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Privacy notice

Eolus AB (publ) (“Eolus”, “we” or “us”) is committed to your privacy and to protecting your personal data. Below you will find information on how we collect, process and share your personal data (section 1) and what your rights are in relation to our processing (section 2).

Eolus AB (publ), reg. no. 556389-3956, Box 95, 281 21 Hässleholm, is the personal data controller for the processing of personal data described below. This means that we are responsible for ensuring that the personal data is processed correctly and in accordance with applicable personal data legislation. If you have questions regarding our processing of personal data or if you wish to exercise your rights, you may contact us by e-mail at gdpr@eolus.com or by letter to the address above. If you have objections or comments regarding how we process your personal data, you also have the right to contact or submit a complaint to the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten), which is the supervisory authority for our processing of personal data.

1. Description of our processing of personal data

1.1 Processing of personal data concerning you as a representative of potential and existing suppliers and customers

1.1.1
We process your personal data in order to prepare, administer and conduct our business, as well as to protect our rights and fulfil our obligations in the context of our cooperation with the customer or supplier you represent.

1.1.2
We process your personal data to fulfil our obligations under applicable legislation (e.g. anti-money laundering, sanctions, tax or accounting legislation).

1.1.3
Where applicable, we process your personal data for the establishment, exercise and defense of legal claims.

1.1.1
• Contact details, e.g. name, title, employer, postal address, telephone number and e-mail address
• Identifying information, e.g. passport details, identification documents and date of birth/personal identity number
• Information about whether you are authorised to represent a legal entity or whether you are a beneficial owner
• Billing information, e.g. responsible contact person, account number and tax information
• Other information and personal data in addition to those mentioned above, e.g. correspondence, course of events or other circumstances or data relevant to our contractual relationship

1.1.2
• Contact details, e.g. name, title, employer, postal address, telephone number, e-mail address and nationality
• Identification information, e.g. passport details, identification documents, photograph and date of birth/personal identification number
• Information about whether you are authorised to represent a legal entity or whether you are a beneficial owner
• Billing information, e.g. responsible contact person, account number and tax information

1.1.3
• Contact details, e.g. name, title, employer, postal address, telephone number and e-mail address
• Billing information, e.g. responsible contact person, account number and tax information
• Correspondence, payment information, descriptions of events or other relevant circumstances or information

1.1.1
The legal basis for processing is our legitimate interests.

We consider that the processing of your personal data is necessary for the preparation, administration and conduct of our business, as well as for protecting our rights and the fulfilment of our obligations within the framework of our cooperation with the customer or supplier you represent. We also consider that these interests outweigh any competing interests and fundamental rights and freedoms. You always have the right to object to this assessment and can read more about your rights in section 2.

1.1.2
The legal basis for the processing is a legal obligation under anti-money laundering, sanctions, tax or accounting legislation.

1.1.3
The legal basis for processing is our legitimate interests.

We consider that the processing of your personal data is necessary for the establishment, exercise or defense of legal claims. We also consider that these interests outweigh any competing interests and fundamental rights and freedoms. You always have the right to object to this assessment and can read more about your rights in section 2.

1.1.1
Personal data is stored for the duration of our contractual relationship with the supplier or customer.

1.1.2
• Personal data processed to fulfil obligations under the Anti-Money Laundering Act are generally retained for five years, but may be retained for up to ten years if necessary for the prevention, detection or investigation of money laundering or terrorist financing.
• Personal data processed to fulfil obligations under the Accounting Act are kept for seven years.
• Additionally, personal data processed to fulfil other legal requirements or for a legitimate interest may be retained for as long as necessary to comply with the relevant legislation.

1.1.3
The personal data will be kept for at least ten years from the date of termination of the co-operation with the customer or supplier, or such longer period as may be required by the nature of the contractual relationship or applicable limitation provisions.

1.2 Processing of personal data concerning you as a representative of a public authority

1.2
We process your personal data in order to prepare for, participate in, document and follow up on consultation, permitting and supervision processes, to correspond with you within the framework of such processes and to be able to appeal or otherwise deal with decisions following such processes.

 

1.2
• Contact details, e.g. name, title, postal address, telephone number and e-mail address
• Information about your employer

1.2
The legal basis for processing is our legitimate interests.
We consider that the processing of your personal data is necessary in order to prepare for, participate in and document consultation, permitting and supervision processes, to correspond with you within the framework of such processes, and to be able to appeal or otherwise deal with decisions following such processes. We also consider that these interests outweigh any competing interests and fundamental rights and freedoms. You always have the right to object to this assessment and can read more about your rights in section 2.

1.2
The personal data will be stored before and during the process with the authority. Any personal data contained in notified decisions will be kept as long as the decision is valid.

1.3 Processing of personal data about you as a land or property owner

1.3.1
We process your personal data in order to handle expressions of interest received from you regarding the leasing of your land to Eolus for renewable electricity production.

1.3.2
We process your personal data in order to fulfil our obligations in accordance with the leasehold agreements entered into.

1.3.3
If applicable, we process your personal data for the establishment, exercise and defense of legal claims.

1.3.1
• Contact details, e.g. name, title, telephone number and e-mail address
• Information about land or property you own

1.3.2
• Contact details, e.g. name, title, telephone number and e-mail address
• Information about land or property you own
• Billing information, e.g. responsible contact person, account number and tax information
• Correspondence, payment information, descriptions of events or other relevant circumstances or information

1.3.3
• Contact details, e.g. name, title, telephone number and e-mail address
• Information about your land or property
• Billing information, e.g. responsible contact person, account number and tax information
• Correspondence, payment information, descriptions of events or other relevant circumstances or information

1.3.1
The legal basis for processing is our legitimate interests.
We consider that the processing of your personal data is necessary in order to handle expressions of interest received from you regarding the lease of your land to Eolus for renewable electricity production. We also consider that these interests outweigh any competing interests and fundamental rights and freedoms. You always have the right to object to this assessment and can read more about your rights in section 2.

1.3.2
If the contract has been concluded with a legal entity, the legal basis for processing is our legitimate interests.

We consider that the processing of your personal data is necessary for the fulfilment of our obligations under the lease agreement. We also consider that these interests outweigh any competing interests and fundamental rights and freedoms. You always have the right to object to this assessment and can read more about your rights in section 2.

If the contract has been concluded with a natural person, the legal basis for processing is the fulfilment of the contract.

1.3.3
The legal basis for processing is our legitimate interests.
We consider that the processing of your personal data is necessary for the establishment, exercise or defense of legal claims. We also consider that these interests outweigh any competing interests and fundamental rights and freedoms. You always have the right to object to this assessment and can read more about your rights in section 2.

1.3.1
The personal data will be kept during the process of managing your expression of interest and for a period of three years thereafter.

1.3.2
The personal data will be processed for the duration of the contract, or for such longer period as is necessary to comply with applicable law.

1.3.3
Personal data is retained for at least ten years from the date of termination of the contract, or such longer period of time that may be required by the nature of the contractual relationship or the applicable limitation provisions.

1.4 Processing of personal data concerning you as an individual and representative of public

1.4
We process personal data about you who are an individual or a representative of the public and who can be assumed to be affected by a permit that Eolus intends to apply for in order to send out invitations and to receive, compile and respond to comments within the framework of consultation and permitting processes, and to enable follow-up.

1.4

• Contact details, e.g. name, address, telephone number and e-mail address
• Property unit designation
• Details of comments submitted
• Any images submitted
• IP address

Personal data is collected from, e.g. the consultation portal’s feedback form, the civil registration database, e-mails, phone calls, letters and consultation meetings.

1.4
The legal basis for processing is our legitimate interests.
We consider that the processing of your personal data is necessary to send out invitations to and to receive, compile and respond to comments in the context of consultation and permitting processes, and to enable follow-up. We also consider that these interests outweigh any competing interests and fundamental rights and freedoms. You always have the right to object to this assessment and can read more about your rights in section 2.

1.4
The personal data will be retained for the duration of the consultation and permitting process and for the time thereafter necessary to enable follow-up of the permitting process.

1.5 Processing of personal data about you when you apply for a job or traineeship with us

1.5.1
We process your personal data in order to manage the recruitment process and assess job applicants based on experience, qualifications and academic achievements, administer invitations and schedule interviews, and carry out recruitment tests and checks.

1.5.2
If applicable, we process your personal data to safeguard our rights in the event of a claim under the Discrimination Act and to defend against legal claims.

1.5.1
• Contact details, e.g. name, title, employer, postal address, telephone number and e-mail address

• Identification information, e.g. passport details, identification documents and date of birth/personal identity number
• Information about you provided in your CV, cover letter or other application documents or provided by any references
• Documentation from interviews
• Information regarding education, professional qualifications, certificates and grades, work experience including diplomas and employment certificates
• Photographs and information on education and professional experience from your LinkedIn profile for applications made using a login from a LinkedIn account
• Results of tests and checks carried out during the recruitment process

1.5.2
• Contact details, e.g. name, title, employer, postal address, telephone number and e-mail address
• Identification information, e.g. passport details, identification documents and date of birth/personal identity number
• Information about you provided in your CV, covering letter or other application documents or provided by any referees
• Documentation from interviews
• Information on education, professional qualifications, certificates and grades, work experience including diplomas and employment certificates
• Photographs and information on education and professional experience from your LinkedIn profile for applications made by logging in from a LinkedIn account
• Results of tests and checks carried out during the recruitment process

1.5.1
The legal basis for processing is our legitimate interests.
We consider that the processing of your personal data is necessary to manage the recruitment process and evaluate job applicants based on experience, merits and study results, administer invitations and scheduling interviews, and conduct recruitment tests and checks. We also consider that these interests outweigh any competing interests and fundamental rights and freedoms. You always have the right to object to this assessment and can read more about your rights under the heading “What are your rights?” in section 2.

1.5.2
The legal basis for processing is our legitimate interests.
We consider that the processing of your personal data is necessary to safeguard our rights in the event of a claim under the Discrimination Act and to defend against legal claims. We also consider that these interests outweigh any competing interests and fundamental rights and freedoms. You always have the right to object to this assessment and can read more about your rights in section 2.


1.5.1
Personal data will be stored during the recruitment process and for a further three years after the recruitment process has been finalised.

1.5.2
• The personal data will be stored during the recruitment process and then for a further six or twelve months after the recruitment process has been completed.
• In the event of a claim under the Discrimination Act, the personal data may be retained for a longer period of time in connection with any legal proceedings.

1.6 Processing of personal data of those who contact our customer service

1.6
We process your personal data to be able to communicate with you when you contact us via various communication channels and to be able to administer such communication.

1.6
• Contact details, e.g. name, title, employer, postal address, telephone number and e-mail address
• Data attributable to you participating in or involved in telephone or video calls and e-mails depending on the subject of the communication or correspondence

1.6
The legal basis for processing is our legitimate interests.
We consider that the processing of your personal data is necessary to enable and administer communication with you. We also consider that these interests outweigh any competing interests and fundamental rights and freedoms. You always have the right to object to this assessment and can read more about your rights in section 2.

1.6
Personal data will be deleted on an ongoing basis after a needs assessment, taking into account the purpose of the communication or correspondence. Personal data will never be retained for longer than three years.

1.7 Processing of personal data of those who have subscribed to our newsletter

1.7
If you have subscribed to our newsletter, we process your personal data in order to provide you with information about our activities.

1.7
• Name and e-mail address

1.7
The legal basis for processing is our legitimate interests.
We consider that the processing of your personal data is necessary in order to provide information from Eolus, such as press releases, news and newsletters. We also consider that these interests outweigh any competing interests and fundamental rights and freedoms. You always have the right to object to this assessment and can read more about your rights in section 2.

1.7
Personal data is retained for the duration of your subscription to our newsletter. You always have the right to unsubscribe from our newsletter. In that case, we will delete your personal data and stop sending you newsletters.

1.8 Processing of personal data about you when you visit our website

1.8.1
We process your personal data through strictly necessary cookies to provide a functioning website.

1.8.2
If you choose to accept the use of additional cookies, we will process your personal data through functionality and performance cookies to provide additional features and services on our website, to measure the performance and effectiveness of the website and to ensure the security and stability of the website.

1.8.1
We only collect personal data that is strictly necessary to provide you with a functioning website. See more information in our Cookie Policy.

1.8.2
• Only personal data necessary to provide the additional features and services we offer on the website
• We process personal data such as IP address, language choice, visitor ID to save information in forms and session ID
• See more information in our [Cookie Policy]

1.8.1
The legal basis for processing is our legitimate interests.
We consider that the processing of your personal data is necessary to provide a functioning website. We also consider that these interests outweigh any competing interests and fundamental rights and freedoms. You always have the right to object to this assessment and can read more about your rights in section 2.

1.8.2
The legal basis for processing is our legitimate interests.
We consider that the processing of your personal data is necessary to provide a well-functioning and user-friendly website with contact details and information about our activities. We also consider that these interests outweigh any competing interests and fundamental rights and freedoms. You always have the right to object to this assessment and can read more about your rights under the heading in section 2.

1.8.1
Personal data processed in connection with visits to our website are stored for varying periods, depending on the cookie set in your browser. For specific retention periods, see our [Cookie Policy].

1.8.2
Personal data processed in connection with visits to our website are retained for varying periods depending on the cookie set in your browser. For specific retention periods, see our [Cookie Policy].

How is your personal data collected?
We mainly collect your personal data directly from you. Where appropriate, we may also collect personal data by obtaining information from other sources, such as publicly available, public or private sources or registers (e.g. the Swedish Tax Agency or other authorities and institutions) or from your employer.

How do we protect your personal data?
We are committed to ensuring that personal data is processed with a high level of security and confidentiality. Therefore, we have implemented technical and organisational measures to protect your personal data from loss, destruction, misuse and unauthorised access or disclosure. Only authorised persons who actually need to access your personal data in order for us to fulfil our stated purposes have access to it.

Where do we process your personal data?
As a general rule, we and our suppliers and partners only process your personal data within the EU/EEA. If personal data is processed outside the EU/EEA, there is either (i) a decision from the Commission that the country in question ensures an adequate level of protection or (ii) appropriate safeguards that ensure that your rights are protected in the form of, for example, standard contractual clauses. To ensure transparency of our processing of your personal data, you have the right to obtain a copy of any standard contractual clauses by contacting us. You can read more about which countries are considered to have an “adequate level of protection” on the European Commission’s website and you can read more about standard contractual clauses on the website of the Swedish Authority for Privacy Protection.

With whom do we share your personal data?
We will not disclose your personal data except in the cases described below.

(i) Personal data contained in consultation statements and permit documents may be shared with environmental consultants and/or legal advisors that assist us in collecting and processing of personal data. In such cases, we primarily act as the controller and the environmental consultant/legal advisor primarily acts as our processor. We may also share consultation statements and permit documents with potential buyers when selling a project to enable the buyer to evaluate the permitting process and the project before making an investment decision. The legal basis for the sharing of personal data is our legitimate interests. We consider that the processing is necessary for the purposes. We also consider that these interests outweigh any competing interests and fundamental rights and freedoms. You always have the right to object to this assessment and can read more about your rights in section 2.

(ii) Your personal data is shared with third party service providers or partners who perform services on our behalf when it is necessary to provide us with IT or system services or administrative services. The legal basis for the sharing of personal data is our legitimate interests. We consider that the processing is necessary for the purposes. We also consider that these interests outweigh any competing interests and fundamental rights and freedoms. You always have the right to object to this assessment and can read more about your rights in section 2.

(iii) Relevant personal data will be shared with other parties when it is necessary for the safeguarding of legal interests or when agreed in an individual case between you and us. In some cases, the recipients of your personal data are actors who are data controllers for their processing of personal data, while in other cases they are data processors that process the personal data in accordance with our instructions and may not use the personal data for their own purposes (e.g. service providers and partners who are contractually authorised to process personal data only to provide the relevant service and for storage, support and development purposes).

2. What are your rights?

When we process your personal data, you have several rights. These rights are described in more detail below.

Right to lodge a complaint
If you have objections or concerns about how we process your personal data, you have the right to contact or lodge a complaint with the Swedish Authority for Privacy Protection, which is the supervisory authority for our processing of personal data.

Right to information and access
You can request to be informed of whether we are processing your personal data and to receive a copy of it (known as a data subject access request or DSAR) together with some certain additional information about how we process your personal data.

Right to rectification
If you believe that your personal data is inaccurate or incomplete, you can request for it to be corrected or completed.

Right to object
You have the right to object to the processing of your personal data which is based on our legitimate interest. If we cannot demonstrate compelling and legitimate grounds to continue processing the personal data, we must cease the processing. You always have the right to object to our processing of your personal data for direct marketing purposes.

Right to restriction
In some cases, you have the right to request the restriction of the processing of your personal data, which means that the data can only be processed for certain limited purposes in the future. This is possible, for example, if you have objected to the processing, if you have disputed the accuracy of your personal data or if the processing is unlawful. By requesting a restriction of processing, you have the possibility, at least for a certain period of time, to stop us from using the personal data for purposes other than, for example, to defend against a legal claim.

Right to erasure
In certain cases, you can have your personal data erased. Erasure may apply, for example, to personal data that is no longer necessary to process or retain for the purpose for which it was collected or to personal data processed on the basis of your consent if you choose to withdraw your consent. In certain circumstances, we may not able to delete your personal data, e.g. when your personal data is needed to comply with a legal obligation, if it is still necessary for the purpose for which it was collected, or if our interest in continuing to process the data outweighs your interest in having it deleted.

Right to transfer your personal data (data portability)
If we process your personal data to fulfil a contract or on the basis of your consent, you may, in certain cases, be able to obtain the personal data for use elsewhere, for example by obtaining a copy of it in a machine-readable format and transferring it to another controller.

Right to withdraw consent
When we process your personal data based on your consent, you have the right to withdraw your consent at any time. When you withdraw your consent, we will stop any processing of personal data which is based on your consent.

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