Privacy Policy
Introduction
Ture Invest Partners AB, 559251-2437 (“Ture” or “we”) processes your personal data in connection with your involvement with Ture. Your privacy is important to us and we encourage you to read this privacy policy to learn more about our personal data processing. As data controller, we are responsible for ensuring that your personal data is processed correctly and in accordance with applicable laws. If you have questions regarding your rights related to personal data, please contact us at GDPR@tureinvest.se or +46 (0) 708 87 08 83.
Legal basis and purposes
All processing of personal data must be based on one of the legal bases stipulated in the EU’s General Data Protection Regulation (the “GDPR”). The legal basis shall be determined and documented before a processing activity is initiated. In practice, we primarily rely on the following legal bases:
Performance of contract
Processing of personal data is conducted where it is necessary to fulfil a contract with you. This includes concluding, performing and terminating a contract, as well as managing client/customer relations.
Legal obligation
Processing of personal data may be conducted if it is necessary to comply with a legal obligation, including but not limited to where we have a legal obligation (i) to file information with tax or police authorities, (ii) to perform know-your-customer (KYC) controls under anti-money laundering (AML) regulations, or (iii) to comply with bookkeeping and accounting regulations.
Legitimate interest
In certain cases, we process personal data on the basis of our legitimate interests, provided that such interests are not overridden by your interests or fundamental rights and freedoms. Our legitimate interests may include maintaining and developing business relationships, managing investor and borrower communications, administering access to systems such as virtual data rooms, protecting our business against fraud and misuse, keeping limited CRM records, handling enquiries, and carrying out internal business development, analysis and marketing in relation to our services. When processing is based on this legal basis, a balance of interest test must be conducted where our legitimate interest and the individual’s right to privacy must be weighed against each other. The more extensive the processing activities, the more compelling the reasons must be to rely on this basis. Please contact us if you want to know more about how we have balanced these interests.
Consent
In some cases, we might obtain your consent to process your personal data. The GDPR stipulates that consent must meet certain requirements to be valid; for example, it must be documented, specific and freely given. Such requirements must be carefully considered each time consent is obtained. Before giving consent, you will be provided with information on the processing, including its purpose. You can withdraw your consent at any time.
An overview of our data processing activities is set out in the table below.
Our data processing activities
| Group | Data | Purpose | Legal basis | Retention |
|---|---|---|---|---|
| Investors and prospective investors |
|
Investor contact, customer classification, CRM and marketing. |
|
Until the purpose ends. If no relationship is established: normally up to two years after last meaningful contact, unless longer retention is required by law or for legal claims. |
| Investors, their UBOs and representatives |
|
Investor administration, contracts, shareholder records, VDR access, AML/KYC and accounting. |
|
AML/KYC: five years after the relationship ends. Accounting: until the end of the seventh calendar year after the financial year. |
| Borrowers, their UBOs and representatives |
|
Investment assessment, loan agreements, CRM, loan administration, AML/KYC and accounting. |
|
During the relationship and thereafter as needed for administration, portfolio analysis, legal claims and legal obligations.
AML/KYC: five years after the relationship ends. Accounting: until the end of the seventh calendar year after the financial year. |
| Contractors |
|
Contract administration, communications and business contact management. |
|
During the relationship and thereafter as needed for contract administration, follow-up and legal claims.
AML/KYC: five years after the relationship ends. Accounting: until the end of the seventh calendar year after the financial year. |
| Candidates |
|
Recruitment, suitability assessment, references, legal compliance and, with consent, future opportunities. |
|
During recruitment. Thereafter up to two years for legal claims. Talent pool data: until consent is withdrawn or the stated period ends. |
| Anyone who contacts Ture |
|
Respond to enquiries and maintain business contacts. | Legitimate interest | As needed to handle the matter. If no relationship follows: normally up to two years, unless law or legal claims require longer. |
Where do we collect personal data from?
We may collect personal data directly from you, from the organisation you represent, from public registers and official sources, from service providers assisting with AML/KYC, sanctions screening and background checks, from references or recruitment agencies, and from counterparties, advisers and other business contacts involved in our relationship with you. We only use such sources where relevant and lawful for the purposes described in this notice.
Are you required to provide us with your personal data?
Although you are not legally required to provide us with your personal data, we are sometimes required by law to process personal data relating to you for certain purposes, such as investment screening, KYC and screening against export control and sanctions lists. If you do not allow us to process your personal data, we may not be able to provide you with our services or proceed with our relationship.
Who has access to your personal data?
We have implemented technical and organisational measures to appropriately protect your personal data against loss, accidental and unlawful access and unauthorised disclosure. Access to your personal data is limited and granted on a need-to-know basis (in accordance with the purposes above). We may use personal data processors to process personal data on our behalf. This includes IT and system suppliers, fund administrators, banks and other subcontractors. We also disclose your personal data when required by law or by decision of the authorities (e.g. police authorities, auditors, tax and supervisory authorities). As a general rule, recipients of personal data should be based within the EU/EEA. If we transfer personal data to a country outside the EU/EEA, we will ensure that the transfer is made in accordance with the safeguards in the GDPR, for example on the basis of an adequacy decision by the European Commission, the European Commission’s standard contractual clauses, and, where required, supplementary safeguards. We will always ensure that any transfer of personal data is lawful and that appropriate safeguards are in place to protect your personal data. We do not make decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you.
What are your rights?
You have various rights when we process personal data about you, depending on the circumstances and the legal basis for the processing, including:
right to receive information on the personal data we process about you and obtain register extracts of your personal data (including purpose, categories of personal data, recipients, retention period and any automated decision-making)
right to have inaccurate data rectified
right to object (when we process personal data based on our legitimate interest, you have the right to object to the processing at any time)
right to require us to restrict our processing of your personal data if, for example, you consider it to be inaccurate
right to erasure, for example if the personal data is no longer necessary for the purposes for which it was collected or if you withdraw consent, unless we are required or entitled to retain the data by law or for legal claims, and
right to have your personal data transferred to another company (data portability), where the processing is based on consent or contract and carried out by automated means.
You have the right to complain to us and to the supervisory authority, the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, “IMY”), about how we process your personal data. For more information on how to lodge a complaint, please visit: https://www.imy.se/privatperson/utfora-arenden/lamna-ett-klagomal/
Contact
If you wish to exercise any of your rights or if you have any questions regarding our processing of your personal data, please contact us at:
Ture Invest Partners AB
Address: Nybrogatan 7, 114 34 Stockholm
Phone: +46 (0) 708 87 08 83
Email: GDPR@tureinvest.se
A request will be handled as quickly as possible and you will receive a response no later than one month from the date of receipt of your request (unless we inform you that we have a right to extend the deadline by a further two months).
Cookies
We use a limited number of cookies on our website, www.tureinvest.se. Cookies are small text files that are placed on your device when you visit a website. They are widely used to make websites work more efficiently and to create a better user experience by enabling websites to remember information about visitors and their actions and preferences. We use the following types of cookies:
i. Necessary cookies (session cookies) or similar technologies to make our website work properly for you. Necessary cookies mean that information will only be processed while you are on the website. They are necessary to display the website in a user-friendly way, for example to let you choose the language.
ii. Analytical/performance cookies are used to measure and improve the performance of our website and understand how visitors use our website. These cookies may involve the use of identifiers and may therefore constitute personal data depending on the implementation. We only use analytical/performance cookies where you have given your consent, unless the cookie is strictly necessary or otherwise exempt under applicable law.
We may use third-party cookies on our website, such as Google Analytics and Microsoft cookies. These cookies are set by other domains or websites, and we do not have control over all subsequent processing performed by those providers. Where such cookies involve transfers of personal data outside the EU/EEA, the relevant transfer safeguards must be assessed and maintained.
The collection and use of cookies may involve the processing of personal data. You may give or refuse consent to cookies that are not strictly necessary, and you can withdraw or change your cookie choices at any time. Necessary cookies cannot be rejected because they are required for the website to function properly. Cookies that are not necessary are only used for as long as your consent remains valid or until you withdraw it. The following cookies are used by tureinvest.se:
Necessary:
Crumb. Deleted at the end of the session. Domain: www.tureinvest.se
_cvr. Information about company. Stored for 13 months. Domain: www.tureinvest.se
_cvt. Deleted after 24 hours. Domain: www.tureinvest.se
Others:
_ga. Used to distinguish users for Google Analytics. Expires after 2 years.
_gid. Used to distinguish users and store random IDs and information about users for Google Analytics. Expires after 1 day.
_gat. Used to distinguish users in Google Analytics. Expires after 1 day.
MSO. Microsoft. Expires after 24 hours.
MUID. Microsoft. Expires after 9 months.
MC1. Microsoft. Expires after 6 months.
For more information, please visit:
Så använder Google cookies – Integritet och användarvillkor – Google
https://privacy.microsoft.com/en-us/privacystatement#maincookiessimilartechnologiesmodule
Changes
We are constantly working to improve and develop our business, and we may therefore make changes to this privacy policy from time to time. The latest version is always published on our website, www.tureinvest.se.