Last updated: 29 July 2022
In this policy, “FunPlus,” “we,” “us,” and “our” means FunPlus International AG, Switzerland, a company registered in Switzerland whose registered office is at Bahnhofstrasse 2, 6300 Zug, Switzerland and its global Group Affiliates (which means all FunPlus’ group affiliated legal entities under the direct or indirect control of KingsGroup Holdings (Cayman Islands). This policy deals with where we are acting as a ‘data controller’ under the data protection legislation: which essentially means where we are responsible for deciding what Personal Data we collect and how we use it. We may also operate as a ‘data processor’, meaning that we are processing Personal Data on behalf of another entity. When we refer to “Personal Data”, we mean “personal” relating to you personally or from which you can be identified. Some of the information mentioned in this policy is not “Personal Data” as is meant under data protection legislation, but we may refer to it to help you understand what we do.
We are committed to protecting and respecting the Personal Data of everyone we deal with – that is important to us and we know it is important to you.
This Policy applies to our suppliers and service providers who are individuals (such as self-employed persons, social media brand ambassadors), the representatives, employees, or contact persons of our contractors, suppliers, and service providers. In this Policy, you will find information about which types of Personal Data we hold about you, how and why we collect it, how we use it, and how we keep it secure. You will also find information about your rights and how you may exercise them.
Please read this Policy carefully and if you wish to contact us about anything that is in here, or for anything else related to your Personal Data, you can reach us by email at firstname.lastname@example.org or by post at the address below.
You’ll find in this Policy information about the following:
1.What information do we collect about you?
We will collect your contact information so that we can manage our business relationship with you. When you provide services to us we may collect other information from you which is relevant to the provision of those services. We may process the following categories of Personal Data:
- Contact information, including the name of the contact person, identification information, country time zone, language, work email address, personal email address, phone number, and personal address, if necessary;
- Information about your company including your company name, department, job title, and your position;
- Personal Data that is necessary for signing documents, including signature, proof of authorisation, certificates, and authorizations;
- Personal Data that is necessary for the assessment of the tender process and for the purposes of managing our business relationship;
- For our individual service providers, we may also collect certain financial information such as Bank account details; and
- Social media account(s).
2. How we collect information about you
We will collect this information in a variety of ways depending on how we interact with you, such as:
- Directly from you.
- You may give us your identity, contact, or other information by filling in online forms or by corresponding with us by post, phone, email, or otherwise;
- You may give your Personal Data to us prior to entering into an agreement with uS.
- from Your employer, if any; or
- from FunPlus’ suppliers` database.
3. How we use your information?
We may use different information in different ways:
- We process your Personal Data if you have registered as a supplier or prospective supplier via our website;
- To contact you and your company in relation to the business relations or opportunities with your company;
- As a contact person or representative of your company, we use your Personal Data to enable us to manage our business relationships and conduct our business;
- To communicate with you via phone, letter, or email;
- To send you a press kit;
- To identify, evaluate and select your company as our contractor/supplier;
- To conclude the commercial agreements and in connection with invoicing, accounting, and financial statements;
- When you have entered into an agreement with FunPlus, we process your Personal Data in connection with the management of the contract; and
- any other purposes imposed by applicable law and governmental authorities.
4. Legal basis for processing
There are a number of different legal grounds for processing Personal Data. Which one is applicable will depend on how we are using your information and for what purpose. In the majority of cases the applicable condition of the following conditions needs to be fulfilled:
- You have provided your consent to us using your Personal Data for the above/mentioned purposes.
- Our legitimate interests are to run our business and to be able to manage FunPlus’ business relationships and interact with our contractors, service providers, or suppliers. When processing your Personal Data on this basis, we always seek to maintain a balance between our legitimate interests and your privacy.
- Our use of your Personal Data is necessary to take pre-contractual steps with you or to perform contractual obligations towards you (e.g. to manage your account and if we need to process your Personal Data to be able to perform your obligations); and/or
- Our use of your personal data is necessary to comply with a relevant legal or regulatory obligation such as bookkeeping legislation.
We generally do not collect or process any ‘special categories’ of personal data (including information regarding your health, religious or political beliefs, ethnic background, sexual life, and sexual orientation). If this would apply, we will generally rely on obtaining additional explicit consent from you at the time we collect the information unless there is a legal requirement or other justification for processing that information.
5. Sharing your information
The Personal Data you provide to us may be shared internally with our personnel and with third-party companies, contractors, service providers, or our affiliated companies to respond to your inquiries or for any of the purposes described in this Policy. Such recipients are obligated to protect the confidentiality and security of your Personal Data. This may include:
- FunPlus personnel (e.g all employees, interns, directors, shareholders, and employees of our Group Affiliates);
- Our business partners and suppliers;
- Sub-processors who store or process the information on our behalf, in particular data analytics providers and data storage providers. Information shared with such providers is supplied in an anonymised format such that, that data cannot be linked to any particular individual and is therefore not considered to be ‘Personal Data;
- Our auditors, insurers, lawyers, and other professional advisers;
- Credit reference check agencies in the context of our supplier compliance policy;
- Law enforcement agencies, other governmental agencies, or third parties if we are required by law to do so;
- Other business entities (in case of any merger, acquisition, or re-organization involving such business entity).
6. International Data Transfers
FunPlus is operating globally and belongs to the global FunPlus Group. Your Personal Data can therefore be transferred anywhere in the world for the purposes as set in section 3 of this Policy. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this policy. Our relevant group entities and partners will use adequate safeguards, which may amongst others include EU-approved standard contractual clauses.
7. Your rights
Under EU data protection laws you have a number of rights in relation to your Personal Data. We respect and honour these rights and will help you to exercise them insofar as we are able.
You have the right:
- To request access to or a copy of any Personal Data which we hold about you;
- To rectification of your Personal Data, if you consider that the information we are holding is inaccurate;
- To ask us to delete your Personal Data, if you consider that we do not have the right to hold it;
- To withdraw consent to our processing of your Personal Data (to the extent such processing is based on your previously obtained consent);
- To ask us to stop or start sending you marketing messages as described below in the marketing section;
- To restrict the processing of your Personal Data;
- To request the transfer of your Personal Data to a third-party;
- To object to your Personal Data being processed in certain circumstances; and
- To not be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your Personal Data.
Please note that these rights are not absolute – in some cases they will not apply to you, or to the particular use that we are making of your data, and there are exceptions (for example if we have to process the data to comply with our own legal obligations) but if that is the case we will let you know if you make a request that we believe we cannot comply with.
Any request from you for access to or a copy of your Personal Data must be in writing and sent to our Privacy Office by e-mail at email@example.com and we will endeavour to respond within a reasonable period, however, in any event within one month such in compliance with data protection legislation. We will comply with our legal obligations in respect of your rights as a data subject.
We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, you have the option to fully control the data you shared with us, and you may update your information directly under your profile or adjust the settings on your device.
8. How long will we keep your information?
We will only keep the information we collect about you for as long as required for the purposes set out in this policy and as required to comply with any legal obligations applicable to us. This will involve us periodically reviewing our files to check that information is accurate, up-to-date, and still required.
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. Such measures will be appropriate to the nature of the data concerned and the level of risk. If you have been provided with a password to access any of our services you should not share that password with anyone else.
10. Links to Other Sites
11. European Union Representative
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our Swedish EU GDPR Representative EUrepresentativeoffice@funplus.com or contact your local data protection authority within the European Economic Area respectively the Swedish data protection authority.
Questions, comments, and requests regarding this Policy are welcomed and should be addressed to FunPlus International AG, Bahnhofstrasse 2, 6300 Zug, Switzerland, or by email to firstname.lastname@example.org.
13. Changes to this policy
We will update this Policy from time to time. Any changes we make to our Policy in the future will be posted on this page and, where material and appropriate, notified to you by email, by prominent posting on our website or through other appropriate communications channels.