerts, or other materials; when you sign up for a webinar or event; and when you respond to our communications or requests for information; or when you, as a client, communicate with us regarding the business and legal matters we assist you with in accordance with our written agreement. The information you provide may include your name, contact information, title, information about the organisation with which you are affiliated, as well as any other applicable or relevant information about e.g. your job application or legal matter.

Information we collect when you engage our services

The majority of the personal information we collect and use to provide our Services is supplied voluntarily by you (or collected by us from third party sources at the request of) our clients. Because of this, if you are a client of Sharp Cookie Advisors then it will generally be obvious to you what personal information we collect and use. 

This information includes: Basic information such as your name, the company you work for, your position and your relationship to a person; Contact information such as your postal address, email address and telephone number(s); Financial information, such as payment-related information; Identification and background information provided by you or collected as part of our business acceptance process; and any other personal information relating to you or other third parties which you may provide to us for the purpose of receiving our Services.

Information we may collect automatically

When you browse or in any way access our website, we use cookies and similar technologies to collect and store information about your use, access and interaction of the website and our Digital Services.

We may, for example, collect information about the type of device you use to access the website and Digital Services, your browser type, operating system and version, your IP address, your general geographic location as indicated by your IP address, the content you view and features you access, the web pages you view immediately before and after you access the website and Digital Services, how you interact with the content on our website and Digital Services, the links you click, and the search terms you enter on the Digital Services. For more information about how we use cookies and similar technologies, as well as the choices you have regarding them, please see the section “Your use of our website”.

Information we collect from other sources

We may receive personal information from other sources, including third parties that help us identify new customers or prevent and detect fraud.

We may also receive information about you from social media platforms, including, but not limited to, when you interact with us on those platforms or access our social media content. The information we may receive is governed by the privacy settings, policies, and/or procedures of the applicable social media platform, and we encourage you to review them.

Information we collect when you apply for a job

We collect information about candidates in connection with open job positions opportunities at Sharp Cookie Advisors. This information may include information that you provide us directly with such as CV, identification documents, academic records, work history, employment and references.

We may further collect information from additional sources, such as:
• Recruitment agencies – for example, when a recruitment agency contacts us to identify you as a potential candidate;
• Publicly available sources online – for example, where you have a professional profile posted online (e.g. on your current employer’s website, or on a professional networking site like LinkedIn); and
• Reference or word of mouth – for example, through a referred from former employee/employer or from a referee you have identified.

We use your personal data to match your skills, experience and education with the opportunities offered by Sharp Cookie Advisors. We share this information with the relevant HR managers and persons involved in the recruitment process to decide to invite you for an interview. We will collect additional information from you if you are invited to the interview or subsequent stages of the recruitment process.

Where we have an employment law obligation to provide a candidate with a suitable working environment, or the future provision of employment benefits, we may also collect special categories of personal data from candidates. For example, we may need to collect information about a candidate’s disabilities to provide a suitable working environment for that candidate if they are successful in their application. We may also need to conduct criminal background checks for some candidates, for example, applicant lawyers, to assess their eligibility to work at Sharp Cookie Advisors.

How we use your personal information

We use your personal data to provide our clients with legal services and other services they request, provide our clients and visitors with our Digital Services and relevant user experience of our websites, to communicate with you and to operate our business, as further described below. We do not sell personal information to anyone and only share it with third parties who are facilitating the delivery of our services.

We use the information we collect for the following purposes

- Provide you with legal and other services that you may request and respond to your inquiries
- As part of our business acceptance process including conflict, reputational and financial checks, and to fulfil any other legal or regulatory requirements to which we may be subject to
- Send you newsletters, client alerts, legal updates, marketing communications, targeted advertising and other information or materials that may interest you
- For Sharp Cookie Advisors’ business purposes, including data analysis, submitting invoices, detecting, preventing and responding to actual or potential fraud, illegal activities or intellectual property infringement
- To operate, troubleshoot and improve our website and Digital Services
- To maintain our list of contacts
- To understand how our Digital Services are used, including analysing statistics
- To evaluate, recruit and hire personnel
-To comply with our legal obligations, as we believe reasonably necessary or appropriate, respond to legal process or requests for information issued by government authorities or other third parties; or to protect your, our and other’s rights.

Your use of our website

Our website collects certain information automatically and stores it in log files. The information may include anonymised internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of our website, including a history of the pages you view. We use this information to help us design our site to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyse trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.

We have a legitimate interest in understanding how clients, visitors and potential clients use our website. This help us with providing more relevant content and services and with communicating value to our clients and candidates. 

We also collect the website visitors' consent according to applicable e-privacy legislation by using a cookie consent mechanism tool. You can find out more about cookies and how to control them in our Cookie Notice.

How we share the personal information we collect

Sharp Cookie Advisors provides legal and other services to our clients on a global market and where we do not have operations or certain expertise, we collaborate with other well renowned law firms and consultancy firms. We may share information with our business partners to the extent that is reasonably necessary in order to be able to provide you with the legal services you have requested, and also for business purposes such as internal administration and billing.

We do not otherwise share information that identifies you or your organisation with unaffiliated entities for their independent use, except with your prior permission. We may share information that does not reasonably identify you or your organisation as permitted by applicable law.

We may also disclose personal information we collect to:

- Our business partners, as well as our service providers that perform services on our behalf, such as web-hosting service providers, mailing vendors, our blogs, analytics providers, event hosting services and information technology providers;
- Competent law enforcement, regulator, government authority, court or third parties: (i) as may be permitted or required by applicable law or regulation; (ii) to exercise, establish or defend our legal rights; or (iii) to protect your vital interests or those of any other person;
- A potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice; and
- A person or an organisation you have provided your consent to disclose to.

Your rights

This Privacy Notice provide you with information about what personal data Sharp Cookie Advisors collects about you and how it is used. If you wish to confirm that Sharp Cookie Advisors is processing your personal information or have access to any personal information, please send us an email via our Contact Us page.

The European Union’s General Data Protection Regulation and other countries’ privacy laws provide certain rights regarding your personal data that we have collected. 

Our legal basis for collecting and using the personal information described in this Privacy Notice will depend on the personal information concerned and the specific context in which we collect it. We will typically process personal data from you where we need the personal information to perform a contract or entering into a contract with you when providing you with our services, or where processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to process personal information about you, or may need to process personal information in order to exercise, establish or defend legal claims. Where it will be required by applicable law, we will collect your consent.

You may request information from us about

- the purpose of the processing;
- the categories of personal data concerned;
- who else apart from Sharp Cookie Advisors might have received the information;
- what the source of the information was; and
- how long it will be stored.

You also have a right to request to have your information updated or corrected if it changes or you believe that it is inaccurate, deletion or cessation of the personal information we store, subject to certain exceptions. If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

You also have a right to lodge a complaint with the appropriate data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.

If you no longer want to receive marketing communications from us, you can tell us by sending an email via our Contact Us page. The marketing emails we send you may contain opt-out mechanisms that allow you to tailor your marketing preferences. Note: if you ask us not to contact you by email at a certain email address, we will retain a copy of that email address on its “master do not send” list in order to comply with your no-contact request

We respond to all requests received from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

For information about the choices you may have in regard to our use of Cookies, please see our Cookie Notice.

Third-party services and content

Our Digital Services may include integrated content or links to content provided by third parties such as social media content. This Privacy Notice does not address the privacy, security, or other practices of the third parties that provide such content.

We engage third parties that support the operation of our Digital Services, such as analytics providers. These third parties may use technologies to track your online activities over time and across different websites and online platforms, please see our Cookie Notice.

Security and international data transfers

Personal data managed by Sharp Cookie Advisors is stored and processed in the region in which you live, in Sweden or in other European countries where we, our business partners or suppliers are active. We take steps to ensure that the information we collect in accordance with this Privacy Notice is dealt with in accordance with the provisions of this Notice and in accordance with applicable laws where the information is available.

When required or appropriate and feasible, we obtain written assurances from third parties that may access your data that they will protect the data with safeguards designed to provide a level of protection equivalent to that adopted by Sharp Cookie Advisors. If we were to transfer your personal data to third countries, i.e. countries outside the EU / EEA, we will enter into agreements and take other measures in accordance with applicable legal requirements.

To protect the privacy of your personal information, we maintain both technical and organisational safeguards, and we update and test our security regularly. However, no information system can be completely secure. Hence, we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to us over networks that we do not control, including the Internet and wireless networks.

Further, only the employees who need to know your personal information in order to fulfil any of the purposes described above in “How we use your personal information” will have access to this information.

Data retention

We will retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements), described in “How we use your personal information”.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.

How to contact us

We will retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements), described in “How we use your personal information”.

If you have any questions or concerns you are welcome to contact us by sending an email to us via our Contact Us page.

Please note that if you are not a client of Sharp Cookie Advisors, we may not be able to treat the information you send us as confidential or privileged.

If you have a legal matter and are looking to have us represent you, please reach out to our office via the contact information you may find on our main website (www.sharpcookie.se).

Change History

For information of changes and updates made to this Privacy Notice, see below. 

June, 2015

First published with launch of the website.

May, 2018

Clarifications due to the entry into force of the new Data Protection Regulation ("GDPR") on May 25, 2018. The updated Privacy Notice will automatically enter into force for all existing clients and users on May 25, 2018. Your continued use of our website and our Services from that date will be subject to this new Privacy Notice. This Privacy Notice has also been revised to be concise, clear, comprehensible, and easier to understand taking into consideration the "layered approach" to present information.

April, 2021

Minor updates due to re-launch of website. The updated Privacy Notice will automatically enter into force for all existing clients and users on April, 13 2021. Your continued use of our website and our Services from that date will be subject to this new Privacy Notice.
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