Privacy policy

This privacy policy sets out how Svenska Petroleum Exploration AB (“Svenska” or "we/us/our") collects, uses and protects any personal information about visitors to the Svenska website (this/our “Site”), an organisation that we sell our product to (or who enquire about our product) about individuals that get in contact with us, our contractors and suppliers and those individuals whose personal information we otherwise process in the course of our business. This privacy policy also covers data processing related to job applications and our recruitment activities.

Svenska is committed to ensuring that your privacy is protected. You can be assured that any personal information you send us or we collect from you will only be used in accordance with this privacy policy and applicable data protection law.

Svenska reserves the right to amend or vary this policy from time to time by updating this page. This policy is effective from 31 May 2018 and was updated in June 2020 and again in February 2022.

For the purposes of applicable data protection laws, the data controller (in other words, the organisation that determines how and for what purposes your personal data is used) is Svenska Petroleum Exploration AB, which is a Swedish company with company registration number 556093-2583.

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We do however share your information with certain third parties in the circumstances described in this policy.

You may request details of personal information which we hold about you under applicable data protection laws. If you would like a copy of the information held on you please write to Svenska Petroleum Exploration AB, P.O. Box 27823, 115 93 Stockholm, Sweden.

If you believe that any information we are holding on you is incorrect or incomplete, please contact us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

What information we collect

Contact Details

If you give a representative of Svenska your contact details then we may keep those details, which may include your name, organisation, job title and contact details, on file for future business use.

Careers and Recruitment

If you apply for a job or work placement at Svenska the information we collect about you may include: individual details (name, address (including proof of address), other contact details (e.g. email and telephone numbers), gender, date and place of birth, nationality, employer, job title); identification details (identification numbers issued by government bodies or agencies, such as your national insurance number, passport number, tax identification number and driving licence number); credit, anti-fraud and sanctions information (credit history, financial information, credit score and information received from various anti-fraud and sanctions databases relating to you); and special categories of personal information (and, in particular, state of health).

Know Your Suppliers and Counterparties

If you are an actual or prospective contractor, supplier, service provider, consultant, joint venture partner or other counterparty that we engage or do business with, or you work for, represent or beneficially own any of the same (a "KYS contact"), we may collect certain personal information about you. This may include individual details (name, address (including proof of address), other contact details (e.g. email and telephone numbers), gender, date and place of birth, nationality, employer, job title; identification details; credit, anti-fraud and sanctions information; and special categories of personal information. We may collect this personal information from you, your employer, the person that has engaged you or that you represent, anti-fraud databases, sanctions lists, court judgements and other databases .

Visiting our Site

When you visit our Site, we may collect, generate, store and use certain personal data about you. This personal data may include: technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, device types, operating system, time and date of consent and platform.
It may also include information about your visit to our Site, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse our Site.

Use of your information

We may use your personal information if:

it is necessary for the performance of a contract with you or necessary in connection with a legal obligation; or
you have provided your consent to such use; or
we consider such use of your information as not detrimental to you, within your reasonable expectations, having a minimal impact on your privacy, and necessary to fulfil our legitimate interests; or
we are otherwise required or authorised by law.

We use your information to:

maintain and develop our relationship with you;
facilitate our internal business operations.

Careers and Recruitment

If you apply for a job or work placement at Svenska, we may use your personal information to assess your application and to allow us to carry out both recruitment analytics and any monitoring activities which may be required of us under applicable law as an employer. We may also carry out screening checks (including reference, background, directorship, financial probity, identity, eligibility to work and vocational suitability) and consider you for other positions.

The lawful basis on which Svenska will rely to process this information will be:

for all personal information, the legitimate interest (we have a legitimate interest in knowing the identity and background of the individuals we employ or engage to ensure we have the appropriate staff to comply with our various legal and regulatory obligations and ethical duties); and
for special category data – compliance with a legal obligation and legitimate interest (we have a legitimate interest in providing reasonable adjustments to our recruitment process where you ask us to).

We may disclose your personal information to recruiters, screening check providers, health service providers, professional and trade associations, law enforcement agencies, recruitment analytics and research providers, referees, your current and previous employers and third party due diligence and know your counterparty service providers. We may also collect your personal information from these parties in some circumstances. Without your personal information we may not be able to progress considering you for positions with us.

Know Your Suppliers and Counterparties

If you are a KYS contact, we may use your personal information when we co-operate with supervisory and lawful authorities in order to comply with the laws and regulations that apply to us – for example, to help us comply with legislation on money laundering, or where we do due diligence on, and monitor and store details (including personal information) about, the people we engage or do business with in accordance with regulatory requirements. We may also collect and disclose your personal information under orders from courts and regulators to those persons who are entitled to receive the required information. . Where we use your personal information for the purposes set out in this paragraph:

we do so on the following legal bases:
- for all personal information: compliance with a legal obligation; and legitimate interest (we have a legitimate interest understanding more about the organisations and people we engage and contract with and ensuring the efficacy of our supply chain); and
- for special category and criminal data – preventing or detecting unlawful acts, and suspicion of terrorist financing or money laundering; and

we may provide your relevant information to third party due diligence and know your counterparty service providers such as World-Check (see below for more information).

Visiting our Site

When you visit our Site, we may collect, generate, store and use certain personal data about you. This information is used by us to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and for the control of illegal acts. We reserve the right to check these log files and data retroactively if there is reasonable suspicion of an illegal act due to concrete indications. We safeguard your interests by anonymizing your IP address upon collection so that you are not identifiable. In some circumstances we will use your personal data because it's necessary for us to comply with a legal obligation (for example, if we receive a legitimate request from a law enforcement agency). In other cases (such as the detection of theft, fraud or ensuring security of our Site) we will rely on our legitimate interests in keeping our Site secure and to prevent theft and fraud.

Retention of your information

We will only retain your personal information for the periods set out below:

Type of data	Retention period
Recruitment information (excluding right to work documentation) For example: CVs, interview records, pre-employment verification records (including references)	For unsuccessful candidates: 6 months after notifying candidates of the outcome For successful candidates: Documents relevant to ongoing employment will be transferred to the individual's personnel file and retained throughout employment/engagement and for 7 years after employment/engagement end
Equal opportunities monitoring and diversity records	For unsuccessful candidates: 6 months after notifying candidates of the outcome For successful candidates: Documents relevant to ongoing employment will be transferred to the individual's personnel file and retained throughout employment/engagement and for 7 years after employment/engagement end
Business Contact Information and details	For as long as the business relationship continues (or until the legitimate interest ceases)
Know Your Suppliers and Counterparties information	Five (5) years or for as long as the business relationship continues.

Change of purpose

We will only use your personal information for the purposes for which we collected it. If we need to use your personal information for a purpose other than that for which it was collected, we will provide you, prior to that further processing, with information about the new purpose, we will explain our legal justification for doing so and we will provide you with any relevant further information. We may also issue a new privacy policy to you.

How we share your personal information and where it may be processed

Third party suppliers and service providers which process your personal information

Like most businesses, we may provide your personal information to third parties for processing as part of the services that those third parties carry out on our behalf as part of the day to day operations of our business. These trusted suppliers will process your personal information on our behalf and provide us with services such as the provision of certain HR-related functions, the provision of IT services, third party software providers, the hosting of your personal information and our accountants and professional advisers.

We will always make sure that these trusted suppliers meet agreed standards for the protection of your personal information and that they will only ever be allowed to use your personal information in order to provide us with services (and not for their own purposes). We require all third parties to take appropriate technical and organisational security measures to protect your personal information and to treat it subject to a duty of confidentiality and in accordance with applicable data protection law.

Sharing your personal information with other entities in our group

We will share your personal information with other entities in our group as part of the administration of our business. For example, we may share personal information as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.

Other scenarios in which we might share your personal information

We may also share your personal information:

with government authorities or professional bodies;
with our professional advisors including tax, legal or other corporate advisors who provide professional services to us;
with regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts, the police and any other authorised law enforcement bodies, for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters etc.;
in the event that we consider selling or buying any business or assets we will disclose your personal information to any prospective sellers or buyers of such business or assets;
in the event of any insolvency situation (e.g. administration or liquidation);
if we, or substantially all of our assets, are acquired by a third party, in which case your personal information will be one of the transferred assets;
to protect the rights, property or safety of our employees, workers, contractors, clients, or others. This includes exchanging your personal information with other companies and organisations (including without limitation the local police or other local law enforcement agencies) for the purposes of our employee, worker, contractor and client safety, crime prevention, fraud protection and credit risk reduction; or
if we are under a duty to disclose or share your personal information in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.

Processing your personal information in other territories

Your personal information may be transferred in and out of the UK and the European Economic Area ("EEA") where local laws may not provide legal protection for personal data in the same way as is applicable in the UK or the EEA. Where your personal information is processed outside of the UK and EEA, we will ensure that we take the necessary steps to protect your personal information as required by data protection laws.

Third-party websites

Our Site may, from time to time, contain links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect as required by law and in accordance with accepted good industry practice. We will always keep these under review to make sure that the measures we have implemented remain appropriate. You can obtain further information about these measures from Svenska (using the contact details set out in the Contact section of this privacy policy below).

In addition, we limit access to your personal information to those employees, workers, agents, contractors and other third parties who have a business need to know in order to perform their job duties and responsibilities. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

Your rights in relation to the information that we collect

It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes so that our records can be updated. We cannot be held responsible for any errors in your personal information in this regard unless you have notified us of the relevant change.

Data protection law grants you a number of specific rights in respect of your data in addition to the broad and general right to have your data protected. Under certain circumstances, by law you have the right to:

be informed of the purpose and basis for processing your personal information, amongst other things. This enables you to receive information about how we use your personal information. We have set this information out in this policy;
request access to your personal information (commonly known as a “data subject access request”) . This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
request the rectification of any inaccurate or incomplete personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
request erasure of your personal information in certain circumstances (commonly known as the "right to be forgotten"). This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below);
object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground;
restrict processing of your personal information in certain circumstances. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it; and
obtain a portable copy of your personal information or to have a copy of that information transferred to a third party.

If you want to exercise any of the rights set out above, please contact Svenska (using the contact details set out in the Contact section of this privacy policy below).

Cookies

How we use cookies

A cookie is a small encrypted text file which asks permission to be stored on your browser or on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our Site and to deliver a better and more personalised service. Some of the cookies we use are essential for the Site to operate.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our Site in order to tailor it to visitor needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

The types of cookie that we use

Strictly necessary cookies. These cookies are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site.
Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors to our Site and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users can find what they are looking for easily. All information collected by these cookies is aggregated (i.e. we could not identify you as an individual using the data).

Third party cookies

Third parties may also use cookies on our Site.

For example, we use Google Analytics to learn how visitors are using our Site and how we could improve it.

Managing cookies

We have deployed a cookie "consent management platform" which means that you will normally see a message on our Site before we place cookies on your device or browser. The message will describe the types of cookies we use and what information they might collect. We will not place (and we won't permit third parties to place) cookies other than "strictly necessary" cookies on your device or browser when using our Site unless you have told us that you are happy to do so using the consent management platform. You can update your preferences at any time by clicking here.

You can usually modify your browser setting to decline cookies if you prefer. However, this may prevent you from taking full advantage of the website.

More information

If you would like further information about our use of cookies, you can contact Svenska (using the contact details set out in the Contact section of this privacy policy below). You can read more about how to administer cookies stored on your computer at www.aboutcookies.org.

Complaints

We encourage you to contact us first if you have any queries, comments or concerns about the way we handle your data (our details are in the section immediately below). We will try to put things right.

However, if you are not satisfied with our handling of any request by you in relation to your rights or concerns, you also have the right to make a complaint to a data protection supervisory authority.

If you are based in Europe, you can contact the Swedish Datainspektionen at Drottninggatan 29, 5th Floor, Box 8114, 104 20 Stockholm; +46 8 657 6100; or www.imy.se

If you are based in the UK, you can contact the UK's Information Commissioner's Office ("ICO"). You can contact the ICO at: First Contact Team, Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF; +44 303 123 1113; or ico.org.uk.

Contact

If you have any questions about this privacy policy or how we handle your personal information, please write to Svenska Petroleum Exploration AB, P.O. Box 27823, 115 93 Stockholm, Sweden.