PERSONAL DATA POLICY

Data controller

The companies listed above within the Holmström Group are responsible for the processing of your personal data and are responsible for ensuring that such processing takes place in accordance with applicable legislation.

When do we process your personal data?

In order to administer your property or for you to contact us for service or information, we must collect and process personal data about you. Holmströmgruppen collects and processes personal data about you when you apply for an apartment, when you live within our apartment portfolio, when you have moved, or when you are in contact with us regarding your accommodation.

What personal data do we process about you?

The personal data that the Holmström Group collects and processes about you as a tenant is different depending on where you are in the rental process:

When applying
• Name
• Social Security number
• Address
• Phone number
• E-mail address
• Economic conditions
• Desired accommodation (apartment size, need for adapted accommodation.)
• Living conditions at the time of application/expression of interest in the form of
– tenancy (with indication of the landlord's name)
– condominium (with information about the contact person on the board of the tenant-owned association)
– own homes (with an indication of property designation) other accommodation with information about references.
• Any information provided by the applicant himself in the free text field in connection with the application.

The Holmström Group assumes that an application is valid until the applicant has been allocated an apartment or until the application is withdrawn.

When the rental relationship begins
• Name
• Social security number or coordination number (for non-registered persons)
• Address
• Phone number
• E-mail address
• Existence of security (e.g. guarantor)
• Presence of trustees/good man
• Financial information, account number, annual income, direct debit
• Accommodation form/category

While the lease is in progress, this is recorded
• Defaults
• Disturbances in the property
• Non-compliance with health, order and good condition
• Notice to the Social Welfare Board in connection with defaults or disturbances

When the lease has ended
• Information in rental agreements and related documents may be saved for as long as it is necessary to monitor outstanding claims relating to the rental relationship.
• In the case of a tenant whose rental relationship has ceased due to his or her misconduct, the name, social security number, rental property, time of removal and brief indication of the reason for removal, except for criminal data, may be kept for a maximum of two years after the rental relationship has ended.

Why do we process data about you?

The Holmström Group processes your data for the purpose of:

• Fulfil our obligations to you as a tenant such as administration of your property and notification of rent.
• Enable general customer care and customer service, such as answering questions and correcting incorrect data.
• Provide you with relevant information regarding your property
• Assess what payment methods we can offer you, e.g. through credit assessments
• Comply with applicable legislation, such as accounting legislation

The legal grounds for our processing of your personal data

The Holmström Group bases the processing of your personal data on the agreement that forms the basis of our relationship, your rental contract.
In some cases, the Holmström Group may have a legal obligation to process your personal data. This applies, for example, to the processing of personal data that we carry out in order to comply with the requirements of the Accounting Act.

How long do we keep data about you?

Your personal data is only stored for as long as there is a need to save it in order to fulfil the purposes for which the data was collected in accordance with this policy. The Holmström Group may save the data for longer than that if it is needed to comply with legal requirements or to protect the Legal Interests of the Holmström Group, e.g. if there is a legal process going on.

Who do we disclose personal data to?

The Holmström Group may disclose your information to third parties such as partners who perform services that the Holmström Group deems to be within the scope of the purpose for which the data was collected. The Holmström Group also transfer data to suppliers who provide our IT systems.

The protection of your personal data

You should always be able to feel safe when you provide us with your personal data. The Holmström Group has therefore taken the necessary security measures to protect your personal data against improper access, alteration and deletion. For example, all information about our tenants in IT systems that is protected through permission control and firewall is administered.

Your rights

The Holmström Group is responsible for ensuring that your personal data is processed in accordance with applicable legislation. The Holmström Group will, at your request or on its own initiative, correct, delete or supplement data that is found to be inaccurate, incomplete or misleading.

You have the right to request:

A. Access to your personal data.

This means that you have the right to request a register extract of the processing we carry out regarding your personal data. You also have the right to receive a copy of the personal data processed. You have the right to receive, once a year, through a written application, a register extract free of charge about what personal data are registered about you, the purposes of the processing and to which recipients the data have been or are to be disclosed. You are entitled in the register extract to receive information about where the data has been retrieved from if the personal data has not been collected from you as well as the anticipated period during which the data will be stored or the criteria used to determine this period. You also have the right to receive information about your other rights set out in this paragraph in the register extract. The requested register extract is retrieved by identification at Holmströmgruppen's office (Sturegatan 6, 114 35 Stockholm).

B. Correction of your personal data.

We will, at your request, correct as quickly as possible the incorrect or incomplete data we process about you.

c. Erasure of your personal data.

This means that you have the right to request that your personal data be deleted if it is no longer necessary for the purposes for which it was collected. However, there may be legal requirements that we may not immediately delete your personal data in, for example, accounting and tax legislation. We will then end the processing for purposes other than complying with the legislation.

d. Restriction of processing.

This means that your personal data is marked so that it can only be processed for certain defined purposes. Among other things, you can request restriction when you believe that your data is incorrect and you have requested correction under paragraph (b.). While the accuracy of the data is investigated, their processing will be restricted.

The Holmström Group will inform each recipient to whom the personal data has been disclosed as described above of any corrections or deletions of data and restriction of the processing of data.

You have the right to data portability. This means a right, under certain conditions, to obtain and transfer your personal data in a structured, widely used and machine-readable format to another data controller.

You have the right to object to personal data processing in cases where it has been carried out on the basis of a balance of interests. If you object to such processing, we will only continue the processing if there are legitimate reasons for the processing that outweigh your interests.

You have the right to lodge any complaints regarding the processing of your personal data with the Swedish Data Protection Authority. More information can be found on the Swedish Data Protection Authority's website: www.datainspektionen.se

Contact

Do not hesitate to contact us if you have any questions about this policy, the processing of your personal data or if you would like to request a register extract.

Holmström Group
Box 5184
102 44 Stockholm
info@holmstromgruppen.se