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20210117

Privacy Policy

1. Introduction

The purpose of this privacy policy is to provide information about how we, Thule Sweden AB, process your personal data in connection with the use of our website and the services we provide through this website. We respect your privacy and protect the personal data we process about you. 

We protect children’s integrity. Therefore, we do not intentionally process personal data relating to anyone under the age of 18.

The following describes, among other things, how we collect, process and share your personal data.

2. Purpose and legal basis for the processing of your personal data

In this privacy policy you will find a description of the personal data we process about you, the purposes for which we process your personal data and the legal bases we base our processing of personal data on.

 

  • When you send us a request

  1. What personal data is being processed and why?

 

When you send us a request regarding, for example your orders or purchased products, either via the contact form available through our support function or directly to one of our employees listed as contact persons on the website, we process the following personal data to answer and fulfil your request: your email address, name and telephone number if you choose to provide it, the country you come from, which category the question concerns, a description of the topic and your question. We may use the information to contact you regarding your request by email or telephone and to administer and handle your request.

 

  1. What is the legal basis for the processing?

 

The processing of your personal data for this purpose is based on our legitimate interest to enable us to provide you with good service and answer your request. When you contact us with a request, it is also in your interest that we process your personal data in order to provide you with the information and service that you have requested. Furthermore, the personal data is necessary for us to satisfy and answer your request. In certain cases, the processing is also necessary to enter into or fulfil an agreement with you, for example to handle cancellations of orders before delivery etc.

 

  • When you buy a product online

  1. What personal data is being processed and why?

 

In order to administer your order, to deliver the products you have purchased online and to follow-up on your order and any potential issues or requests concerning it, we process your name, billing address, delivery address, email address, payment method and information about the products you have ordered. Personal data relating to your payment (including personal identity number, bank details and account information or information about other payment methods) is processed by our collaboration partner, Ingenico, who act as a separate controller for its processing of personal data. Please see the privacy policy of Ingenico that is available upon collection of your personal data for information about its processing of your personal data.

 

  1. What is the legal basis for the processing? 

 

The processing of your personal data for the purpose of fulfilling your order is necessary to fulfil the agreement we enter into with you. If you do not provide your personal data in connection with the purchase, we will not be able to administer your purchase or deliver in accordance with your order. The processing of your personal data for the purposes of being able to follow-up on your order and handling issues and requests is based on (i) our legitimate interest to provide you with good customer service, and (ii) in certain cases, depending on the type of request made, our obligation to fulfil the agreement entered into with you regarding the purchase. Certain personal data is also stored based on our obligation to keep records according to specific legal requirements.

 

  • When registering or logging in to a user account

  1. What personal data is being processed and why?

 

In order for you to register and use a user account, we process your email address and your password as well as your address if you choose to provide it.

 

  1. What is the legal basis for the processing?

 

The processing of your personal data for this purpose is based on our legitimate interest to provide you with a user account and the features that follow from you registering a user account, such as to provide you with order history, order status and delivery information. This is information that we provide to make your shopping experience better as Thule always strives to provide you with the best possible service.

 

  • When making a return

  1. What personal data is being processed and why?

 

When you make a return, we process your order number, information about purchased products, returned amount and your name, address and email address to satisfy, administer and follow-up on your request to return the product you purchased and to provide you with good customer service.

 

  1. What is the legal basis for the processing?

 

The processing of your personal data for the purpose of fulfilling and administering your request is necessary for us to comply with applicable consumer law if you exercise your right of withdrawal, and to enable us to comply with our contractual obligations in this respect. We also process your personal data based on our legitimate interest to keep records of the returns in order to provide you with good customer service.

 

  • When making a compensation claim

  1. What personal data is being processed and why?

 

When you make a compensation claim, we process your order number, information about purchased products, post code for billing address and your email address to be able to administer, satisfy and follow-up on your compensation claim relating to the product you purchased as well as to provide you with good customer service.

 

  1. What is the legal basis for the processing?

 

The processing of your personal data for this purpose is necessary for us to be able to comply with applicable consumer law if you exercise your right of complaint. The processing is also necessary to fulfil our obligations in the agreement we enter into with you that includes our own product guarantees through the “Thule Guarantee” or “Thule Extended Warranty”. We also process your personal data based on our legitimate interest to keep records of compensation claims to provide you with good customer service.

 

  • When making a product registration

  1. What personal data is being processed and why?

 

To perform the product registration which, among other things, ensures that you have a valid “Thule Extended Warranty” and to simplify warranty matters, we process your name, email address, country, purchased products, date of purchase and other information that you choose to provide in the free text field.

 

  1. What is the legal basis for the processing?

 

The processing of your personal data for this purpose is based on our legitimate interest to register the product as requested by you and to make sure your warranty matters are handled as smoothly as possible. The processing conducted to offer you “Thule Extended Warranty” is necessary in order for us to fulfil our obligations in the agreement entered into with you including our future warranty commitment in relation to you.

 

  • When we need to send product safety notices or conduct product recalls

  1. What personal data is being processed and why?

 

To provide you with, and document, product safety notices and to notify you about and document product recalls, for example if a product was defective, we process your name, address, email address, purchased products and telephone number.

 

  1. What is the legal basis for the processing?

 

The processing of your personal data for this purpose is necessary for us to fulfil our obligations in accordance with applicable product safety and liability laws to prevent risks to your health and safety. We also store records of product safety notices and products recalls based on our legitimate interest to exercise and defend legal claims.

 

  • When we send you marketing materials

  1. What personal data is being processed and why?

 

In order to provide you with our newsletter, surveys and other direct marketing communications we process your name and email address.

 

  1. What is the legal basis for the processing?

 

The processing of your name and email address for sending newsletters, surveys and other direct marketing communications is based on our legitimate interest in promoting our business, brand and product range. We also do this in the legitimate interest of our subscribers and customers in being able to stay in touch with you, so that we can keep you advised of new products, events and special offers. .

 

  • When you apply for a position at Thule Group 

 

Please visit www.thulegroup.com to find information about our vacancies and how to register your CV and professional profile as well as information about how your personal data is processed in connection with this.

 

3. Who has access to your personal data?

The number of people who have access to your personal data is limited. Only people with us who need to process your personal data in accordance with the purposes stated above have access to your personal data.
 
We may share your personal data with companies within the Thule group if it is necessary to fulfil the purposes mentioned above. Such Thule companies might be located within or outside the EU/EEA. Please find information about the group companies that we share your personal data with here.
 
We may also share your personal data with suppliers and partners who perform services on our behalf or who in other ways co-operate with us, including our partners providing tax calculation and fraud protection services, our payment service providers, our business system provider, our website hosting supplier and our implementation partner. Such partners will in principle be located within the EU/EEA, but if they are not, we will comply with the relevant international data transfer requirements. Please find information about the partners that we share your personal data with here.
 
Your personal data may be transferred to countries, which may have a lower level of protection of personal data than that provided within the EU/EEA. When your personal data is shared with countries outside the EU/EEA, we use standard contractual clauses provided by the European Commission and additional measures necessary to ensure an adequate level of protection of your personal data. The standard contractual clauses are available vi the following link https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
 
 
If you would like to obtain a copy of any of our agreements, please contact us at the contact information provided in section 5. In addition, in certain cases we also rely on the adequacy decisions of the European Commission for international transfers of personal data, which means that we may transfer personal data to countries outside the EU that are deemed to have an adequate level of data protection. See information on adequacy decisions here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en.

4. For how long do we store your personal data?

Type of processing Time period or criterion for determining the storage period
Personal data processed in connection with a request Deleted continuously taking into account the type of request in question. However, stored for a maximum period of three (3) years.
Personal data processed in connection with online purchases One (1) year initially. Thereafter, you will be asked annually whether or not you wish us to continue processing your personal data for this purpose. If you do not wish continued processing or if you do not answer the request within the time frame stated in the request, your personal data will be deleted. However, certain personal data relating to your purchase will be stored for a period of seven (7) years pursuant to applicable limitation and legal retention periods.
Personal data processed in connection with registration and use of user account One (1) year initially. Thereafter, you will be asked annually whether or not you wish us continue processing your personal data for this purpose. If you do not wish continued processing or if you do not answer the request within the time frame stated in the request, your personal data will be deleted.
Personal data processed in connection with a return Stored for a period of six (7) years in accordance with applicable limitation and legal retention periods.
Personal data processed in connection with a compensation claim Stored for a period of six (7) years in accordance with applicable limitation and legal retention periods.
Personal data processed in connection with a product registration Three (3) years initially based on Thule Extended Warranty. Thereafter, you will be asked annually whether or not you wish us to continue processing your personal data for this purpose. If you do not wish continued processing or if you do not answer the request within the time frame stated in the request, your personal data will be deleted.
Personal data being processed in connection with product safety notices and product recalls Ten (10) years after we sent out the product safety notice or did the product recall
Personal data used for sending out newsletters surveys and other direct marketing communications One (1) year initially (provided that you do not object). Thereafter, you will be asked annually whether or not you wish us to continue processing your personal data for this purpose. If you do not wish continued processing or if you do not answer the request within the time frame stated in the request, your personal data will be deleted.

5. What are your rights?

Thule Sweden AB, reg. no. 556076-3970, post box 69, 330 33 Hillerstorp, is the data controller of the processing of your personal data. However, in relation to the processing taking place when we send product safety notices or conduct product recalls, the data controller will be the Thule entity that is the legal manufacturer of the product you purchased. You may always contact Thule Sweden AB if you have any questions or concerns regarding the processing of your personal data. The data controllers are responsible for your personal data being processed correctly and in accordance with applicable laws. See more about your rights below.  
 
The right to access: You have the right to know which personal data we process about you, for what purposes the personal data is being processed and who we share your personal data with etc. You also have the right to access your personal data and request a copy of the personal data being processed. 
 
The right to rectification: If you notice that we have incorrect or incomplete personal data about you, you can always request that we correct or supplement this personal data. 
 
The right to erasure and restriction: In some cases, you may request that we delete your personal data or that we limit our processing for a certain period of time. Please note that restricting or deleting your personal data may result in us not being able to, for example, provide you with the services offered in connection with product registration. 
 
The right to object: You have the right to object to the processing we perform based on our legitimate interest. 
 
The right to data portability: In cases where we base our processing on your consent or on the fulfilment of an agreement, you have the right to receive your personal data in a structured, commonly-used and machine-readable format and have the personal data transferred to another controller. 
 
Withdrawal of consent: If you have given your consent to processing of your personal data, you may withdraw your consent at any time by contacting us using the contact information below. However, please note that a withdrawal of your consent would not affect the legality of any processing which had already validly occurred on that basis. 
 
If you have any questions about our processing of your personal data or wish to exercise any of your rights set out above, you can contact us at policy@thule.com. If you have any objections or complaints regarding how we process your personal data, you also have the right to contact or file a complaint with the relevant supervisory authority (Sweden: Swedish Authority for Privacy Protection (Sw. Integritetsskyddsmyndigheten)). 

6. Does the privacy policy apply to external linked websites?

Our website may contain links to other websites, such as charitable organizations. Such third parties are beyond our control and are not covered by our privacy policy. If you enter such other websites through links provided, administrators of those websites may collect your personal data. Please review the websites' privacy policies before providing your personal data.

7. Cookies

When you visit our website, we can collect and store information about your visit by placing cookies. Cookies are small text files that a website or its service provider transfer to your computer's hard drive through your web browser. They enable us to recognize your browser and capture and remember certain information.  
 
For more information on how we use cookies on our website and how to change cookie settings, please visit our Cookie Policy. 

8. Changes in the privacy policy

If any changes are made concerning the processing of your personal data, we will inform you of the changes by publishing an updated version of this privacy policy on the website. If we make material changes to this privacy policy, we will inform you by active means, for example by sending you an email or similar.