Privacy Policy for Swedbank Fastighetsbyrå

It is important that you feel comfortable with how we process your personal data. We therefore ask you to read the text carefully. If you have any questions or queries about how we process personal data, you are most welcome to email us at integritet@fastighetsbyran.se.

Swedbank Fastighetsbyrån AB (hereinafter “Fastighetsbyrån”) is the common data controller for the processing of personal data within the framework of the brokerage transactions with all real estate agencies in Portugal, Spain and Sweden. Fastighetsbyrån is jointly responsible with the real estate agent offices for ensuring that your personal privacy is protected and processed responsibly.

Fastighetsbyrån has implemented internal regulation of the various obligations we have to you regarding the exercising of your rights under GDPR. The common point of contact is integritet@fastighetsbyran.se for all enquiries concerning privacy and the processing of personal data.

If you have any questions about buying or selling a residence, please contact your estate agent.

“Personal data” is the umbrella term for all information that has to do with an identified or identifiable natural person. An “identifiable natural person” is a person who can be identified directly or indirectly through information such as their name, civil registration number and address, as well as via encrypted information and various types of electronic identity (e.g. IP number) that constitute personal data on condition that they can be linked to a natural person. Information that can only indirectly identify a person can be considered personal data as well, in the event that it is indirectly possible – in combination with other data – to identify a person.

The processing of personal data encompasses all aspects of handling personal data, such as collection, registration, processing and storage.

Fastighetsbyrån collects information from you when you visit us in person or digitally. You may also provide us with information about yourself directly or indirectly in a number of ways. Such situations can arise, for example, when you commission a real estate agent, participate in a viewing, visit the Fastighetsbyrån website, register for a subscription service, or use digital services such as Min hemsida (My homepage) and Visningshjälpen (Viewing aid).

We may also collect information from a third party; for example, owner information from Lantmäteriet (the Swedish mapping, cadastral and land registration authority) or supplementary address data from our address supplier. The information about you that we have reason to collect depends on how and why we have come into contact with each other. Examples of personal data we collect include:

• Personal and contact details such as your name, civil registration number, email address, phone number and physical address.

• Account and payment data for buyers and vendors.

• Device information such as IP-address, language and browser settings.

The principal purpose of the personal data processing performed by Fastighetsbyrån is to provide, execute and improve the services we supply to you. There are many reasons why we may need to collect, process and save information about you. Some of them are purely legal; for instance, we may need to save data in order to comply with prevailing laws such as the Swedish Estate Agents Act, or the currently applicable legislation to combat money laundering. In other cases, we may need to save your personal data in order to fulfil our agreements, supply you with what we promised, or offer you the best, most customized services possible. Some processing of personal data is also required to enable us to provide solid service and support, as well as to deal with complaints in an efficient, customer-friendly manner. We may also need to save your personal data if you decline to receive marketing from us, so that we can make sure that you do not receive any further mailings from us in the future.

If you apply to work for us or are otherwise involved in a recruitment process, we need to process your personal data in order to be able to administrate the process and assess you as a candidate. For more detailed information about how we process job applicants’ personal data, click here.

We may sometimes need your civil registration number, as this provides a secure way to establish your identity in connection with signing agreements, for example, or registering for the Digital Bidding service. We will only ever process your civil registration number when it is clearly necessary for the stated purpose.
When you register for the Digital Bidding service, the way your civil registration number is processed depends on how you use the service. If you register the service but do not submit a bid, we will store your civil registration number for as long as you are registered as a potential property buyer, after the number is archiving for two (2) years. If you do submit a bid for a property, you will be categorised as a bidder instead, and we will therefore store your civil registration number for ten (10) years pursuant to the Swedish Estate Agents Act.

Fastighetsbyrån processes personal data for the following objectives and on the following legal bases:

Purpose of the processingLegal basis for the processing (what entitles us to process your data)

To confirm your identity and verify your personal data and contact detailsTo fulfil our agreements and undertakings with you

To broker properties and supply other services for youTo fulfil our agreements and undertakings with you

To provide customer service and any assistance you may need regarding our servicesTo fulfil our agreements and undertakings with you

To process participation in competitions and events, where relevantConsent from you or our legitimate interest

To comply with prevailing legislation such as laws to combat money laundering and terrorism financingLegal obligation

Storage of verification pursuant to the Swedish Accounting ActLegal obligation

Maintaining journals pursuant to the Swedish Estate Agents ActLegal obligation

Customer group and market analysis in order to improving our services for youLegitimate interest

Mailing offers and marketingLegitimate interest

Ensuring that if you have declined advertising mailings, etc. they are not sent to youLegal obligation

To conduct digital customer meetingsLegitimate interest

To handle recruitmentsLegitimate interest

The period for which we store the personal data we collect is defined in accordance with the purpose of – and our legal obligations in relation to – each processing. In practice, this means that Fastighetsbyrån stores personal data for the period necessary for the purposes specified above. This may be for as long as is necessary for us to carry out what we promised you through an agreement or other undertaking. It may also be for as long as is necessary pursuant to prevailing laws or decisions from the authorities. For this reason, the storage periods may differ depending on our specific purpose in relation to the personal data. Fastighetsbyrån thins out personal data on a regular basis. Fastighetsbyrån also implements reasonable measures to ensure the personal data processed are up-to-date and to erase obsolete or otherwise incorrect or superfluous personal data. Your personal data will be erased or anonymised as soon as the purpose for which they were collected – or the statutory obligation to store them – expires.

Fastighetsbyrån has a legal obligation to store your data for a specified period for special reasons.

• For example, we process personal data linked to your recruitment for two (2) years after you submitted your application, on account of discrimination regulations.

• Under the Swedish Estate Agents Act, estate agents must keep records of brokerage assignments in a journal. Estate agents are also required to prepare bidding lists containing information about the bids made on the property and stating the name and contact details of the bidder, the sum bid, the date the bid was submitted and the terms and conditions of the bid. Fastighetsbyrån stores these personal data for ten (10) years.

• Fastighetsbyrån is obliged to comply with legislation to combat money laundering and terrorism financing. For this reason, Fastighetsbyrån must store personal data concerning customer verification or individual transactions of more than EUR 15,000 for five (5) years. If we consider it necessary to store the documents for longer in order to investigate possible money laundering, we can store personal data for a maximum of ten (10) years.

When we apply the legal basis of “legitimate interest”, this means that the processing is necessary to accommodate our legitimate interest. For example, this includes instances where we offer you property-related products and services such as our Value Monitor (Värdebevakaren) or End Price Subscription (Slutprisprenumeration). It may also apply to our wish to follow up on your participation in a viewing or your purchase of a property. In addition, legitimate interest encompasses keeping our services as user-friendly and relevant for you as possible. In this context, we need to analyse how the services are utilised in order to be able to make improvements for you, our customer.

Our objective is to provide you with service in the form of relevant communication and a range of services, as well as relevant and customised offers. Another legitimate interest is to communicate sales prices and addresses via different channels, for example through publication on our own and other partners’ websites, through mailings and on social media, with a view to marketing Fastighetsbyrån and our business. Whenever the legal basis of “legitimate interest” is applied, we always balance the interests of Fastighetsbyrån’s processing of personal data against the interests of the individual in protecting his/her personal data. If we consider the interests of the individual to take precedence, we do not conduct the processing.

Fastighetsbyrån does not sell your personal data to third parties, nor do we share them with just anyone. In some cases, however, we may share your personal data with selected recipients. If this should happen, the data will always be transferred in a secure manner. The recipients of your personal data may be a independent data controller, parties who share responsibility with us, or the personal data processor.

When we share your personal data with a personal data processor, i.e. a party that processes your personal data on our behalf, this is only done for purposes commensurate with the purposes for which we collected the information. We check all personal data processors to ensure that they can provide sufficient guarantees concerning the security and confidentiality of the data. We have written agreements with all personal data processors, through which they guarantee the security of the personal data processed and undertake to comply with all our security requirements and instructions.

The section below presents the categories of recipient with whom we may share your personal data:

• Swedbank. Fastighetsbyrån is a wholly owned subsidiary of Swedbank AB. We may therefore share your personal data with Swedbank for statistical purposes. We may also share your data with Swedbank and its affiliated companies in order to enable Swedbank to offer you mortgage products and other banking services.

• Banks. On request from you, we may share your information with your bank or another bank within the framework of the property purchase/sale.

• Fastighetsbyrån’s estate agents. Fastighetsbyrån is the common data controller with all our estate agent offices, which all operate under the same brand, using the same system. For this reason, your personal data may be shared between Fastighetsbyrån’s estate agent offices.

• Buyer and vendor. As a potential buyer of/bidder on a property, personal data such as your name, contact details and bid may be shared with the vendor on conclusion of the commission. If the property purchase is completed, the buyer will have access to the vendor’s personal data.

• System suppliers of business system and case processing. In order to be able to complete our commissions and services, we store your data in our business system (a system used to manage our customers and contacts) and, in the event of problems, in a case processing system.

• Suppliers of printing and advertising services. We may also share information about you with suppliers who provide printing and distribution services. This information may, for example, be a description of properties prior to sale, or advertisement of properties on the Hemnet website.

• Statistics and sales information. After Fastighetsbyrån has completed the mediation assignment the address, including coordinates and sales information, will be shared with “Svensk Mäklarstatistik AB” which is a trade organisation with the purpose of producing statistics for the real estate market. The information shared with Svensk Mäklarstatistik also include the final price of the property sold and if both vendor and buyer have given their approval this will be published on Bopedia for after-market purposes. If vendor and buyer have given approval, final price and address will also be shared with “Hemnet AB” for publication on Hemnet.se.

• Partners in association with brokerage transactions. Fastighetsbyrån offers a range of supplementary products and services, such as the brokerage of insurance policies and inspection services, which may involve transferring personal data to our partners. Fastighetsbyrån also participates in other working relationships – ratings sites, for example – which may entail the transfer of your personal data. Moreover, we work with other operators to simplify the brokerage process. Such operators include Wint, which we may commission to handle and facilitate making the down payment, and Scrive, which helps us sign agreements electronically. On the sale of new builds, some personal data about the prospective buyer/vendor may be shared with the contractor or the cooperative housing association.

• Authorities. Fastighetsbyrån may be required to supply your data to various authorities for a number of reasons. For example, real estate agents and real estate businesses are

  obliged by law to provide Fastighetsmäklarinspektionen [the Estate Agency Inspectorate] (FMI) with the information and documents that FMI requests for its monitoring activities. Personal data may therefore be submitted to FMI for this purpose. Fastighetsbyrån may be subject to a similar obligation with regard to the Swedish Financial Intelligence Unit if we have reasonable grounds to suspect that one of our customers is in breach of anti-money laundering laws.

• Insurance companies and legal agents. In some cases, Fastighetsbyrån may be required to share information with the estate agent’s insurance company or legal representative (a lawyer, for example). Personal data may be shared with such recipients with a view to establishing, exercising or defending legal claims, or in the event of suspected or established injury to Fastighetsbyrån, the buyer or the vendor.

We apply a number of technical and organisational measures to ensure a level of security that is appropriate to protecting the personal data we process. For example, we have established internal guidelines for IT security, data protection and information security, and have signed NDAs with employees, the Board of Directors, suppliers and partners. Fastighetsbyrån has also prepared instructions for the classification of information that regulate which security level is to apply to different kinds of information, which security measures are to be adopted for the respective levels, circles of authority, etc.

As a general rule, Fastighetsbyrån, our suppliers and partners all process your personal data within the EU/EEA. Data may, however, sometimes be transferred to the United States and Japan, through the use of Google Analytics to the United States, and via the service Digital live view to Japan. In the event that personal data are processed outside the EU/EEA, we make sure that our suppliers and partners live up to the same levels of security and protection as are applied within the EU/EEA, and that there is a legal basis for the transfer that guarantees applicable security measures. This may, for example, take the form of our using the standard agreement clauses prepared by the EU, or the recipient country having been adjudged to offer an adequate level of protection. When transferring data to the United States, Fastighetsbyrån relies on standard agreement clauses pursuant to Article 46.2 c of GDPR. The EU has adjudged Japan to offer an adequate level of protection, which means that Fastighetsbyrån is allowed to transfer personal data to Japan.

For additional information about recipient countries adjudged to offer an adequate level of protection, see www.imy.se/verksamhet/dataskydd/det-har-galler-enligt-gdpr/overforing-till-tredje-land/adekvat-skyddsniva/
If you have any other questions about Fastighetsbyrån’s transfers of data to third countries, backed by standard agreement clauses, email us at integritet@fastighetsbyran.se. You are also entitled to study a copy of the standard agreement clauses we have signed.

Swedbank Fastighetsbyrå AB is the data controller for the camera monitoring of the head office at the address Västra Järnvägsgatan 7, 111 64 Stockholm, Sweden. The respective estate agent offices are the data controllers for any camera monitoring of their office premises. So as to eliminate any potential misunderstandings: Swedbank Fastighetsbyrå AB is not data controller jointly with the individual estate agent offices as regards camera monitoring.

Camera monitored areas are clearly marked with signs. Fastighetsbyrån conducts camera monitoring on the basis of the legal grounds of “legitimate interest”, where Fastighetsbyrån has an interest in assuring the safety of Fastighetsbyrån’s staff and customers. Personal data concerning suspected crimes are processed with a view to establishing, exercising or defending legal claims. With regard to the purpose of camera monitoring, camera recordings are stored for a maximum of seven (7) days. The camera monitoring material may be submitted to relevant recipients in the event that the recordings are required to investigate a crime.

No matter what information about you we may have stored, you are always to be able to exercise control of your own data. You therefore have the right to the following under GDPR:

• Right to access (“register extract”)
  You are entitled to request an extract of registered personal data and to verify the information about you that we have stored. To prevent others gaining access to your data, you will be required to identify yourself when requesting a register extract.

• Right to rectification.
  You have the right to have incorrect or incomplete information about you rectified.

• Right to be erased.
  You have the right to request erasure of your personal data. We will then erase your data if these data are no longer necessary for the purpose for which they were collected. If the data have been stored on the basis of a statutory obligation, however, we cannot erase them.

• Right to data portability.
  If our right to process your personal data is based on consent given by you or in order to fulfil an agreement with you, you are entitled to request a copy of these data in a machine-readable format to allow you to reuse them at another company. This primarily applies to data you have provided to us yourself. In other words, only certain data are subject to the right to data portability.
  
  You are entitled to withdraw your consent at any time. If you withdraw your consent, all processing based on this consent will cease. To withdraw your consent, you can email us at: integritet@fastighetsbyran.se.

• Right to object to certain types of processing.
  You are always entitled to decline direct marketing and to object to any processing of personal data that is based on a balancing of interests (legitimate interest).

  • In cases where we apply legitimate interest/balancing of interests as the legal grounds for a given purpose, you are entitled to object to the processing. In order to continue to process your personal data subsequent to such an objection, we need to be able to prove a compelling, legitimate reason for the processing in question that weighs more heavily than your interests, rights or liberties.

  • If you object to direct marketing, we will cease processing your personal data for this purpose.

• Right to limit processing of personal data.

  • You are entitled to limit the processing of your personal data if, for example, you consider them to be incorrect.

Remember that you have the opportunity to influence the channels we use to contact you. For example, you can choose not to be contacted by email or text message. You also have the opportunity to decline different types of mailings – newsletters, for example. In such cases, you should not object to the processing of the information, but simply contact us and request limitation to one channel of communication that we use.

It does not cost you anything to exercise your rights. If, however, a request is obviously unfounded or unreasonable, we will charge a fee to cover the administrative costs associated with said request. We may also decline a request that is unfounded or unreasonable.

Fastighetsbyrån does not use automated decision-making.

In this context, “profiling” refers to automatic processing of personal data with a view to assessing certain personal characteristics of a natural person, more specifically, to analyse or predict, for instance, this person’s financial situation, personal references, interests or whereabouts. Fastighetsbyrån uses profiling for purposes including market- and customer analyses, and in system development. The legal grounds for profiling are our legitimate interest, legal obligations, fulfilment of agreements or consent. In the event that consent constitutes the legal grounds, you will be asked to give your consent for the processing.

You are entitled to withdraw your consent at any time. If you withdraw your consent, all processing based on this consent will cease. To withdraw your consent, you can email us at: integritet@fastighetsbyran.se.

If you have any complaints regarding our processing of your personal data, you have the right to submit them to the supervisory authority in the country in question. In Sweden, the Integritetsskyddsmyndigheten (Swedish Privacy Protection Authority – IMY) is responsible for supervising and following up on us and other companies that process personal data on the Swedish market. In Spain, the corresponding supervisory authority is the Agencia Española de Protección de Datos (Spanish Data Protection Agency – AEPD), while in Portugal it is the Comissão Nacional de Proteção de Dados ( Portuguese Data Protection Authority – CNPD).

Contact details:

Sweden: Integritetsskyddsmyndigheten (IMY)

Phone: +46 8 657 61 00

Email: imy@imy.se

Spain: Agencia Española de Protección de Datos (AEPD)

Phone: +34 900 293 183

Portugal: Comissão Nacional de Protecção de Dados (CNPD)

Phone: +351 213 928 400

Email: geral@cnpd.pt

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Do you have any questions about our handling of your personal data, or do you want to exercise any of your rights linked to the processing of personal data? If so, you are welcome to contact us at Fastighetsbyrån via integritet@fastighetsbyran.se.

The data controller is SWEDBANK FASTIGHETSBYRÅ AB (company reg. no. 556090–2115), visiting address: Västra Järnvägsgatan 7, 111 64 Stockholm, Sweden, and postal address: Box 644, 101 32 Stockholm, Sweden, Phone: +46 8 54 54 55 00,
Email: info@fastighetsbyran.se,
Web: www.fastighetsbyran.com

For additional information about the estate agent offices, see: https://www.fastighetsbyran.com/sv/sverige/hitta-maklare