Privacy Policy

Effective as of 8 December 2020

1: Introduction

Höganäs is responsible for how we handle your personal data. Höganäs comprises of Höganäs AB (a public limited liability company incorporated in Sweden, registration number 556005-0121) and its subsidiary undertakings (referred to collectively as “Höganäs”, “we” or “our”). For the purposes of applicable data protection laws, your data will be controlled by the Höganäs affiliate or subsidiary undertaking that you have instructed, that is providing products or services to you, purchasing products or services from you or otherwise communicating to you and each such entity is regarded as an independent data controller of your personal data. This policy (“Privacy Policy”) applies to all such entities and explains how Höganäs collects, uses, discloses and stores your personal data as well as the rights you have as a data subject of Höganäs.

The Privacy Policy is applicable to all products and services that are provided by Höganäs in connection with orders, purchases, support, service matters, marketing, events and other requests as well as for all other contact with Höganäs, such as visits to our website www.hoganas.com ("website"), by email/phone or visits to our sites.

2: Definitions

In this Privacy Policy, the term "personal data" means any information relating to an identified or identifiable person, such as name, email address and telephone number (and in the US, Personal Identifiable Information (PII)).

In this Privacy Policy, we describe how we process your personal data. "Processing" means any operation or set of operations which is performed by us on your personal data or on sets of personal data, such as collecting, recording, organizing, structuring, storing, adapting, retrieving, consultation, using, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction as described in this Privacy Policy.

3: The information we process and why

The information we process about you depends on your relationship and activities with Höganäs. Höganäs only processes personal data that is necessary and relevant for the purposes described in sections 3.1 – 3.8 below.

When you are asked to provide personal data, you can choose to decline. In cases where you choose not to provide necessary information to access a particular product/service, you might not be able to use the specific product/service or otherwise interact with Höganäs.

3.1: Customers

– if the company you work for purchases our products and services

Categories of data	Purposes
Contact data (such as name, business address email address and phone number)	Effective and efficient communication: communicate regarding orders and respond to your questions; send information about Höganäs’ products and services of interest to you; lead generation; fulfill our obligation to keep you informed about safety matters; communicate technical changes; enter into and fulfil agreements with the company that you represent
Organizational data (such as which company and department you work in)	Efficient communication and marketing: understand what products and services information you would be interested in receiving
Training records (such as training attendance, completion of learning activities, competence data, qualifications)	Administer our supplier relationship with you and to communicate and develop new training opportunities you may be interested in
Individual preferences (such as language and food preferences)	Provide efficient communication in the language of your choice and cater for dietary requirements. To offer you a pleasant experience when dealing with us.
Service and warranty data (service history and claims)	For contract warranty fulfilment and for product development improvements and for fulfilling our maintenance obligations
Health and safety data (such as incidents occurring during visits to our test and manufacturing facilities and any injuries that may occur from use of our equipment or products)	Fulfill legal obligations to record incidents and claims management. Improve safety in hazardous environments and to facilitate access for individuals with physical restrictions
Travel data (such as visa and passport information, travel costs, itinerary)	Arrangement of travel to Höganäs’ sites and events, including the arrangement of visas

If you are dealing with Höganäs as a private person, we may also process the following personal data:

Categories of data	Purposes
Financial data (such as credit or payment information, bank account details)	Fulfilment of agreement and financial control: to pay or receive payment; assess credit and payment history; fulfil anti-money laundering obligations; manage rebate and refunds
Contract data (such as sales and purchase orders, shipment address or return to address, billing information and other information collected under our customer contracts, scope of assignment if you are a sales agent)	Facilitation of order management, shipment and warranty; administration of service level agreements; administration of agreement

3.2: Suppliers

– if you work for one of our many supplier companies from which we purchase goods and services

Categories of data	Purposes
Contact data (such as name, business address email address and phone number)	Effective and efficient communication: send and receive information about Höganäs’ requests for quotations and orders and your offering; respond to your questions; lead generation; information about safety matters; communication regarding technical changes and order changes; enter into and fulfil agreements with the company that you represent
Organizational data (such as which company and department you work in)	Efficient communication and purchasing: understand what products and services you could provide to Höganäs
Training records (such as training attendance, completion of learning activities, competence data, qualifications)	Administer our customer relationship with you and to communicate and develop new training opportunities you may be interested in
Individual preferences (such as language and food preferences)	Provide efficient communication in the language of your choice and cater for dietary requirements. To offer you a pleasant experience in dealing with us.
Service and warranty data (redelivery and repair, service history and claims)	For contract warranty fulfilment and for product development improvements and for fulfilment of your maintenance obligations
Health and safety data (such as incidents occurring during visits to our test and manufacturing facilities and any injuries that may occur from use of our equipment of products)	Fulfill legal obligations to record incidents and claims management. Improve safety in hazardous environments and to facilitate access for individuals with physical restrictions
Travel data (such as visa and passport information, travel costs, itinerary)	Arrangement of travel to Höganäs’ sites and events, including the arrangement of visas

3.3: Partners

– if you work for one of our distributors or agents or other intermediaries or partners with which we cooperate

Categories of data	Purposes
Contact data (such as name, business address email address and phone number)	Effective and efficient communication: communicate regarding orders, marketing and questions; send information about Höganäs’ products and services of interest to you; lead generation; fulfill our obligation to keep you informed about safety matters; communicate technical changes; enter into and fulfil agreements with the company that you represent
Organizational data (such as which company and department you work in)	Efficient communication and marketing: understand what products and services information you would be interested in receiving
Training records (such as training attendance, completion of learning activities, competence data, qualifications)	Administer our partner relationship with you and to communicate and develop new training opportunities you may be interested in
Compliance risk assessment data (results from performed compliance risk assessments, such as sanctioned party screenings, country risk evaluations)	Identify transactions we would not be willing to enter into, on reasons of compliance with different legal rules and requirements, mainly with regard to anti-money laundering, anti-bribery, corruption and economic sanctions and our interest of obtaining global compliance herewith, as well as risk management, corporate social responsibility and sustainability considerations when it comes to what business partners we would like to do business with
Individual preferences (such as language and food preferences)	Provide efficient communication in the language of your choice and cater for dietary requirements. To offer you a pleasant experience in dealing with us.
Service and warranty data (service history and claims	For contract warranty fulfilment and for product development improvements and for fulfilling our maintenance obligations
Health and safety data (such as incidents occurring during visits to our test and manufacturing facilities and any injuries that may occur from use of our equipment of products)	Fulfill legal obligations to record incidents and claims management. Improve safety in hazardous environments and to facilitate access for individuals with physical restrictions
Travel data (such as visa and passport information, travel costs, itinerary)	Arrangement of travel to Höganäs’ sites and events, including the arrangement of visas

3.4: Digital visitors

– if you navigate our website without registering as a digital registrant

Categories of data	Purposes
Information about the event you attended	Follow-up with you about more information regarding the product or service you showed interest in and to send you information about related products and services
Log and usage data, device data and location data (such as IP address, cookies – as further detailed in section 6 below - , session identifiers, browser and device type, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our website and other technical information)	Operate and improve your overall web-browsing experience. Personalize your browsing experience and to allow us to deliver the type of content and product service offerings of most interest to you. Allow us to better service you in responding to your customer service requests. Efficiently process your transactions. Administer a promotion, survey or other website feature. Maintain the security and operation of our website. Internal analytics and reporting purposes.

3.5: Facility visitors

– if you visit any of our offices or facilities

Categories of data	Purposes
Contact data (such as name, business address email address and phone number)	Effective and efficient communication: respond to your questions; send information about Höganäs’ products and services of interest to you; lead generation; fulfill our obligation to keep you informed about safety matters; communicate technical changes
Organizational data (such as which company and department you work in)	Efficient communication and marketing: understand what products and services information you would be interested in receiving
Location, date and time of visit information	Travel and transfer arrangements, welcome messages
Video, photo, time and location of recording, car or truck license plate number	Limited camera surveillance. Cameras are stationed at certain unmanned or manned gates to the industrial areas for the following purposes: Open and close gates safely to prevent damage to vehicles and people Control so no unauthorized people gain access to the industrial area when opening gates Monitor exposed areas where there is risk that unauthorized people gain access to the industrial area unnoticed To prevent and reveal property damage and related crime Investigate incidents and accidents
License plate number of vehicle	Facilitate and manage parking permits
Individual preferences (such as language and food preferences)	Provide efficient communication in the language of your choice and cater for dietary requirements. To offer you a pleasant experience in dealing with us.
Health and safety data (such as incidents occurring during visits to our test and manufacturing facilities and any injuries that may occur from use of our equipment or products	Fulfill legal obligations to record incidents and claims management. Improve safety in hazardous environments and to facilitate access for individuals with physical restrictions
Travel data (such as visa and passport information, travel costs, itinerary)	Arrangement of travel to Höganäs’ sites and events, including the arrangement of visas
Information about the event you attended	Follow-up with you about more information regarding the product or service you showed interest in and to send you information about related products and services

3.6: Digital registrants

– if you use our website to request information about our products or services, register for newsletters or events, respond to surveys or marketing communication or use any of our community forums. If you use our website to apply for a job, a separate privacy policy

Categories of data	Purposes
Contact data (such as name, business address email address and phone number)	Effective and efficient communication: respond to your questions; send information about Höganäs’ products and services of interest to you; lead generation; fulfill our obligation to keep you informed about safety matters; communicate technical changes
Organizational data (such as which company and department you work in)	Efficient communication and marketing: understand what products and services information you would be interested in receiving
Individual preferences (such as language and technology preferences)	Provide efficient communication in the language of your choice. To offer you a pleasant experience in dealing with us.
Information about the event you attended	Follow-up with you about more information regarding the product or service you showed interest in and to send you information about related products and services
Information about where you were on the website when you gave us your contact information and the material you downloaded from our website.	Follow-up with you about more information regarding the product or service you showed interest in and to send you related product or service information
Information about Höganäs’ newsletters or other Höganäs content related material you have subscribed to	Deliverd subscribed material and follow-up with you about more information regarding the product or service you showed interest in and to send you related product or service information

3.7: Physical registrants

– if you register with us in person at any of our events

Categories of data	Purposes
Contact data (such as name, business address email address and phone number)	Effective and efficient communication: respond to your questions; send information about Höganäs’ products and services of interest to you; lead generation; fulfill our obligation to keep you informed about safety matters; communicate technical changes
Organizational data (such as which company and department you work in)	Efficient communication and marketing: understand what products and services information you would be interested in receiving
Location, date and time of visit information	Travel and transfer arrangements, welcome messages
Individual preferences (such as language and food preferences)	Provide efficient communication in the language of your choice and cater for dietary requirements. To offer you a pleasant experience in dealing with us.
Information about the event you attended	Follow-up with you about more information regarding the product or service you showed interest in and to send you information about related products and services
Information about Höganäs’ newsletters or other Höganäs content related material you have subscribed to	Follow-up with you about more information regarding the product or service you showed interest in and to send you related product or service information

3.8 Information from other sources

In addition to the above stated categories of personal data processed and the identified purposes, we have developed a separate Privacy Statement to describe the due diligence and other screening activities in accordance with legal and regulatory obligations and risk management procedures that we purchase from Dow Jones/Factiva Limited.

In some limited circumstances we may also collect and process personal data from public databases, marketing partners and other external sources in order to enhance our ability to provide relevant marketing, offers and services to you and update our records. This information includes mail and e-mail address, job title, phone number, intent data or user behavior data, IP address, social media profiles, social media URLs and custom profiles. The purposes of these collections are to be able to provide targeted advertising and event promotion.

4: Legal grounds for processing

We need to process your personal data as specified in section 3 above in order to enter into or fulfil our contractual obligations with the company/organization that you work for and therefore we process your personal data on the legal grounds of legitimate interest. If you are dealing with Höganäs as a private person or applying for a job with us, we need to process your personal data in order to enter into or fulfil our contractual obligations with you. In cases where you supply your job application through our website, we have a separate privacy policy for the information that you share with us, and to process this information we, in addition, rely on your consent.

Your personal data may be processed for direct marketing purposes, however only in respect to products and services that Höganäs markets. This allows us to provide you and the company/organization that you work for, with offers or other direct marketing in connection with our products/services, by mail, e-mail, or by phone. The legal grounds for processing your personal data for direct marketing purposes, is our legitimate business interests. You may at any time decline any direct marketing by following the opt-out link in the message sent to you.

When you order material from us or subscribe to newsletters and the like, we may, due to legal obligations process your personal data based on your consent.

Some of the personal data that Höganäs collects might be processed to comply with legal obligations, as required by laws or judgments or governmental decisions, or due to our legitimate interest in seeking to meet our global legal obligations, to reduce compliance risks and to carry out business. Such requirements may for example exist in the applicable data protection laws, accounting act or the money laundering act and in different export control and sanctions regulations.

We may also use your personal data to comply with law or legal process, to protect, enforce or defend our legal rights, safety or property, to protect against fraud and other unlawful activity or for risk management purposes. The legal grounds for these purposes is to comply with legal obligations and our legitimate interest in protecting our business interests and property.

5: How long is your personal data processed?

Unless a longer retention period is required or permitted by local law to which Höganäs is subject, your personal data will only be stored as long as Höganäs deems it necessary to fulfill the purposes for which the personal data was collected in accordance with this Privacy Policy. Your personal data will be deleted or anonymized as soon as the personal data is no longer relevant for the purpose.

Furthermore, we never process your personal data longer than what is allowed according to applicable laws, regulations, practices or authority decisions. Personal data that we manage in order to do business with your employer/client is saved for the time it is necessary for us to administer the agreement, practice our rights and fulfil our commitments to the company you are representing or otherwise work for.

We save your personal data as long as we have business on behalf of the company you are representing or in any way working for and as long as it is necessary to maintain a customer contact.

Personal data processed for marketing purposes is stored for three years after the business relationship has expired, i.e. after the products/services have been provided and the company/organization that you work for is no longer an existing business partner/customer to us. If you do not wish for us to keep personal data for marketing purposes during this time, please contact us or follow the opt-out link in the message sent to you.

In order to enable Höganäs to comply with the legal obligations arising from law (bookkeeping, product safety, money laundering, etc.) or to take charge of Höganäs’ legal interests (if a legal process is in progress or might be initiated), Höganäs may save personal data for longer. However, personal data will be saved only as long as is necessary and/or stated for the purpose.

6: Cookies

When you visit our website, we use cookies. Cookies are small files that a site or its service provider transfers to your computer or phone through your browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. Cookies are used to help us understand your preferences based on previous or current site activity, to personalize content and ads and to provide social media features, all which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may use trusted third-party services such as Google Analytics and Google Data Studio that track this information on our behalf and we may also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you have provided to them or that they have collected from your use of their services.

On our website, we have embedded content from social media channels and other online providers such as Facebook, LinkedIn, Twitter, Tint, Dreambroker, Google Maps and Google reCAPTCHA. This may result in cookies outside our control being set by these websites, so-called third-party cookies.
Embedded content from the following third-party services may set cookies in your browser. Follow the links below to read more about how these services use cookies.

Google Privacy Policy
Google Analytics: Terms of Service
Google Tag Manager: Terms of Service
Google Data Stuido: Terms of Service
Google Maps: Terms of Service
Google reCAPCHA: Terms of Use

LinkedIn: Privacy Policy
Facebook: Data Use Policy
Twitter: Privacy Policy
Dreambroker: Cookie Policy
Tint: Privacy Policy

For more information on how we use cookies, please read our Cookie Policy and Cookie Declaration (see link 'Change your consent' below). You can also, at any time, choose not to allow certain cookies by adjusting your cookie settings in the Cookie Declaration. If you disable some cookies some of our services will not function properly.

Change your consent

7: Social media

Höganäs may provide social media accounts and may collect and process personal data provided by you on social media connected to us. This can be made through your posting on our social media channels or direct messaging or by tagging Höganäs in your social media posts. Any personal data you choose to submit in such forums has been voluntary submitted and we have a legitimate interest in performing our business and communicating with you, as well as to protect the Höganäs brand, prevent fraudulent behavior and to support existing customers/suppliers or other partners. The data you submit may be read, collected or used by others who visit these forums. These third parties may at their own discretion send you unsolicited messages. We are not responsible for these third parties handling of your personal data.

Comments made by social media users referencing Höganäs, posts on Höganäs’ social media, and the like, do not necessarily reflect the opinion of Höganäs, nor does Höganäs confirm their accuracy.

Höganäs adheres to the terms and conditions provided by the social media platforms where Höganäs has a presence and we reserve the right to delete offensive, profane or socially irresponsible comments, posts and uploads. Users not adhering to the terms and conditions can be subject to being blocked and reported for further investigation, where relevant.

8: Your rights as a data subject

In some regions, such as the European Economic Area (“EEA”), California, Brazil etc. you have certain rights in relation to the personal data we hold about you.

You are entitled to obtain information from us, confirming whether or not personal data concerning you is being processed. You are in most cases also entitled to receive a copy of the personal data that we process about you. Furthermore, you may ask us to update, correct or remove personal data we hold about you, or object to or ask us to restrict our processing of your personal data. Contact information can be found at the end of this Privacy Policy. In order to ensure your identity in connection with your request, we may ask for further information from you. We will not unlawfully discriminate against you if you exercise your privacy rights.

Any request should be submitted in writing to us with clarification as to what information you wish to receive. We will respond to your request as soon as we can. If we cannot meet your request regarding access to the information your request concerns, we will provide reasons for this. Any copy of your personal data requested will be sent to your registered address unless otherwise agreed in writing.

If we have collected your personal data based on your consent, you have the right to withdraw your consent at any time. You may exercise this right by clicking the “unsubscribe” or “manage subscription” link located at the bottom of Höganäs’ marketing e-mails or by contacting us using the contact details provided below. If you have applied for a job with Höganäs, you can at any time log in and update your created profile. Please note however, that withdrawing your consent will not affect the lawfulness of the processing before the withdrawal, nor will it affect the processing of your personal data conducted in reliance on another legal ground than your consent.

If you believe we are unlawfully processing your personal data you have the right to lodge a complaint with a supervisory authority. For information on supervisory authority contacts, see the Contacts section below.

9: Sharing information

Höganäs does not sell or trade personal data to third parties. However, we may transfer your personal data to third parties based on our legitimate interests in managing our business and provide you with high quality products and services, purchases, marketing information and other communication, as applicable by using services of third-party companies. This means that we share some of the personal data that we have collected from you with these selected third parties, such as companies which provide us with servers and cloud-based services and sales representatives that are acting on our account. Höganäs undertakes in connection with such sharing or transfer of your personal data to such selected third parties, to take appropriate technical and organizational precautions to ensure that your personal data is handled securely and safely. These selected third parties will only process your personal data in accordance with, and to fulfill the purposes stated in, this Privacy Policy.

Höganäs is responsible for the processing of your personal data performed by such third parties and to ensure that these third parties treat your personal data in a correct and legal manner.

We and our sales representatives usually only process personal data of people within the EEA within the EEA. If personal data is transferred from the EEA to any non-EEA country, Höganäs will make sure that personal data remains protected and also take the necessary actions to legally transfer personal data to non-EEA countries in accordance with applicable data protection laws. If the country is not considered by the European Commission to provide an adequate level of data protection, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission, to protect your personal data. To obtain a copy of our safeguards for such transfers, please communicate your request using the information shown below under section Contacts.

Höganäs may also share your personal data with another Höganäs company, if necessary to perform business with the company that you represent, to market and sell relevant Höganäs products and services to you and otherwise respond to any requests put forward by you.

Höganäs may share or transfer your personal data in connection with or during negotiations of any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company.

Höganäs may be required to disclose your personal data when required by law, legal process or authority decision. Such disclosure may, for example, be done for the police or the tax office or for other governmental authorities. We may also disclose your personal data to our professional advisers, including legal service providers and accountants in the context of taking professional advice and protecting our rights and to law enforcement agencies and authorities to protect, enforce or defend our legal rights, privacy, safety or property, to protect against fraud and other unlawful activity or for risk management purposes.

10: Safety

To protect your personal privacy, detect, prevent and limit the risk of hacker attacks, etc., Höganäs undertakes technical and organizational security measures. These measures are taken to protect your personal data against unauthorized access, abuse, disclosure, changes and disruption.

11: Changes to the Privacy Policy

Höganäs reserves the right to unilaterally amend this Privacy Policy when it is necessary due to compliance with applicable laws. Such changes are mainly called for in the event of any legislative changes, due to statements from the supervisory authority or other bodies issuing opinions on the basis of applicable data protection laws. In addition, this Privacy Policy will be updated as needed as a result of changes in our products/services.

When this Privacy Policy is updated, the date for update will be shown at the top of this Privacy Policy. If Höganäs makes major changes to this Privacy Policy or changes regarding how we process your personal data, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your personal data.

12: Contact information for our Group DPO and supervisory authorities

If you have questions regarding this Privacy Policy or the processing of your personal data, or if you wish to make a request in accordance with the Privacy Policy or to report a violation of this Privacy Policy, please contact our Data Protection Officer (DPO) at dpo@hoganas.com or you may write to:

Höganäs AB (publ)
Attn: Group DPO
SE - 263 83 Höganäs
Sweden

Or call +46 42 33 80 00 and ask to be connected to the Data Protection Officer.

We will respond to your questions and complaints about our processing of your personal data. If you are not satisfied with our response, depending on where you are located, you can contact a supervisory authority or your state’s attorney general.

A list of supervisory authorities in the European Union, including our lead supervisory authority in Sweden, Datainspektionen / Integritetsskyddsmyndigheten / Swedish Authority for Privacy Protection, can be accessed here.

If you are a resident in Switzerland, the contact details for the data protection authorities are available here.