Privacy Policy

OUR PROCESSING OF YOUR PERSONAL DATA

GO NORTH GROUP AB

It is important to us, Go North Group AB, company registration number 559252-2188, to protect all personal data that we process. Most of the personal data processed by us, we receive through our website, http://www.gonorth.co (the “Website”).

This Privacy Policy includes information on how we process your personal data, and it applies in relation to all processing activities that we conduct in the capacity of data controller. Of course, we only process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (the ”GDPR”) and other applicable laws.

1. INTRODUCTION AND IMPORTANT TERMS

For this Privacy Policy to become easier to read, some of the terms used herein are described below:

The term ”personal data” (or sometimes just ”data” or ”information”) refers to any and all information about you or someone else (i.e., to any identifiable, natural person), even if linking the information to you or someone else would require some effort. This could for instance be information about your phone number or your workplace.

The term ”processing” refers to any action taken, such as use or collection, in relation to personal data. The processing can either be automatic or manual.

The term ”data controller” refers to the person who is responsible for certain processing of personal data, and therefore determines the purpose and means of the processing. We, Go North Group AB, are the data controller in relation to the processing of personal data which we conduct on our own behalf, and such processing is covered by this Privacy Policy. You find our contact details further down in this policy.

The term ”you”, when used herein, refers to a person whose personal data we process in the capacity of data controller. Depending on your relationship with us or actions taken by you, i.e., which type of data subject you are (see the left column below in Section PROCESSING OF PERSONAL DATA), the information in Section PROCESSING OF PERSONAL DATA below may be applicable to you. The different kind of data subjects whose personal data we process in accordance with this Privacy Policy are the following:

Persons representing e-merchants that we acquire or evaluate an acquisition of
Website visitors
Persons who apply for a job or internship with us or who are otherwise subject to a recruitment process of ours
Persons representing (or who are themselves) a supplier, partner, or another person within our network
Any other persons who contact us for other purposes than as set forth above

2. PROCESSING OF PERSONAL DATA

Below you will find information on how, for how long, and based on what legal ground we process your personal data as well as what kind of personal data we process.

To the extent it is stated that the processing is based on our “legitimate interest”, we have carefully made an assessment of our need to process personal data and your interest of that no such processing takes place considering your integrity, and thereupon come to the conclusion that our interest of the processing prevails.

Processing and purpose of processing
To be able to acquire and evaluate the acquisition of ecommerce businesses, including find potential targets, which is our core business, we need to collect data, compile it in our systems, use it to communicate, enter into agreements and take similar actions.
Type of personal data
Information regarding what company or business you are representing, your role, contact details such as name, phone number, email address, communication data, information on shareholding and similar and related data.
Legal ground for processing
Our legitimate interest of conducting our business and thereby take the actions which we find necessary.
How we received the personal data
Most of the data that we process about you, we have received directly from you, for instance by using the contact form on the Website. We may also collect the data ourselves from the internet, including in particular Amazon, your website, or following a recommendation from a third party.
Processing and purpose of processing
To complete an acquisition of an ecommerce business and fulfil our obligations and enjoy our rights in the relevant purchase agreement, we need to process data to, for instance, make relevant payments and, as applicable, enable assets to be transferred to us.
Type of personal data
All personal data included in the purchase agreement, such as, as applicable, contact details such as name, phone number, email address, information regarding what company or business you are representing, as well as communication data, information on shareholding and similar and related data, and, should you be a sole trader, in some cases, information regarding your bank account and personal identification number.
Legal ground for processing
Our legitimate interest of conducting our business and thereby acquire businesses and comply with, and enjoy our rights according to, such purchase agreements.
How we received the personal data
Most of the data that we process about you, we receive directly from you (either upon our request or on your own initiative).
Processing and purpose of processing
With the overall purpose of acquiring ecommerce businesses, including find potential targets, which is our core business, and to maintain your interest for our business, we send newsletters and other marketing content to you which may include educational content, invitations to workshops, events and online webinars.
Type of personal data
Name, email address and phone number.
Legal ground for processing
Our legitimate interest of finding suitable targets to acquire and to maintain your interest for our business, with the overall purpose of being able of conduct our business.
How we received the personal data
Normally, we receive the data directly from you.
Processing and purpose of processing
With the overall purpose of acquiring ecommerce businesses, including find potential targets, which is our core business, and to maintain your interest for our business, we arrange workshops, events and online webinars, we collect data, compile it in our systems, and communicate in relation to such events.
Type of personal data
Information regarding your name, email address and phone number, and information about what company or business you are representing.
Legal ground for processing
Our legitimate interest of finding suitable targets to acquire and to maintain your interest for our business, with the overall purpose of being able of conduct our business.
How we received the personal data
Normally, we receive the data directly from you.
Processing and purpose of processing
We process your personal data to be able to fulfil our legal obligation to not send, and your wish to not receive, any newsletters and other marketing content (should you have requested us to not send any such).
Type of personal data
Name, email address and phone number.
Legal ground for processing
Our legitimate interest if complying with applicable law and your wishes.
How we received the personal data
We receive the data directly from you.
Processing and purpose of processing
To be able to improve/market our business, in particular optimizing the Website/our services, we collect the data, compile it within our system, and evaluate it.
Type of personal data
Data regarding demography and website behaviour, as well as information about your geographical location as well as your IP address.
Legal ground for processing
In relation to strictly necessary cookies, we process the personal data based on our legitimate interest in being able to develop our business. As regards other types of cookies, our processing will be subject to your consent (which may be withdrawn).
How we received the personal data
The information will, as applicable, be collected by us when you visit the Website.
Processing and purpose of processing
For us to be able to find suitable persons to hire for employment and finding suitable persons for internships, we compile the data in our system for any future contact with you, we communicate with you by email, phone (by talking, texting or otherwise) and/or in another way, and use the data in connection with eventual job interviews, in connection with taking of references and to be able to enter into an agreement with you.
Type of personal data
Contact details such as name, phone number, address, and email address, information included in your CV and other parts of your application, communication data, as well as notes from eventual job interviews and our taking of references.
Legal ground for processing
If you submit an application to us, this means that you give your consent to our processing of your information.If we, as a result of our own searching activities, find that you are a potential candidate and therefore process your data, our processing will be based on our legitimate interest of finding and hiring personnel.
How we received the personal data
If you submit an application to us, the data is thus collected directly from you. We may also collect the data ourselves from the internet, including from social media (such as LinkedIn), or another third party (such as from someone telling us about you). Personal data may also be collected directly from you in connection with job interviews and in connection with taking of references.
Processing and purpose of processing
To be able to conduct, develop, improve our business, and otherwise to meet a need of ours, we sometimes need to purchase certain services/products, cooperate with others, engage with investors and similar. If we have entered into an agreement with a supplier, partner, investor or other third party, the purpose of the processing is dependent on what has been agreed with you/the company that you represent and us, or the relevant need of ours. In general, in such cases, processing takes place to meet the need of ours, which may include the performance and administration of what has been agreed to, and to take advantage of our rights as set forth in the relevant agreement.
Type of personal data
It depends on the relevant situation or agreement. In most cases, only contact details such as name, phone number, email address, communication data and, as applicable, information about who is your employer/principal, your work title, and, should you be a sole trader, in some cases, your bank account/invoicing information and personal identification number. If you provide us with other personal data, we will also process such data. We might also request that you provide us with additional data as depending on the type of agreement to be or which has been entered into.
Legal ground for processing
Our legitimate interest of conducting, developing and improving our business.
How we received the personal data
Most of the personal data that we process, we have received directly from you or anyone else representing the supplier/ partner/ investor/ third party. It might also be that the company that you represent or one of your colleagues provides us with information about you. Further, we might also, where needed, collect it ourselves from the internet.
Processing and purpose of processing
To be able to answer any request received from you, we need to process personal data to communicate with you and, as applicable, take any actions as a result thereof.
Type of personal data
This depends on what information you provide us with. In most cases, your name and other contact details (normally email address and phone number) will be processed, as well as communication data.
Legal ground for processing
Our legitimate interest of keeping you happy with us and to respond to your inquires.However, the processing may instead, depending on your inquiry, be based on your consent, an agreement, or other legal ground.
How we received the personal data
The personal data will be received directly from you.
Processing and purpose of processing
We may need to process certain personal data in order to fulfil an obligation under law (for example, to fulfil our obligation to keep accounts). The types of processing that may occur is dependent on what legal obligations that we have from time to time. For example, we may use the information to share your data with authorities to the extent they require us to do so.
Type of personal data
All categories of personal data set forth herein may be processed in connection with the stated purpose.
Legal ground for processing
Our (or someone else’s) legitimate interest of safeguard our or someone else’s rights and/or interests in the event of a legal claim.
How we received the personal data
Since all personal data processed by us may be included, everything set forth in this column above and below regarding how we received the data apply.
Processing and purpose of processing
We may need to process certain personal data in order to safeguard our or someone else’s rights and/or interests in the event of a legal claim against us or someone else. The type of processing is depending on each situation. Normally, we may need to use the data in connection with court proceedings or when having a dialogue with a counterparty or counterparty counsel.
Type of personal data
All categories of personal data set forth herein may be processed in connection with the stated purpose.
Legal ground for processing
Our legitimate interest of developing our business and reconstruct.
How we received the personal data
Since all personal data processed by us may be included, everything set forth in this column above and below regarding how we received the data apply.
Processing and purpose of processing
To be able to reconstruct, such as divide into several businesses, or if someone wishes to invest in us, acquire us or a part of us, or any of our assets, we might have to disclose your personal data to such potential investor or purchaser (who is bound by a confidentiality obligation), for instance as part of a due diligence investigation, and take other measures within the scope of the above-mentioned purpose (such as discussing with a counterparty about their findings). For the avoidance of doubt, the processing of your personal data will continually be in accordance with this Privacy Policy, unless you are informed otherwise.
Type of personal data
All categories of personal data set forth herein may be processed in connection with the stated purpose.
Legal ground for processing
If we process data due to the stated purpose, such processing will be based on our legitimate interest, after having carefully assessed the matter, in being able to restructure ourselves, finance our business or as otherwise stated, and thereby process your personal data.
How we received the personal data
Since all personal data processed by us may be included, everything set forth in this column above and below regarding how we received the data apply.
Processing and purpose of processing
If you on your own initiative provide us with other personal data than the one that we it requested, we may process them by, for instance, compiling them in our systems and communicate with you about them by email, phone (by talking, texting or otherwise) and / or in another way.
Type of personal data
Since we cannot control what information you provide to us, any type of personal data may be processed in connection with the stated purpose.
Legal ground for processing
The legal ground for our processing is dependent on the type of data provided by you and the reason for it. The processing may thus be based on your consent, an agreement, our legitimate interest or other legal ground.
How we received the personal data
We receive the data directly from you (normally by using the contact form on the Website), your employer/principal or another third party.

3. STORAGE PERIOD

We process personal data only for as long as it is necessary to fulfil the purpose of the processing. When we no longer need certain personal data for the processing stated above, we delete it. Depending on the legal ground for the processing, the period during which we process the personal data may be governed by an agreement, be subject to a valid consent, be specified in legislation or be a result of our own assessment based on our legitimate interest or the legitimate interests of others. We review our need to process personal data regularly.

4. SECURITY

We have taken technical and organizational measures to ensure that your personal data is protected in the best possible way (such as introducing passwords, two-step verification, secure networks, instructions, when choosing our systems etc.). We ensure that your personal data is not disclosed other than when necessary (which varies depending on the type of personal data and the purpose of the processing) and otherwise ensure that it is protected from loss and unauthorized access.

5. DISCLOSURE

The personal data that we process is available to persons within our organisation who need it in order to carry out their work duties only (which varies depending on the type of personal data and the purpose of the processing) who are employees or consultants. We also share personal data with our subcontractors and, where applicable, to potential investors and purchasers according to Section PROCESSING OF PERSONAL DATA above, to the extent necessary for us to be able to achieve the purpose of the personal data processing. We might also share personal data with authorities to the extent we are required to do so.

We never share more information than necessary given the purpose of the sharing. We choose our subcontractors with great care and enter into data processing agreements with all of them, meaning that they may only process personal data in accordance with applicable law and our instructions. We use or may use, as from time to time, subcontractors/third-party tools for the following purposes:

IT system support and security
Electronic contract signing and contract management
Cloud storage
Payment and financial support
Email
Analytics

We strive for your personal data to be processed within the EU/EEA. However, some of our subcontractors are domiciled outside the EU/EEA, and therefore personal data may sometimes be transferred and processed outside the EU/EEA where other rules on personal data processing apply. However, we will always take all necessary measures to ensure that your personal data is processed with appropriate safeguards in accordance with the GDPR and other applicable laws (such as standard contractual clauses).

6. YOUR RIGHTS

Due to our processing of your personal data, you have the following rights:

You have the right to
a. access the personal data which concerns you and which is processed by us, and
b. should it or parts of it be inaccurate and/or incomplete, have it rectified or completed.
You have the right to demand
a. that we erase the personal data which concerns you and which is processed by us,
b. that we restrict our processing of your personal data, and/or
c. that we completely discontinue our processing of your personal data.
You have the right to exercise your right to data portability (i.e., the right to receive the personal data concerning you in a structured, commonly used, and machine-readable format which may be transmitted to another controller).
Should our processing of your personal data be based on your consent, you have the right to withdraw such consent (in relation to future processing).

If you wish to exercise one or several of your rights, you are welcome to contact us via the contact details provided in Section Contact and questions below. If you exercise your rights as described above, we may not be able to cooperate or have continued contact with you (or the company that you represent), provide our services to you (or the company that you represent), include you in a recruitment process etc.

Please note that you in some cases do not have all the rights listed above. This applies, for example, if we have to process your personal data i) for the purpose which it was collected, ii) according to our conclusion after having carefully weighed interests, or iii) otherwise according to EU law or the national law of an EU country. The rights set forth above are not absolute, and you only have the right to exercise them to the extent it would be in accordance with the GDPR and other applicable law, and where we otherwise have the legal/contractual right to comply with them (for instance by disclosing information to you). Further, please note that the rights set forth above apply subject to the duty of confidentiality which we might have in relation to third parties. Such duty of confidentiality may imply that we cannot disclose certain data that we have received.

Further, you have the right to make complaints about how we process your personal data if you believe that this is not done in accordance with applicable laws. You may do this by contacting the Swedish Authority for Privacy Protection (Swedish: Integritetsskyddsmyndigheten), for instance by using the email address imy@imy.se. Other contact information for the Authority for Privacy Protection can be found here: https://www.imy.se/kontakta-oss/.

7. CONTACT AND QUESTIONS

If you have any questions about our personal data processing or want to exercise your rights as set out above, you are welcome to contact us. The easiest way to reach us is to send an email to privacy@gonorth.co. Also, you are always welcome to send us a letter. Our address is:

Go North Group AB
Norra Allégatan 5
413 01 Göteborg, Sweden

8. PRIVACY POLICY UPDATES

We may make changes to this Privacy Policy. The latest version of it is always available upon request. Before any material amendments to this Privacy Policy enter into force, we will inform you about them (for instance through a notice on the Website or an email) before continuing the processing of your personal data.