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Privacy Policy

Information on processing of personal data

1. Introduction
With this information text ("Privacy Information"), Embark Studios AB ("Embark Studios"/"We") intend to fulfil our obligations under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) ("Data Protection Regulation"). An important aspect of this obligation is that persons to whom the information applies are informed of how personal data is processed.

2. Controller
Controller: Embark Studios AB
Corporate identification number: 559172-3019

Address: Järntorget 84
111 29 Stockholm

E-mail: contact@embark-studios.com

3. Categories of data subjects
Categories of data subjects whose personal data is processed by Embark Studios in accordance with this Privacy

Information are:
● Embark Studios customers/potential customers
● Embark Studios subcontractors/potential subcontractors
● Job applicants

4. Categories of personal data
The categories of personal data processed by Embark Studios in accordance with this Privacy Information are:

Customers/potential customers:
● Contact information such as name, address, e-mail address and phone number.
● Order information such as customer identification number, ordered service and payment.
● Contact information for the customer's employees such as name, e-mail address and phone number at the workplace.
● Billing information such as account number.

Subcontractors/potential subcontractors:
● Contact information such as name, address, e-mail address and phone number.
● Order information such as ordered service and payment.
● Contact information to the subcontractor's employees such as name, e-mail address and phone number at the workplace.
● Billing information such as account number.

Job applicants:
● Contact information such as name, address, e-mail address and phone number.
● Personal information such as age and gender.
● Work tasks such as CV, qualifications, and references.

5. Access
Embark Studios collects personal data, processed in accordance with this Privacy Information, from external address sources and from the data subject itself. We also collect personal data from data subjects in connection with contact and inquiries via contact@embark-studios.com.

6. For what purposes and on what legal basis do We process personal data?
a) Customers and subcontractors (contracting parties)

Complete obligations under agreement and law.

In connection with the provision of our services, We may process the personal data of customers and potential customers (see categories of personal data under section 4 above) in order to fulfil our obligations under the agreement with the customer, administer bookings, manage orders and make mandatory controls that follow from applicable law. We may hire subcontractors in order to be able to provide our services. In such case, We may process personal data relating to the employees of the subcontractors (see categories of personal data under section 4 above) in order to be able to fulfil our commitments under the agreement with the subcontractor, administering bookings, manage orders and make mandatory controls that follow from applicable law. The legal basis for this processing is that it is necessary in order to fulfil Embark Studios' obligations pursuant to an agreement and/or applicable law. Personal data needed to fulfil contractual obligations towards our contracting parties (customers/subcontractors) will be deleted twelve (12) months after We have fulfilled all of our obligations under the applicable agreement and met the counterparty's interests pursuant to applicable laws and agreements (such as warranty rights and warranty obligations). In some cases, Embark Studios may have a legal obligation to process personal data related to our contractors. This applies, for example, to the processing of personal data that We carry out in order to meet the requirements of the Swedish Accounting Act, prevent fraud and carry out risk management. Personal data processed to fulfil our legal obligations will be erased within seven (7) years after We have fulfilled all of our obligations under the applicable
agreement.

Balancing of interests
Part of the processing of personal data carried out by Embark Studios is based on legitimate interests. This, for example, applies to the processing of data regarding potential contracting parties (customers/subcontractors) where the purpose is to develop new business opportunities and organize future collaborations where processing is necessary to satisfy Embark Studios' legitimate business interests. Furthermore, We can, with the support of balancing interests as a legal basis, treat subcontractor's employees' personal data in order to ensure that resources are linked together with the appropriate assignment or project. Personal data processed employing legitimate interests as legal basis, will be deleted within twelve (12) months after We have fulfilled all of our obligations under the applicable agreement.

b) Job applicants
Embark Studios processes personal data relating to job applicants in order to be able to evaluate and register candidates, book interviews and manage contact with the job applicants. The legal basis for processing is that it is necessary in order to enter into a potential agreement with the job applicant. The applicant's personal data that is processed by Embark Studios will be deleted within one (1) month after the end of the recruitment process.

7. Who can We share personal data with?
a) Third parties - In order for us to be able to fulfil our commitments, We may transfer personal data to third parties. Such a third party can be a service provider of various HR and IT-services. Third parties that Embark Studios discloses personal data will only process the personal data for the purposes mentioned in this Privacy Information. Embark Studios has entered into data processing agreements with these third parties. All third parties that Embark Studios has entered into a data processing agreement with meet the requirements of applicable data protection legislation.
a) Transfers to third countries - Embark Studios always seeks to process personal data within the EU/EEA but in the event of a transfer of personal data outside the EU/EEA, Embark Studios will always observe applicable data protection legislation regarding transfers to third countries. Embark Studios will only transfer personal data to a country outside the EU/EEA provided that (i) the third country ensures an adequate level of protection of personal data under a decision issued by the EU Commission, (ii) Embark Studios ensures that appropriate security measures are in place according to applicable data protection legislation; or (iii) if any other exception exists under applicable data protection legislation.

8. Cookies
By using the webpage, Embark Studios collects information about user’s activity, e.g. which pages are visited and how they are used. Through server logs and other tools Embark Studios records information about your device and internet connection, including IP addresses. Embark Studios uses Google Analytics, a web analytics service provided by Google Inc, and cookies in order to improve the webpage, user experience and analyses how the Embark Studios website is used. Embark Studios uses cookies and Google Analytics to remember your settings as well as for authentication and analytics. Aside from the approximate location (IP address), the information collected by Google Analytics is mostly anonymous traffic data including browser information and device information. The collected information is used to provide an overview of how people are accessing and using the webpage. It is not used for any additional purpose, such as to profile those who access the Embark Studios webpage.

9. Security measures
Embark Studios takes appropriate technical and organizational measures to ensure a level of security that is appropriate in relation to the risk and to protect the personal data that We process against personal data breaches.

Only the staff at Embark Studios who need access to the personal data necessary to provide our services have been granted access. They are also obliged to observe confidentiality. In the event that a data breach occurs, Embark Studios will, as soon as We become aware of it, notify data subjects in writing without undue delay in accordance with the provisions of applicable data protection legislation.

10. Rights
According to the Data Protection Regulation data subjects have the right to:
● Request to receive a confirmation from Embark Studios about how We process personal data, and in such case request access to the personal data in the form of an extract from the register
● Correct incorrect or incomplete personal data
● Have your personal data deleted in some cases, e.g. if your personal data is no longer necessary for the purposes for which they were collected
● Object to processing that relies on legitimate interests, however only to the extent permitted by applicable data protection legislation
● Receive and transfer personal data to another controller in some cases (data portability)
● Lodge complaints regarding the processing to the Swedish Data Protection Authority or other competent supervisory authority within the EU

When requesting access to your personal data, please contact Embark Studios at:
E-mail: contact@embark-studios.com