Background to updated personal data policy
GDPR (Data Protection Regulation) is a new EU regulation that comes into effect throughout the EU on 25 May 2018. GDPR replaces the Swedish Personal Data Act (PUL). Much is the same, but this means that the requirements for how companies and organizations may process your personal data are tightened.
Personal data controller
Gentlemens Agreement AB organization no: 559149-8760
Hugo Stockholm S:t Eriksgatan 39 SE-112 34 Stockholm Sweden
What is personal data?
A personal data is any kind of information that can be directly or indirectly linked to a natural person who is alive. This means that, among other things, the following are personal data: name, address, telephone number, e-mail address, IP address, photograph, etc.
What personal data does Hugo process?
Hugo stores the personal data that you as a customer provide to Hugo in connection with an order. This includes name, address, e-mail address, mobile number, information about credit cards, other means of payment and also social security numbers for possible credit checks when paying against an invoice. This information is saved so that we can handle your order, deliver your goods to the desired address, handle payment and any returns, exchanges and complaints. If you have accepted to take part in Hugo's newsletter, Hugo stores your email address upon registration. If you have been to one of our stores and entered your email address to receive the digital receipt, your email address is stored.
Personal data may be disclosed for processing on Hugo's behalf through a so-called personal data assistant. In such case, a written agreement will be drawn up to regulate the processing of the personal data by the personal data assistant and the personal data assistant will not have the right to use the personal data for purposes other than to perform the tasks the personal data assistant undertook towards Hugo.
Legal basis for the processing of personal data
Hugo processes submitted personal data on the legal basis that it is necessary to fulfill the parties' agreement. Hugo further has the right to process the Customer's address and other contact information for marketing purposes based on a balancing of interests, where Hugo, as long as you do not object to that processing, considers that its interest in marketing its products and services outweighs your privacy interest.
If you subscribe to Hugo's newsletter, the personal data is saved for one (1) year after you cancel the subscription, provided that no purchase is made during that time. Hugo saves your data as long as it is necessary based on legal requirements or to fulfill Hugo's obligations towards you in the individual case. Your data is never saved longer than is permitted according to current personal data legislation.
To the extent that Hugo is obliged by law or authority regulation to save data for a longer period of time than stated above, the data is saved accordingly. An example of this is the Accounting Act.
Your rights as a customer
Right to information: You can at any time request information about what personal data we have saved about you.
Right to rectification: If your data is incorrect, incomplete or irrelevant, you can request to have it corrected or deleted.
Right to erasure: You can request that we erase your personal data. We cannot delete your data when there is a statutory storage requirement, such as accounting rules, or when there are other legitimate reasons why the data must be saved, such as unpaid debts. However, you as a customer should be aware that a request for the deletion of data or restriction of the processing of personal data may mean that your opportunities to use Hugo's services may be limited or completely eliminated.
Data portability: You can ask us to move your personal data from our IT environment to someone else, either another company or to you. This does not apply to data that the law requires us to retain.
Withdraw consent: You may withdraw your consent to us using the data for marketing purposes at any time.