Latest update: 2023-01-16

This Privacy Policy is effective as of 2023-01-16

Introduction and purpose

This Privacy Policy (“Policy”) documents the processing and treatment of Personal Data (“Personal Information”). The Privacy Policy applies to visitors of the focalpay.se website and individuals that engage with Focalpay AB, corp. reg.no 559312-7771, with registered address post box 30122, 104 25 Stockholm  (“Focalpay”, “we”, “us”, “our”) at events, trade shows and similar activities detailed below. 

Focalpay is committed to protecting your (“Data subject” “individual/-s”) privacy and Personal Data. Your confidence is of utmost importance to us, and we strive to carefully and responsibly treat all information provided to us, to protect your interest. Focalpay’s Privacy Policy describes how we process Personal Data, and describes Data Subjects’ privacy rights. We ensure that we have legitimate legal ground and a legitimate purpose for processing of Personal Data. We only process necessary Personal Data, and we do not keep it for longer than necessary. Our ambition is for the Personal Data that we process about you to be correct, which means that we may delete incorrect information. 

Our Privacy Policy adheres to the European legislation concerning privacy protection, mainly the GDPR (General Data Protection Regulation), EU 2016/679. All capitalized terms in this Privacy Policy, not defined herein, have the same meaning as defined in GDPR. To ensure compliance with applicable data protection laws in all geographical areas where Focalpay operates is our goal. 

Please note, this Privacy Policy may be updated. You can revisit this policy to learn of new privacy practices, or potential changes to our Privacy Policy. 

Please note, this Privacy Policy does not apply to, refer to, or provide information on, the usage of the Focalpay commerce platform. Neither does it provide information on Data Processing by Focalpay in the role of service provider or Processor on behalf of Focalpay customers, with regards to our cloud-native commerce platform. 

Privacy Policy - key terms and who it applies to 

This Policy applies to: 

• Visitors of focalpay.se (the “Website”, “website”)

• Participants in Focalpay sales processes, potential Focalpay customers (“Sales”)

• Participants at trade shows and/or events where Focalpay is present

• Potential customer prospects who submit their details for marketing purposes or other enquiries

• Visitors to our third party social media platform pages

• To any recruitment activity candidates and participants

• This Privacy Policy is also applicable to data we gather from other online services

• Public records and company websites

About this Privacy Policy 

Our Privacy Policy explains who we are and how we collect, share and use Personal Information. Additionally, it outlines the actions taken by Focalpay to protect Personal Data, and provides information regarding Processing of Personal Data, that we have conducted as a Controller. Furthermore, it outlines the available rights and choices for individuals regarding the use of, and access to, Personal Information, and how to update the information. 

What is Personal Data? 

Personal data is information about an identified or identifiable natural person. "Identifiable natural person" means a person who can be directly or indirectly identified specifically by reference to an identifier, e.g. name, identification number, location information, online identifier or other factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

What does Personal Data processing mean?

The processing of Personal Data refers to an action or a combination of actions related to Personal Data - regardless of whether it occurs automatically or not - such as collection, registration, organization, structuring, storage, processing or modification, production, reading, use, delivery by transmission, dissemination or other provision, adjustment or combination, restriction, erasure or destruction.

Collected information in the role of Personal Data controller

Focalpay has the role of Personal Data controller with regards to processing Personal Data under the processing activities subject to this Privacy Policy and communicating with customers and conducting business, related to employment applications, customer contact individuals, and individuals representing potential customers. 

If you are using the Focalpay website, or if you communicate with Focalpay by visiting us at events, contacting us on social media platforms, or visiting us at our offices, we collect, use, process and share information relating to you according to this Privacy Policy. 

Personal Data collected when you visit the Focalpay website

We mainly process Personal Data collected directly from the individual in question, or other persons connected to the individual such as a manager or colleague. At times Focalpay collects Personal Information from third parties such as partners or social media platforms, relating to marketing, recruitment or public records. 

Focalpay collects two categories of Personal Information:

• Voluntarily provided

• Automatically collected

Voluntarily provided information

If you complete one of our online forms on our website, we collect Personal Data. We also collect information if you provide your contact details during a trade show or event. Depending on how we engage with you, Focalpay will collect and process the below information. We have outlined further how we process the Personal Data in schedule X. 

• Full name

• Title

• Company or organization

• Email

• Phone number

• IP address

• Organization address such as street number, postal code, city, country

• Information collected through custom fields, if applicable. 

• Data concerning place of employment, position and/or title

• Preferences and interests

• Email conversations with the Focalpay team

• Information relating to job applications

Automatically collected information

Some types of technical information is usually collected as a standard when you visit our website. This type of information may include:

• IP address

• Access times

• Any website your visit linked from

• Pages visited on the Focalpay website

• Links used 

• Ad banners or other digital content viewed

• Device information

• Information provided by your browser that may be otherwise collected with some services

Some of the above information may be gathered using cookies and similar tracking, please review our cookie policy for further information. Additionally, when you visit Focalpay’s website or interact with us with telecoms networks some information such as mobile subscription number can at times be transmitted to us by telecoms operators as a standard part of communication. 

Other parties that may access information

Focalpay uses third party service providers to offer services to our website visitors and potential customers. Therefore, we will need to share Personal Data to provide services and information to individuals if relevant. Additionally, some third party vendors, partners or authorities may gain access to Personal Data. Vendors of sub-processors may also access Personal Data. 

We may share your Personal Data with third parties, for example in the following situations: 

Partners

We share your Personal Data with partners and suppliers, during shared initiatives such as digital and physical events, trade shows, in addition to co-initiated sales and marketing campaigns. 

Authorities

Personal Data may be used and shared as we deem appropriate or required in order to comply with legal processes, lawful requests and applicable laws, for example to reply to subpoenas or government authority requests. For example, the Swedish Tax Agency and other authorities may require Personal Data to be disclosed by Focalpay. In these instances, Focalpay will only disclose this information if there is legal ground for it. 

Personal Data may be used and disclosed to government authorities, law enforcement and private parties as Focalpay deems necessary or appropriate in order to protect our own or individuals’ safety, privacy, rights or property and to protect and to investigate and discourage unauthorized, unethical, illegal or fraudulent behavior.  

Mergers & Acquisitions

In connection with an acquisition, a merger with another company or a division, the acquiring company and/or its hired consultants may require access to certain personal data that we process about you. In the event of such disclosure, we will ensure that the person receiving the personal data is covered by a confidentiality agreement.

Opting out

You can opt out of marketing communications by clicking the unsubscribe link in our marketing emails, or alternatively by contacting us at contact@focalpay.se. Please note we may send emails related to our services (i.e. non marketing material) if required after opting out, if this is relevant to you and you are for example a customer or partner of Focalpay. 

Information gathered from social media channels and other third parties

We may gather Personal Data from Focalpay’s social media platforms, such as LinkedIn, YouTube, Google, Meta (Facebook, Instagram), Twitter, TikTok and other third party social media platforms. When interacting with our pages on these platforms, the respective social media channel’s Privacy Policy will apply for individual interactions and data collection, usage and processing of Personal Information. 

Additionally, we may obtain Personal Data from other third parties, including marketing or commercial partners, data providers and public sources. For example a business partner may share Personal Information with Focalpay if an individual expresses interest in learning about Focalpay’s platform or provided services. 

Use of Cookies

We collect cookies, and we may collect log files for behavioral advertising, which you can opt out of if you wish. When you visit our website, Focalpay may use an automation tool to track activity. Based on activity, we might send out marketing offers, if consent is given. Focalpay will not process Personal Data with the automation tool unless a consent has been given. 

The cookies collected include information about analytics services such as IP information for performance review, Google, LinkedIn, Facebook. Please note that you can withdraw consent at any time. 

Automatically collected cookies

On the Focalpay website, this information is gathered using cookies and browser web storage (locally stored objects). Our service providers and business partners may collect information about you automatically, over time and across third-party websites and mobile applications. This can include information about your devices, and your activity on (or through) our website. 

The information collected may include the below: 

• IP address

• Location information

• Geographic area (city, state, country)

• Usage and actions taken on our website (pages viewed, time spent on website, navigation paths, access time, access length)

• Device version and operating system type

• Manufacturer

• Model

• Screen resolution

• Browser type

Applicants for Employment

With regards to applicants for employment, we process Personal Data. The Personal Data is processed based on Legitimate Interest in processing the Personal Data, and this does not violate applicants’ privacy rights.  

Information processed may include: 

• Name

• Employment

• Identification numbers/documentation

• References

• CVs

• Academic records

• Work history

The Personal Data of job applicants is used to match experience with specific roles available at Focalpay. The data is forwarded to hiring managers and individuals involved in the hiring process. The information gathered may originate from sources such as: 

• The candidate’s provided information

• Information provided by recruitment agency

• Online resources such as LinkedIn

• By references provided by the candidate

Potential customers

We process Personal Data as detailed above, related to potential customers for marketing and sales purposes. The Personal Data can be collected by filling out website forms, contacts via social media platforms mentioned previously in this Privacy Policy, or collection at physical events or customer meetings. Depending on activity, we may send marketing and sales offers. 

We process this Personal Data to: 

• Provide quotes and services when requested by potential customers

• Provide support related to our website features and products

• Maintain and/or Improve features and functionalities in Focalpay’s services

• Manage administration, orders

• Manage prospect sales and contract processes 

Sensitive Data

Sensitive Data includes information about race, ethnicity, religious beliefs, philosophical beliefs, political opinions, memberships in trade unions, and health and private life information. In general, Focalpay does not process any sensitive data about individuals. If any sensitive data is provided by an individual, it is only processed by us if consent is given for this, or if processing is legally required. We limit the use of personal identification numbers, and only process these when required to ensure individuals’ identification. 

How Focalpay processes and stores Personal Data

When we process your Personal Data, everyone in our business is required to comply with applicable data protection legislation and what is stated in this document to maintain a high level of protection for your privacy. We are obliged to:

• Prevent unauthorized access to your personal data

• Prevent dissemination of your personal data

• Prevent other deviations when we process your personal data

We ensure that your Personal Data is treated confidentially, that your integrity is not put at risk by our processing of it and that we guarantee access to Personal Data in accordance with applicable data protection legislation.

Storing and securing personal Data

Focalpay has implemented appropriate technical, organizational and physical measures to protect the Personal Information collected and processed about individuals. The measures are in place to provide a level of security appropriate in relation to the risk of processing Personal Information gathered, processed and stored in the event of a potential infringement. 

Focalpay ensures to: 

• Treat all Personal Information with confidentiality

• Prevent spreading Personal Data

• Prevent unauthorized access to Personal Data

• Adhere to applicable data protection legislation with regards to availability of Personal Information 

Organizational measures

• We continuously work to develop and assess our work concerning progressing Personal Data

• We have appointed staff to manage Personal Data-related topics

• We have incident management procedures to enable efficient action-taking in the event of Personal Data incidents

• We train our staff regarding Personal Information management, and on adhering to this Privacy Policy

• We enter Personal Data processing agreements with all partners, customers, suppliers and other interested parties who process Personal Data on our behalf as required

Technical measures

• Personal Data classification to introduce security measures in relation to risk assessment

• Encryption and pseudonymization to reduce Personal Data progressing risk

• Restricting access to Personal Data so that only those that need access to fulfill contractual or statutory obligations have it

• Using detection, prevention, recreation and reporting systems effectively

Physical measures

• To get access to Focalpay’s premises, access cards are required. Additionally, parts of the premises are video-monitored.

Processing and retention of Personal Information

Focalpay processes and stores information only for as long as it is required, in relation to the purpose of which the information was obtained. The legal basis will consequently depend on the Personal Information in question and the specific context in which we collect it.  

We will keep the information in instances where Focalpay has a legitimate cause for it, for example when providing individuals with requested services and information, or to comply with tax, legal and accounting regulations. 

If there is no legitimate cause to process or retain Personal Data, it will either be anonymized or deleted. If  this is not possible due to Personal Data being required to be stored in archives, it will be securely retained and isolated from any processing until it can be deleted. 

International data transfers 

When collecting Personal Data, it may be processed in countries with different data protection laws than your country. In these instances, we take appropriate measures to ensure that the Personal Information processed is protected in alignment with this Privacy Policy, including when processed internationally by third party providers.  

We always strive to keep Personal Information within the European Economic Area (EEA). Sometimes we may engage suppliers located outside the EEA, for example third party service providers or companies that assist with technical support and/or maintenance of our IT services. In these instances, we will ensure that these suppliers do not have access to Personal Data, and in case this is not possible, we will ensure regulations are followed. Any Personal Information shared will always be kept to a minimum, in relation to the purpose of which it is shared. Regardless of where the Personal Information is transferred, Focalpay takes necessary precautions ensuring that the security level and processing is in accordance with the GDPR by for example implementing the EU Commission’s Standard Contractual Clauses. This requires our non-EEA members to protect Personal Information they process from the EEA in accordance with European Union data protection laws.

Links to other websites

If our website contains links to third party websites or material published by third parties, these links are for information only. As we have no control over the material or the processing of personal data on these pages, we assume no responsibility for the processing of personal data in connection with such pages.

Your rights as a Data Subject

All individual Data Subjects have the right to request information regarding our processing and storing of their Personal Information, if any has been collected. Individuals can contact Focalpay to access, correct, update or request deletion of their information. Please note that we may have to ask details about the individual Data Subject, to ensure that the information requested is provided to the correct person securely. 

Furthermore, individual data subject can: 

• Correction of of Personal Data that we have processed if it is incorrect

• Submit a request that Focalpay deletes the Personal Data held about the individual Data Subject. In this instance, please note that Focalpay may be required by law to decline such a request if the information is required for tax records or bookkeeping, or is necessary to defend legal claims

• Request to limit Focalpay’s processing of Personal Data.  In these instances, Focalpay may need to review the situation prior to reaching a final decision

• Request to transfer Personal Data  to another Controller, if technically possible and aligned with regulations  and laws. 

• Object processing of Personal Data or ask for restricted processing of Personal Data 

• Request portability of Personal Data

• Object to the processing activities of the Personal Data

• Opt out of marketing communications. To opt out of email communications, please unsubscribe in the email sent from Focalpay. For opting out to all forms of marketing communications, please email contact@focalpay.se 

• Withdraw a previously given consent to processing Personal Information related to cookies. Please note that withdrawing consent does not impact the lawfulness of processing made prior to withdrawal, or impacts processing of Personal Data with regards to lawful processing grounds 

• Make a complaint about Focalpay’s collection or processing of Personal Information to a data protection authority: imy@imy.se, 08-657 61 00, Integritetsskyddsmyndigheten, Box 8114, 104 20 Stockholm, Sweden

Focalpay will answer all questions or requests from Data Subjects with regards to exercising data protection rights in accordance with applicable data protection regulations and laws. 

How to exercise rights as a data subject

For any  questions regarding this Privacy Policy, or if you want to exercise your rights as a data subject, please contact us on contact@focalpay.se where we will manage your inquiry confidentially. 

We strive to work with individuals to ensure we reach a fair solution for any  potential complaint or concern about privacy. If an individual believes that Focalpay has been unable to address and assist with a concern, question or complaint, and is located in the EEA, the individual has the right to create a complaint with the supervisory authority. 

Updates to this Privacy Policy

Focalpay may update this Privacy Policy occasionally due to legal requirements, or technical or business developments. You can always view the latest updates made at the top of this page. If this Policy changes, an updated version of the document will be made available on our website. In order to stay up to date on its content, we therefore recommend that you visit our website regularly. If we make significant changes to this document, for example changing the purpose of processing Personal Data, we will also send an email or post a notice via our social media.

Appendix 1

Appendix 2

About Focalpay

Focalpay is an innovative and disruptive commerce platform with cloud-native checkout (point of sale), backoffice and payment software provided to merchants and businesses across Europe. Our cost-efficient, groundbreaking infrastructure has merged the payment and retail processes in one system, enabling secure, sustainable shopping journeys both for retailers and consumers. A seamless, streamlined, secure flow is achieved by integrating Focalpay’s platform. Focalpay is headquartered in Stockholm, and is growing fast internationally.