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Privacy Policy for Swedbank Fastighetsbyrå

Your privacy is important to us. We want you to be reassured that we are managing your personal data responsibly, irrespective of why you are in contact with us. This Privacy Policy contains general information about how we manage your personal data and comply with the relevant legislation. We also explain your rights with regard to your relationship with us at Fastighetsbyrån, and how you can exercise them.

2021-10-29

It is important that you feel confident about how we handle your personal data. We therefore ask you to read this text carefully. If you have any questions or concerns about how we process your personal data, please contact us at integritet@fastighetsbyran.se.

What are personal data and when are personal data processed?

Personal data include any information relating to an identified or identifiable living natural person. An identifiable natural person is someone who can be identified, either directly or indirectly, by such means as a name, personal identity number or address. However, encrypted data and some kinds of electronic identities (such as IP numbers) are also considered personal data whenever that they can be linked to a natural person.

Personal data processing includes all handling of personal data, that is, collection, recording, processing and storage.

What information do we collect and from what sources?


Fastighetsbyrån collects information from you when you visit us in person or online. You may also directly or indirectly provide us with information about yourself in a number of ways, such as when you hire an estate agent, attend a showing, visit the Fastighetsbyrån website, sign up for a subscription service, use services such as “My Website” or make contact with Fastighetsbyrån in any other way.


We may also collect information from third parties, such as the Lantmäteriet and other land registries for information on ownership, and our address provider for supplementary address information. The information we choose to collect about you depends on how and why you contact us.

Examples of personal data we collect include:

Personal and contact information, such as name personal identity number, email address, telephone number and address.

  • Personal and contact information including your name, national identity number, email address, mobile phone number and home address

  • Account and payment details for buyers and sellers

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

Why we need your data


The main purpose of the personal data processing carried out by Fastighetsbyrån is to provide, perform and improve our services to you. There are several reasons why we may need to collect, process and store your data. Some of them are purely legal: we need to save them to comply with applicable legislation, such as the Real Estate Brokers Act and money laundering legislation. At other times, we need to keep your personal data to fulfil our contracts, to provide you with what we have promised, or to offer you better, more personalized services. We must also perform some personal data processing in order to provide good service and support, and to look into any complaints in an efficient, customer-friendly way. If you oppose our marketing communications, we may also need to keep your personal data to ensure that you do not receive any mailings from us in the future.

If you apply for a job with us or are otherwise involved in a recruitment process, we need to process your personal data in order to manage the process and assess you as a candidate. More information on how we process the personal data of jobseekers can be found here.

Fastighetsbyrån processes personal data for the following purposes based on the following lawful basis:

Integrity

What is a ‘legitimate interest’?

Grounds of legitimate interest are used when processing is necessary to meet our legitimate interests, which include being able to offer you property-related products and services, including property alerts and final price subscription. We may also want to follow up on a viewing visit or the purchase of a home. Another of our legitimate interests is to keep our services as user-friendly and relevant to you as possible. We therefore need to analyse how our services are used in order to make improvements that help you as a customer. Our aim is to provide you with a service made up of relevant communication, different solutions and relevant, tailor-made offers. A further legitimate interest is to post sale prices and addresses on several channels, e.g. by posting on our own and our partners’ websites, via mailings and on social media in order to promote Fastighetsbyrån and our business. When grounds of legitimate interest are used, a balance is always struck between Fastighetsbyrån’s interest in processing personal data and data subjects’ interest in protecting their personal data. When we understand that the individual’s interest outweighs our own, we do not perform processing.

Why do we need your national identity number?

We sometimes need your personal identity number, such as when you sign a contract, because it is a secure way of establishing your identity. We only process your personal identity number when the purpose makes it clearly justified.

Who might we share your personal data with?

At Fastighetsbyrån, we do not sell your personal data to anyone and, of course, we do not share them with anyone. However, in some cases we may share your personal data with selected third parties. If this happens, we will ensure that transmission is secure. The recipients of your personal data may be independent data controllers, joint controllers like us or data processors.

When your personal data are shared with data processors, i.e. third parties that process your personal data on our behalf, this is done only for purposes consistent with the purposes for which we collect the information. We check on all data processors to ensure that they can provide sufficient guarantees regarding personal data security and confidentiality. In all our written agreements with data processors, they guarantee the security of the personal data being processed and agree to comply with our security requirements and instructions.

We may share your personal data with the following categories of recipients:

  • Other companies in the Swedbank Group. Fastighetsbyrån forms part of the Swedbank Group. Personal data may be shared with other companies in the group to be able to offer the products and services provided by other companies in the Swedbank Group, such as banking and financial services. A limited selection of personal data may also be shared between Fastighetsbyrån offices.

  • System suppliers for business systems and case management. In order to perform our assignments and services, we store your data in our business system (which manages our customers and contacts) and in a case management system in the event of problems.

  • Printing and advertising suppliers. We may also share information about you with our printing and distribution suppliers, such as descriptions of homes for sale and advertising via Hemnet.

  • Statistics. In order to contribute to industry statistics for residential sales, we share the address and sale price with Mäklarstatistik once the brokerage job is finished.

  • Cooperation partners. Fastighetsbyrån offers complementary products and services, such as insurance and surveys, and personal data may be transferred in these cases. Fastighetsbyrån also works with collaborators such as recommendation websites, where personal data may be transferred. In the case of new-build sales, certain personal data of buyers and potential buyers may also be shared with the developer and the homeowners’ association.

  • Estate agents and estate agencies have a legal obligation to provide the Swedish Estate Agents Inspectorate (FMI) with the information and documents it requests during its supervision. Personal data may therefore also be disclosed to the FMI and the agent’s insurance company.

Security when processing your personal data

We take a number of technical and organizational measures to ensure the security level is appropriate to protect the personal data we process. Among other measures, we have established internal guidelines for IT security, data protection and information security, as well as confidentiality agreements with employees, the Board, suppliers and partners. Fastighetsbyrån has also drafted instructions for information classification that regulate the level of security to be assigned to data, the security measures to be taken at each level and the chain of authorization, among others.

Where do we process your personal data?

As a rule, your personal data are processed within the EU/EEA by Fastighetsbyrån and our suppliers and partners. When personal data are processed outside the EU/EEA, we ensure that our suppliers and partners comply with the same security and protection levels applied in the EU/EEA, and have a legal basis for transmission that ensures appropriate safeguards. This could include the use of standard contractual clauses developed by the EU and whether the recipient country is deemed to have an adequate protection level.

How long do we store your personal data?

The retention period of the personal data we collect is determined based on the purpose and legal obligations of each processing operation. Personal data are therefore stored by Fastighetsbyrån for the time necessary for the purposes described above. This may be for as long as is required to carry out what we have promised you in our contracts or other commitments. It may also be for as long as required by law or government decision. Fastighetsbyrån regularly deletes the personal data it collects. Fastighetsbyrån also takes reasonable steps to keep the personal data processed up to date and to delete outdated and otherwise inaccurate or redundant personal data. Your personal data will be deleted or anonymized when the purpose or legal obligation to store them ends.

Camera surveillance

Some of the Fastighetsbyrån offices are equipped with cameras. Areas under camera surveillance are signposted. Fastighetsbyrån’s camera surveillance represents a legitimate interest based on legal grounds, given Fastighetsbyrån’s interest in ensuring the safety of its employees and customers. Personal data relating to suspected offences are processed for the purpose of establishing, exercising or defending legal claims. Given the purpose of camera surveillance, camera recordings are stored no longer than necessary. The CCTV footage may be disclosed to the relevant recipient if the footage is required for a criminal investigation.


Profiling and automated decision-making

Profiling refers to the automatic processing of personal data to assess certain personal characteristics of natural persons, in particular to analyse or predict details such as their financial situation, personal references, interests and place of residence. Fastighetsbyrån uses profiling for purposes such as market and customer analysis, systems development, marketing and automated decision-making. The legal basis for profiling is our legitimate interest, legal obligation and fulfilment of an agreement or a consent. When consent is the legal basis, you will be asked to give your consent to processing.

Fastighetsbyrån also uses automated decision-making in some cases. You have the right not to be subject to a decision based solely on any form of automated decision-making, including profiling, if the decision may involve legal consequences for you or significantly affect you in any other way. However, if you have given your consent, we have the right to use automated decision-making when it is necessary to conclude or perform a contract between us.

Your rights

Regardless of the information, we have stored on you, you should always be able to control your own data. Therefore, under current data protection legislation, you have the following rights:

  • Right of access.

    You can request an extract of your personal data and verify the information we hold on you. To ensure that no one else has access to your data, you must identify yourself when you request an extract from the register. 

  • Right to rectification.

    You have the right to have inaccurate or incomplete information about yourself corrected.

  • Right to be forgotten.

    You have the right to request that your personal data be deleted if the data is no longer needed for the purpose for which it was collected. However, if the data is being stored because of a legal obligation to store certain information, you are not entitled to request that such information is deleted

  • Right to data portability.

    If our right to process your personal data is based on consent from you, or in order to fulfil a contract with you, you are entitled to request a copy of such data in a machine-readable format in order to reuse it with another company. This primarily applies to data that you yourself have given us. In other words, only certain data is covered by the right to data portability

  • Right to object.

     You always have the right to request not to receive direct marketing, and to object to such processing of personal data based on a balancing of interests (legitimate interest)

    • In cases where we use a legitimate interest/balancing of interests as a lawful basis for a purpose, you have the opportunity to object to the processing. In order to continue processing your personal data following such an objection, we need to be able to show a compelling legitimate reason for the processing in question, which overrides your interests, rights or freedoms

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

  • Right to restriction of processing.

    • You have the right to restrict processing of your personal data if, for example, you consider it to be inaccurate

Remember that you have a say in which channels we use to contact you. For example, you may decide you do not want to be contacted via email or text message. You can also opt out of various types of mailing, such as newsletters. In such cases, you should not object to processing of the data, but instead just contact us and request a restriction to the communication channels we use.

Exercising your rights does not cost anything. However, if a request is clearly unfounded or unreasonable, we will charge a fee to cover any administrative expenses associated with the request. We may also turn down a request that is unfounded or unreasonable.

Complaints?

If you have any complaints about the way in which we process your personal data, you are entitled to submit them to the country’s supervisory authority. In Sweden that is Datainspektionen , which is responsible for monitoring and supervising us and other companies that manage personal data on the Swedish market. The equivalent supervisory authority in Spain is called Agencia Española de Protección de Datos, and in Portugal Comissão Nacional de Protecção de Dados – CNPD.

Contact details:
Sweden: Datainspektionen

Telephone: +46 (0)8-657 61 00
Email:
datainspektionen@datainspektionen.se

Spain: Agencia Española de Protección de Datos

Telephone: +34 91399 6200
Email:
internacional@agpd.es

Portugal: Comissão Nacional de Protecção de Dados – CNPD

Telephone: +351 21 392 84 00
Email:
geral@cnpd.pt

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Contact details for Fastighetsbyrån

Do you have any questions about how we manage your personal data, or would you like to exercise any of your rights associated with the management of your personal data? Then please contact us at Fastighetsbyrån using the contact details below.

If you contact us at integritet@fastighetsbyran.se your case will be in safe hands and we will get back to you shortly.

Contact details of the Personal Data Controller:

The Personal Data Controller is SWEDBANK FASTIGHETSBYRÅ AB (corp. id no 556090-2115), street address Västra Järnvägsgatan 7, 111 64 STOCKHOLM Sweden, and postal address Box 644, 101 32 STOCKHOLM Sweden, Tel: +46 (0)8-54 54 55 00, Fax: +46 (0)8-54 54 55 01, Email: info@fastighetsbyran.se, Website: www.fastighetsbyran.com