PRIVACY policy

Nexer AB respects your privacy and the right to control your personal information. Our guiding principles are simple: we will be transparent with what data we collect and why.

Our processing of personal data is carried out in accordance with the provisions arising from the applicable personal data legislation, including the EU General Data Protection Regulation, EU 2016/679 (“GDPR”) and the UK Extension to the EU-U.S. DPF, and the International Trade Association’s Data Privacy Framework (see Nexer US below).

PERSONAL INFORMATION WE COLLECT
We collect data directly from you, within the framework of the relationship that we have with you. You may be a contact person at one of our customers, suppliers and/or partners; or you may be a consultant, job seeking candidate and/or student. In short, people we interact with in the course of our business. We may process personal data for the purposes outlined below, as a part of caring for and maintaining our commercial relationship with your employer or you personally.

Examples of personal information we may process are your name, your contact details (such as mobile phone number, address and email address), and your profiles on LinkedIn and other social media platforms. We may also update your information from other public records, such as via the Swedish Companies Registration office (Bolagsverket), SPAR, etc. This is only done if it is deemed necessary to maintain good data quality.

We may also register personal information provided to us when you interact with us digitally, such as when you do one of the following:

• Fill in your name, email address and/or mobile phone number on one of our websites.
• Contact us by email, websites or social media.
• Sign up for a newsletter/event or digital service we offer.
• Visit or use our websites and/or apps. These data include but are not limited to trafficdata, location data, web logs and other communication data, and for example the IPaddress, type of device, operating system, and browser type used for the visit.used for the visit.

PURPOSES AND LEGAL BASIS
We process your personal data for the following purposes and legal basis:

Purpose: To manage and nurture our customer or supplier and/or partner relationships with your company (where you are employed) or you as a contractor/partner, and to fulfill the obligations arising out of any applicable agreements, orders and enquiries, which may involve the processing of personal data in digital business support, such as customer care systems and supplier databases.
Legal basis: Our legitimate interest is to nurture our business relationships and fulfill what is expected under commercial agreements.

Purpose: To manage administration, invoicing, correspondence etc with our partners and enable good service, correct erroneous information and/or send information that has been requested or which we deem may be of interest to you (or your employer) in the light of our business relationship.
Legal basis: Our legitimate interest is to nurture our business relationships and fulfill what is expected under commercial agreements.

Purpose: To manage and nurture our relationship with you as an individual contractor, job seeker or student, in order to match the wishes of open assignments and positions.
Legal basis: Our legitimate interest is in nurturing and fulfilling what is expected in our business relationships and the fulfillment of contracts to the extent you have registered/signed up for.

Purpose: To perform, administer, develop and improve our digital services (websites, apps, databases, etc.), which may include analysis of user behaviour and statistical data on an aggregated level, as well as storage and analysis.
Legal basis: Our legitimate interest is in providing and ensuring the functioning of digital services and ensuring effective disclosure and promotion of our activities.

Purpose: To contact you by email, app, SMS, or mail about offers, promotions or services that we believe may be of interest to your employer or you (please note that you may opt out of this promotion).
Legal basis: Our legitimate interest is in offering and marketing services and products that we deem to be of interest to your employer or you.

INFORMATION THAT MAY BE DISCLOSED
We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) where we deem this to be of interest and relevance to the business relationship we have with your employer or you.

We may also disclose personal information with service providers that we have hired to fulfill the purposes of our processing of your personal information. These service providers provide IT services and marketing services unless otherwise informed.

If you are looking for a job assignment or are a candidate, we may also disclose information to our external customer or partner companies as part of our work to find assignments for you.

We only work with partners who process personal data within the EU/UK/EEA [or with companies that maintain the same level of protection as in the EU/UK/EEA]. Any transfer of personal data complies with the requirements of the GDPR.

FOR US BASED INDIVIDUALS
Nexer, Inc USA, the US entity of Nexer AB, operates under the US Data Privacy Framework, adhering to the principles outlined in the framework. All U.S. entities or U.S. subsidiaries of Nexer Inc. are also adhering to the EU-U.S. DPF Principles, including as applicable under the UK Extension to the EU-U.S. DPF, and are covered by our organization’s DP. The subsidiaries and affiliates in the US are: Nexer Enterprise Applications Inc., Nexer Unified Commerce Inc., Nexer Insights Inc., and Nexer Data Management Inc. We will process all EU and UK personal data in accordance with those same principles. We and the data we process, is subject to the rules and regulations of US government regulatory agencies. Public authorities may request data processed by us as permitted by law for purposes of investigation. Under certain circumstances, you may have the right to binding arbitration. We will maintain agreements with any third parties who may be processing your data as part of our services offerings to insure your rights are maintained throughout our business relationship.

STORAGE AND DELETION OF PERSONAL DATA
Processing takes place in accordance with current legislation and means that personal data is not retained for a longer period than necessary. We will store your personal information for as long as you are an active and potential customer, candidate (including subcontractor or job seeker), or partner to us. If our relationship has ceased and/or it is not deemed reasonable to be reactivated, we will remove your information. Such data reviews take place periodically and at least once a year. Unless we have specifically addressed it, or obtained your specific approval, the personal information of anyone who has been inactive in their relationship with us is deleted after 3 years of inactivity.

Certain information can be kept longer when required due to legal requirements, such as the Accounting Act.

When processing and storing personal data, its confidentiality and the relevant level of organisational and technical security measures are observed based upon the risk and sensitivity of the data processed.

PERSONAL DATA PROTECTION AGREEMENT AND OTHER APPLICABLE TERMS AND CONDITIONS
Nexer Inc complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce. Nexer Inc has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) and the UK Extension to the EU-U.S. DPF with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and the UK Extension to the EU-U.S. DPF, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/

At Nexer Inc., we are committed to maintaining the highest standards of data privacy and ensuring transparency in our practices. In accordance with applicable regulations, we inform individuals that Nexer Inc. assumes liability for the onward transfer of personal data to third parties, ensuring that such transfers comply with our stringent privacy policies and applicable legal standards. Additionally, while we prioritize protecting personal information, we may be required to disclose certain data in response to lawful requests from public authorities, including those made to meet national security or law enforcement requirements. Nexer Inc. takes all reasonable steps to ensure such disclosures are made in strict compliance with the law and with the utmost respect for individual privacy rights.

YOUR RIGHTS AND CHOICES
You have rights with respect to your personal information and you are able to amend your information and what is saved. We will, at your request and/or our partners’ request, correct information that is found to be inaccurate. You may also request that your information is deleted or that its use is restricted by contacting us (for contact channels see the “Contact Us” section below). If you believe that your rights are not respected by us, please feel free to contact us or get in touch with the privacy authority (the former Data Inspection Board). You have the right, in certain circumstances, to access the personal data you have provided to us that relates to you, this can be obtained in an electronic format that is widely used and you have the right to transfer such information to another data controller (data portability). You also have the right to object to the processing of your personal data. If this happens, we must demonstrate compelling legitimate reasons that outweigh your interests, rights, and freedoms in order to continue the processing of your personal data.

You may at any time refrain from receiving marketing communications from us by, where relevant, updating your account settings on “My Pages” (or similar), by clicking “Unsubscribe” in any email and SMS communication we send you. You are always welcome to contact us for help to opt out of our communication.

You can obtain information about what personal data is registered with us, by requesting in writing a so-called register extract from us.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Nexer Inc and it’s affiliates, commit to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.

ABOUT COOKIES AND SIMILAR TECHNOLOGIES
When you use our sites and apps, personal information may be collected, for example, so-called cookies. This means that information about the usage and the websites and apps you’ve visited are stored. This can include technical information about your device and Internet connection, such as your operating system, browser version, IP address, cookies, and unique identifiers. When you visit websites where our services are provided, different technologies can be used to recognise you and learn more about our users. This can be achieved directly, or through the use of third-party technology. Similar technologies may be used in connection with our websites, our online advertising, e.g. in social media, or our emails, either by us or by our suppliers, business partners or other third parties.

LINKS TO OTHER SITES
In the event that our website contains links to third-party websites, or materials posted with third parties, these links are for information purposes only. Therefore, because we do not have control over these sites or their material, we are not responsible for its content nor are we responsible for any damages or losses that may arise from the use of these links.

CONTACT US
For further information on personal data management or if you have any questions, please feel free to contact us at privacy@nexergroup.com

Effective Date: 2/1/2025 Revision: 1/16/2025