This notice provides information about the processing of your personal data by WirelessCar.

If you are or have been engaged as a consultant or temporary worker by WirelessCar, we will process personal data about you. In this case please read this Consultant and Temporary Worker notice.

Identity and contact details of the controller

WirelessCar Sweden AB (“WirelessCar”), is the controller of the personal data that it obtains from you and the other sources described below. WirelessCar is responsible for the processing of your personal data under applicable data protection laws and regulations.

If you have questions regarding the processing of your personal data, please contact WirelessCar by email, post or phone at:
WirelessCar, Vädursgatan 6, SE-412 50 Göteborg, Sweden
+46 31 65 19 00

What categories of personal data will WirelessCar process?

WirelessCar will process all or part of the following categories of personal data.

• Individual data, such as name, photo
• Organizational data, such as consultancy number, services description, place of work, business unit, department, manager, direct reports
• Contact data, such as work location, work email, work telephone number
• Consultancy administration data, such as consultancy contract and information about assignment start date and termination date
• Time data, such as working hours, worked time
• Security data, such as access cards, access rights and use of access cards and access rights
• Health and safety data, such as information about work related incidents and sick days
• Competence data, such as learning records and training activities
• Travel administration data, such as information on business trips, booking details, passport number, travel invoices and allowances
• Help desk and support data, such as questions from you/your WirelessCar manager/HR relating to your assignment or IT-equipment or support provided to you in relation to the same
• IT-related data, such as user-ID, passwords, log-in details as well as data and logs about your use of WirelessCar’s IT equipment, application or services, as per WirelessCar’s IT policies, as applicable from time to time

It is specifically noted that some aspects of health and safety data are regarded as sensitive data under the applicable data protection laws and shall be handled with extra care. It is specifically noted that sensitive data is only processed in case of legal obligation and/or explicit consent.

WirelessCar may also process a limited amount of personal data (name and contact details) of persons indicated by you as persons to be contacted by WirelessCar in case of emergency.

Legal basis and purposes of the processing

WirelessCar will process your personal data based on either of the following legal grounds, see also further details below.

• Contractual obligation. Example, WirelessCar must process your personal data to comply with the services agreement in place with your employer.
• Legitimate interests. WirelessCar’s legitimate interests are normally to manage its daily operations, secure its facilities and equipment and keep internal control. In order to base its processing of personal data on the balance of interest-basis, WirelessCar makes an assessment on case-by-case basis. Example, WirelessCar needs to process certain personal data to enable administration of your business related travels where WirelessCar’s legitimate interests are to manage its daily operations; or WirelessCar needs to process certain personal data to review the status of its IT-equipment where WirelessCar’s legitimate interests are to secure its equipment.

In exceptional cases and only when no other legal ground can be applied, WirelessCar may ask for your consent to process your personal data. If consent is used, you may withdraw your consent at any time, which will however not affect the lawfulness of the processing based on consent before its withdrawal.

WirelessCar will process your personal data, as exemplified above, for the purposes stated below.

Administration (normally based on contractual obligation and/or balance of interests)

• Enabling registration of you in WirelessCar’s systems and general administration of your assignment with WirelessCar
• Enabling proper license usage
• Enabling keeping an up-to-date organization chart and record of consultants, including production of internal reports and statistics
• Enabling follow-up on projects

Reporting (normally based on legal obligation and/or balance of interests)

• Enabling reporting to authorities, as required by law
• Enabling keeping track of your working time for invoicing purposes to your employer

Work environment and product safety (normally based on legal obligation and/or balance of interests)

• Enabling fulfillment of WirelessCar’s obligations to provide a safe work environment (including control and prevention of unauthorized access to WirelessCar’s premises or equipment) and other work environment obligations as set out by work environment or labour laws
• Enabling fulfillment of WirelessCar’s obligations related to product safety and quality

Your development and activities (normally based on legal and/or contractual obligation and/or balance of interests)

• Enabling activities regarding competence development
• Enabling and suggesting learning and training activities

Employee work related activities (normally based on legal and/or contractual obligation and/or legitimate interest)

• Enabling the performance of your work tasks, such as writing emails, establishing documents, reports, presentations, drawings etc
• Enabling business travels
• Enabling answering questions from you/your WirelessCar manager/HR regarding your assignment or IT-equipment/services or provision of support necessary for the performance of your work tasks
• Enabling follow-up of WirelessCar’s policies, including Code of Conduct and WirelessCar’s IT policies, as applicable from time to time, to ensure that such policies are adhered to and to investigate suspected prohibited activities

From where will WirelessCar obtain your personal data?

WirelessCar will primary obtain your personal data from yourself, your employer or HR or other third party to whom you have directed us to obtain your personal data. Some personal data might also be automatically generated from WirelessCar’s IT-system, such as creation of user-id.

What happens if you do not provide WirelessCar with any personal data?

Personal data is a requirement and necessary in order to perform your consultancy agreement, which may not be entered into without the required personal data.

How will WirelessCar share your personal data? Will it be transferred outside the EU/EEA?

WirelessCar will normally not share your personal data with anyone outside of its group of companies, unless required by law or regulations. However, WirelessCar may, if necessary to fulfill the purpose for processing the personal data, share your personal data with another group company, including company outside of the European Union or the European Economic Area (EU/EEA). WirelessCar may also, if necessary to fulfill the purpose for processing the personal data, share your personal data with third party suppliers, including supplier outside of EU/EEA.

WirelessCar will secure that there are appropriate safeguards in place which provide adequate levels of protection of your personal data as required by applicable data protection laws. For example, this may include the use of intercompany or external data processing agreements based on EU approved Standard Contractual Clauses or EU-US Privacy Shield or such other mechanisms as have been recognized or approved by the relevant authorities from time to time. If you have questions about the transfer, please contact WirelessCar.

For how long will WirelessCar keep your personal data?

WirelessCar will normally keep your personal data during the consultancy agreement. After your consultancy agreement has ended, WirelessCar will only keep the personal data deemed necessary for the fulfillment of the purposes for which it was collected and only up and until such purposes have been fulfilled or, if later, for such time as may be required to comply with local legal obligations or to satisfy any legal requirements in the event of an actual, threatened or anticipated dispute or claim.

Your data protection rights

You have the right to request from WirelessCar information about the personal data processed about WirelessCar and access to such personal data. You also have a right to request rectification of your personal data if this is incorrect and request erasure of your personal data. Further, you have a right to request restriction of the processing of your personal data meaning that you request WirelessCar to limit its processing of your personal data under certain circumstances. There is also a right for you to object to the processing based on legitimate interest or processing for direct marketing. You have as well the right to data portability (transfer of your personal data to another controller) if WirelessCar’s processing if your personal data is based on consent or contractual obligation and is automated.

You also have the right to lodge any complaints you may have regarding WirelessCar’s processing of your personal data to a supervisory authority. To exercise your rights, please contact WirelessCar on the address or email above.

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