Here you will find our privacy statement at TRATON Financial Services AB. It provides information on how we handle your personal data. We care for transparency, why it may take a while to read it all. You are of course welcome to reach out to us if you cannot find what you are looking for. If you want to exercise your rights as a data subject, you can make your queries directly at us, at our DPO, but also at your local data protection authority.
Who are we?
This statement applies to TRATON Financial Services AB (abbreviated, TFS), incorporated in Södertälje (Sweden) 15187. You can reach out to TFS at info@tratonfs.com or at our address: Kvarnbergagatan 14a, 151 87 Södertälje
What are the contacts of the DPO?
The Data Protection Officer at TFS is in Södertälje (same as above) and can be reached at dpo@tratonfs.com
Introduction, our purposes and our values
TRATON Financial Service is a human centric organisation, where responsibility and respect are the foundation of our interactions with you in your role as our valued customer, co-worker, trusted business partner, supplier or when visiting our websites, premises or events. The data controller responsible for your personal data is TRATON Financial Services AB, unless otherwise stated in a privacy statement specific to a market or a service as accessible through our website. We process your personal data when it is needed to:
Sometimes we utilise trusted business partners to help us deliver our products and services. In cases when we need to share your personal data with our business partners, we ensure that they treat your personal data with the same responsibility and respect. In this statement we would like to inform you what personal data we process, why we are doing it and how we ensure that your rights are respected and exercised. Further information about how your personal data is processed may in specific cases be found in more detailed privacy notices and service descriptions. You will in these cases find the information when accessing the application/system/service. If you have any questions or concerns, you are always welcome to contact us or talk to your TFS contact.
What are your rights with respect to the data we process about you?
We commit to handle your data with fairness, transparency, security, and in a minimised manner. However, at any time you can request access to your data. Furthermore, upon meeting legal requirements, you may request your data to be removed, suspended from processing or moved to another company. We commit to act within 30 days from the receipt of your query.
What data about you do we process?
First, you may be interacting with us in several different capacities. You as an individual who entrusts us with the processing of your data are normally called 'data subject'. In this list you will find the following categories of data subject: customer (or prospect customer), employee, partner /supplier/consultant, visitor, internet user, member of the public. If you have a relationship with our local unit, please refer to the corresponding local privacy statement first.
You are our customer
Who processes the data (our local units or our head office?) |
PURPOSE |
PERSONAL DATA CATEGORIES |
LEGAL GROUND |
RETENTION |
---|---|---|---|---|
Local units |
To create a database of prospect customers, e.g., by using data from third parties |
|
legitimate interest |
Until you are no longer our customer |
Local units |
To provide you a quotation |
|
legitimate interest |
Within three months if you are no longer interested |
Local units |
to provide you with updates and requested information |
|
legitimate interest and local marketing regulations |
Until you are no longer our customer |
Local units |
To verify your creditworthiness and perform our due diligence (incl. but not limited to AML checks) in the pre-contractual phase and during the contract execution |
|
Legal obligation, legitimate interest |
Within 10 years after last event |
Local units |
to deliver upon a contract or a tender: execute it, exercise our contractual rights (incl. collection of unpaid fees), provide contractual support and make corrective actions |
|
performance of a contract |
within 10 years after last event |
Local units and Head Office |
to comply with legitimate requests by authorities and follow up on legal claims |
|
legal obligation and legitimate interest |
within 10 years after last event |
Local units |
to inform you about updates you may be interested in and follow up on our performance and your level of satisfaction of our services |
|
legitimate interest |
Until you are no longer our customer |
Head Office |
to evaluate business performance of our subsidiaries, assess credit risk on a cross border level or deliberate on significant credit exposure (including evaluating our credit exposure and approve your credit application) |
|
legitimate interest |
Until you are no longer our customer |
Local units and Head Office |
To analyse, improve quality and develop products, services and our organization |
|
legitimate interest |
Until you are no longer our customer |
Local units and Head Office |
to execute regulatory reporting of various nature to central banks, national supervisory bodies and regulators. Head office is only involved when providing IT analytical support |
|
legal obligation |
Until we are no longer requested to fulfil reporting legal requirements |
Local units and Head Office |
to execute internal reporting |
|
legal obligation and legitimate interest |
|
Head Office |
to ensure the seamless performance of our subsidiaries' loan and leasing IT system, which includes activities such as addressing tickets and maintaining service governance or data platform services |
|
legitimate interest |
based on local regulatory retention period. These data are collected by our subsidiaries locally and at times incidentally processed by us. We remove the data immediately after the support service has been performed |
You are a TFS employee
As an employer, TFS will process personal data of people we want to attract applicants, employees, consultants and former employees. When you apply for a position at TFS, we ask you to provide some personal data in order to process your application and, if employed, prepare your employment agreement. At times, we also arrange or facilitate moving operations within mobility of employees. During your employment at TFS we process your personal data in order to:
After you have left the company, we process limited amounts of personal data required to fulfil our legal obligations, for example personal data showing your employment period.
Who processes the data (our local units or our head office?) |
PURPOSE |
PERSONAL DATA CATEGORIES |
LEGAL GROUND |
RETENTION |
Head Office and Local units |
Employer branding |
|
Consent or legitimate interest (and local marketing law) |
End of event. Personal data needed for contact for further invitations or surveys will be saved for a maximum of 4 years |
Head Office and local units |
Recruiting |
|
performance of a contract or legal obligation |
based on local labour law regulation. Personal data needed for creation of employment contract is saved until end of employment. |
Head Office and local units |
staff and salary administration |
|
performance of a contract or legal obligation |
based on local labour law regulation. |
Head office and local units |
Travel management |
|
legitimate interest |
until the expense has been reimbursed and for as long needed to fulfil national legislation. |
Head office and local units |
Fulfil legal obligations (e.g., reporting to authorities, whistleblowing), to comply with collective agreement (e.g., pay agreed insurance and pensions) and to answer requests from institutions such as banks and insurance companies. |
|
legal obligation or legitimate interest |
for as long needed to fulfil national legislation. |
Head Office and local units |
Work environment (e.g., conducting statutory medical examinations, documenting incidents and occurrences, documenting work environment) and rehabilitation |
|
legal obligation or legitimate interest |
for as long needed to fulfil national legislation. |
Head Office and local units |
Planning and following up (e.g., Workforce planning, Competence inventory, Succession planning, consultant follow-up) and creating statistics and analyses to improve and develop the organisation, processes and IT-systems |
|
legal obligation or legitimate interest |
until end of employment and for additional maximum of 10 years. Personal data needed to be saved due to national legislation is saved for as long as needed due to the legislation |
Head Office and local units |
Learning and development (e.g., Competence development, P&D, Cross Talent, Education and Trainings) |
|
legal obligation or legitimate interest |
Personal data on education and trainings are saved until end of employment. Personal data on performance and development is saved for a maximum of 3 years. |
Head Office and local units |
Expatriation |
|
performance of a contract |
10 years after termination of assignment |
Head Office and local units |
access to our IT- systems and to update, improve and/or exchange our systems |
|
legitimate interest |
Personal data is saved until end of employment. |
Head Office and local units |
Safety in case of emergency |
|
legitimate interest |
Personal data is saved until end of employment. |
Head Office and local units |
To protect our employees and our company assets |
|
legitimate interest |
maximum of 2 years. Personal data from surveillance cameras is saved for a maximum of 30 days. |
Head Office and local units |
identify you as a TFS employee and to enable you to perform your work duties |
|
legitimate interest |
until end of employment. |
Head Office and local units |
To analyse, improve and develop existing and new products and services, provide you with requested information and relevant updates |
|
legitimate interest |
until end of employment. |
Head Office and local units |
comply with licences of open-source programs |
|
performance of a contract |
until termination of contract |
Head Office and local units |
perform holding activities within and for the TRATON Group (Accounting, Business Development, CEO Office maintenance, Audit, Security, Investor Relations, Tax and Treasury) |
|
legitimate interest |
|
You are a partner, supplier or a consultant
You work as a representative for a supplier that provides products and services to TFS we process limited amounts of your personal data. This is used to evaluate your offering, manage a contract and provide you with access to relevant IT-systems.
Who processes the data (our local units or our head office?) |
PURPOSE |
PERSONAL DATA CATEGORIES |
LEGAL GROUND |
RETENTION |
Head Office and Local units |
evaluate a proposal from you or your employer and assess you as a business partner |
|
legitimate interest |
Until end of our relationship with you |
Head Office and Local units |
perform contracts with you |
|
performance of a contract and legitimate interest |
Until end of our relationship with you |
Head Office and Local units |
To provide access to our IT- systems |
|
legitimate interest |
Until end of our relationship with you |
Head Office and Local units |
identify you as a TFS business partner/supplier |
|
legitimate interest |
Until end of our relationship with you |
Head Office and Local units |
To communicate with yourself or your employer |
|
legitimate interest |
Until end of our relationship with you |
Head Office and Local units |
To analyse, improve and develop existing and new products and services, as well as our organization |
|
legitimate interest |
Until end of our relationship with you |
Head Office and Local units |
To comply with legal obligations and legitimate requests from law enforcement and other authorities |
|
legal obligation or legitimate interest |
Until end of our relationship with you |
Head Office and Local units |
To provide you with requested information and relevant updates |
|
legitimate interest and local marketing law |
Until end of our relationship with you |
Head Office and Local units |
To comply with licences of open-source programs |
|
performance of a contract |
Until end of our relationship with you |
You are a visitor
When you visit our premises and our events, we process personal data about you to be able to fulfil the purpose of your visit and make your visit successful and safe.
Head Office or local units? |
PURPOSE |
PERSONAL DATA CATEGORIES |
LEGAL GROUND |
RETENTION |
Head office |
To fulfil the purpose of your visit at TFS. |
|
legitimate interest |
5 years after end of visit |
Head office |
protect our visitors and our company assets |
|
legitimate interest, consent |
5 years after end of visit |
Head office |
To comply with legal obligations and legitimate requests from law enforcement and other authorities |
|
legal obligation or legitimate interest |
5 years after end of visit |
Head office |
To provide you with requested information and relevant updates incl. webcasts or annual reports |
|
legitimate interest and local marketing law |
5 years after end of visit |
You are an internet user
When you visit our websites, your web browser provides us with some information that helps us understand how you are using our websites, for example if you are using a mobile device or a computer, which region in the world you are surfing from and which browser you are using. This data helps us tailor our website and enhance your browsing experience. We use a limited number of cookies to help us understand how you are using our websites and you will find more information in TRATON’s cookie policy.
Head Office or local unit? |
PURPOSE |
PERSONAL DATA CATEGORIES |
LEGAL GROUND |
RETENTION |
Head Office and local |
Evaluate website usage and enhance our website |
|
legitimate interest |
Consult TRATON’s cookie policy |
Head Office and local |
To enhance your browsing experience |
|
legitimate interest |
Consult TRATON’s cookie policy |
Head Office and local |
To provide you with directed information and campaigns |
|
legitimate interest and local marketing law, consent |
Consult TRATON’s cookie policy |
Third parties, recipients and transfers
In order to perform our business, we at times entrust other companies outside TFS with the processing of your personal data. This may happen for several reasons and in different ways (directly, automatically, indirectly). Any transfer outside the EEA is vetted and assessed against the most recent jurisprudence of the EU Court of Justice. Below is a few examples of transfers to third parties: