Personal Data notice

This notice provides information on WirelessCar’s processing of your personal data as an employee of WirelessCar Sweden AB.

WirelessCar Sweden AB (“WirelessCar”), is the controller of the personal data that it obtains from you and the other sources described below. Controller means that it is WirelessCar that decides on the purpose and means for the processing of your personal data. WirelessCar is responsible for the processing of your personal data under applicable data protection laws and regulations. WirelessCar’s processing of your personal data is necessary with regard to your employment at WirelessCar. If you have questions regarding the processing of your personal data, please contact HR or WirelessCar at:

WirelessCar, Vädursgatan 6, SE-412 50 Göteborg, Sweden
+46 31 65 19 00

What categories of personal data will WirelessCar process?

WirelessCar may process the following categories of personal data. Please note that it is not necessarily so that WirelessCar will process all the personal data listed below. Please note that the examples listed under each category are not exhaustive.

• Individual data, such as name, date of birth, social security number (or equivalent), gender, nationality, preferred language, photo
• Organizational data, such as employee number, job description, position, place of work, business unit, department, manager, direct reports
• Contact data, such as work address, home address, email, telephone number
• Compensation and benefits data, such as salary, salary reviews, tax deductions, pension information, bank account details, bonus.
• Employment administration data, such as employment contract and other agreements between you and WirelessCar, applications or other forms regarding e.g. parental leave, information about hiring date and termination date
• Time data, such as working hours, worked time, vacation, leaves of absence (parental leave, sick leave etc.)
• Union membership data, if applicable and relevant
• Security data, such as access cards, access rights and use of access cards and access rights
• Health and safety data, such as information about sick-leave, rehabilitation plans, work related incidents, health examinations
• Performance and evaluation data, such as evaluations and disciplinary records, if any
• Competence data, such as learning records and training activities
• Travel administration data, such as information on business trips, booking details, passport number, company credit card number, travel invoices and allowances, flight and hotel bonus card numbers if any
• Help desk and support data, such as questions from you/your manager/HR relating to your employment 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 union membership and 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 must only be processed in case of legal obligation, authorized by collective bargaining agreement and/or explicit consent.

WirelessCar may also process 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. In some countries, next of kin data may also be processed for certain purposes relating to benefits and/or labour law requirements.

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.

• Legal obligation. Example, WirelessCar may be obliged by law to report your income to tax authority.
• Contractual obligation. Example, WirelessCar must process your personal data to be able to pay your contractually agreed salary.
• Legitimate interest. WirelessCar’s legitimate interest is 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 legitimate 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 interest is 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 interest is to secure its equipment.

In exceptional cases and only when no other legal ground can be applied, WirelessCar may ask for your explicit consent to process your personal data.

WirelessCar will process your personal data, as exemplified above, for the general purposes stated below. Please note that the examples listed under each purpose are not exhaustive.

Administration (normally based on contractual obligation and/or legitimate interest)

• Enabling registration of you in WirelessCar’s systems and general administration of your employment with WirelessCar
• Enabling proper license usage
• Enabling keeping an up-to-date organization chart and record of employees, including production of internal reports and statistics
• Enabling payment of salary, pension and other benefits to you, as well as reviews of salary, including production of internal reports and statistics
• Enabling follow-up on projects

Reporting (normally based on legal obligation and/or legitimate interest)

• Enabling reporting to authorities, as required by law, such as tax agency
• Enabling keeping track of your working time/leaves of absences/vacations, for remuneration as well as invoicing purposes

Labour law requirement (normally based on legal obligation)

• Enabling fulfillment of WirelessCar’s obligations as per collective bargaining agreements with unions or by labour law

Work environment and product safety (normally based on legal obligation and/or legitimate interest)

• 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 safety and quality

Employee development (normally based on legal and/or contractual obligation and/or legitimate interest)

• Enabling activities regarding competence development/improvement as well as performance evaluations and assessments
• 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 manager/HR regarding your employment 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 manager or HR, stakeholders who you work with 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, or equivalent, for example when creating your user-id to WirelessCar systems.

How will WirelessCar share your personal data?

WirelessCar will normally not share your personal data with anyone outside of its group of companies, unless required by law, regulation or collective bargaining agreement. However, WirelessCar may, if necessary to fulfill the purpose for processing the personal data, share your personal data with other Group company, including company outside of 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 in all cases use all reasonable endeavors to satisfy itself 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 employment. After your employment 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 purpose has been fulfilled or, if later, for such time as may be required to comply with local legal, tax or benefits 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 access to your personal data. You also have the right to request WirelessCar to rectify or erase your personal data or restrict the processing of the same. You may also object to WirelessCar’s processing of your personal data or request data portability. However, please note that WirelessCar may not always be obliged to comply with a request of deletion, restriction, objection or data portability. Assessment will be made on a case by case basis of WirelessCar’s legal obligations and the exception to such rights. To exercise your rights, please contact WirelessCar on the address as set out above.

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