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Privacy Policy

About ProMiner

At JPKF AB, organization number 559417-4178 (“ProMiner”, “we”, “us”, “our”), we value personal privacy. This means we respect and protect your privacy and your right to control and transparency in the processing of your Personal Data.

This Privacy Policy (“Policy”) is applicable to the processing activities for which ProMiner is the Data Controller. The Policy outlines the general purposes for which we need your Personal Data, the legal grounds we rely on, and the measures we take to protect personal data. We also inform you about how to exercise the rights you have in connection to our processing of your Personal Data.

This Policy provides information on our handling of Personal Data when you communicate with us, use our services, purchase our products, or visit our website ProMiner.se (collectively, “Features”).

Who This Policy Applies To

  • Users of our services
  • Potential customers
  • Customers
  • Employees of potential customers
  • Employees of existing customers
  • Visitors to our website

Definitions

  • “Processing” of Personal Data is anything that can be done with Personal Data, such as storage, alteration, reading, transmission, etc.
  • “Applicable Law” is the legislation applicable to the processing of Personal Data, including the General Data Protection Regulation (GDPR), complementary national legislation, as well as practices, guidelines, and recommendations issued by a national or European supervisory authority.
  • “Personal Data” is any information that can be linked to an identifiable, living person.
  • “Data Controller” is the company/organization that determines the purposes and means of the processing of Personal Data and thereby also is responsible for ensuring Personal Data is processed according to Applicable Law.
  • “Data Processor” is the company/organization that processes Personal Data on behalf of the Data Controller and thus may only process Personal Data according to the instructions of the Data Controller and Applicable Law.
  • “Data Subject” means the living, physical person whose Personal Data is processed.
  • “Services” refers to the mining hardware, tools, and support services we provide.

ProMiner’s Responsibility for Data Processing

The information in this Policy encompasses the Processing of Personal Data for which ProMiner is the Data Controller, meaning the Processing for which we determine the purpose (why Processing is done) and means (how it is done, what Personal Data is used, how long etc.). This Policy does not describe how we process personal data in the role of Data Processor, meaning when we process personal data on behalf of our customers.

Why We Need Your Personal Data

ProMiner provides a platform for purchasing mining hardware and related services. We therefore need to process your Personal Data to create user accounts and match you with services that meet your needs. We also contact relevant individuals in the mining industry for the sale of our services.

Types of Personal Data We Process

We have a responsibility to describe and show how we meet the requirements placed on us when we process your Personal Data. This section aims to give you an understanding of the types of personal data we process about you and for which purposes.

Duration of Storage of Personal Data

We store your Personal Data as long as necessary for the purpose for which it was collected. Depending on the legal basis we rely on, this may be: a) under an agreement, b) based on valid consent, c) as stipulated by legislation, or d) based on an internal assessment resulting from a balancing of interests.

We never store your Personal Data longer than necessary and regularly purge Personal Data. ProMiner also takes reasonable measures to keep the Personal Data processed up-to-date and to delete outdated and other incorrect or redundant Personal Data.

Processing Activities

The primary purpose of the personal data processing we perform is to provide, execute, and improve our services to you. There are several reasons why we may need to collect, manage, and save your data.

We mainly process the following personal data:

  • Contact and identification details to confirm your identity, verify your information, and communicate with you
  • Financial information to perform customer due diligence and risk assessments
  • Information about your use of the service or product to improve your customer experience
  • IP address for customer analysis and to present content on our site efficiently for you and the device you use
  • Consumption patterns to provide specific offers
  • Payment information to offer direct debit and other payment methods

How We Acquire Your Personal Data

  • Directly from you when you provide it to us
  • From your employer
  • Through social media platforms like Facebook or other media
  • Through third-party analysis technologies like cookies
  • Through credit rating agencies like UC
  • When we gather KYC (Know Your Customer) information
  • Through our security systems
  • Through our logs
  • From information generated from data analysis
  • Through internally generated information
  • From public sources like government authorities, SPAR, etc.

Legal Grounds for Processing Personal Data

To process your data, we must have a legal basis for each processing activity. In our operations, we primarily process your Personal Data on the following grounds:

  • Consent: ProMiner processes your Personal Data after we have obtained your consent for the processing. Information about the processing is always provided when we ask for your consent.
  • Agreement: The processing is necessary for us to fulfill obligations in an agreement between us or to prepare to enter into an agreement with the Data Subject.
  • Balancing of Interests: ProMiner may process personal data if we have determined that there is a legitimate interest that outweighs the Data Subject’s protection of personal integrity and if the processing is necessary for the current purpose, e.g., direct marketing.
  • Legal Obligation: We are legally obliged by applicable laws and regulations to process personal data as a result of our operations.

Your Rights

You decide over your Personal Data. We always strive to ensure you can exercise your rights as effectively and smoothly as possible.

  • Access: You have the right to obtain information about the processing involving you through a so-called registry extract. The registry extract shows, among other things, which of your personal data we have stored, for what purposes, and on what legal basis. We only release information after ensuring that it is indeed you who ask for the data.
  • Correction: If you find that the Personal Data we process about you is incorrect, contact us, and we will correct it.
  • Deletion: Do you want us to forget you entirely? You have the right to request the deletion of your Personal Data when they are no longer necessary for the purpose they were collected. If we are obliged to retain your data by law or an agreement we have entered into with you, we will ensure that they are only processed for the specific purpose specified by the law or agreement. Afterwards, we make sure the data is deleted as soon as possible.
  • Objection: Do you disagree with us that our interest in processing your Personal Data outweighs your interest in protecting personal integrity? No worries – in that case, we reassess our balancing of interests and check if it still holds. We, of course, consider your objection when making a new assessment to determine whether we can justify our processing of your Personal Data. If you object to direct marketing, we will remove your Personal Data immediately without reassessing our interest.
  • Restriction: You may also ask us to restrict our processing of your data:
    • While we manage a request from you regarding any of your other rights.
    • If you, instead of requesting deletion, want us to mark that the data should not be processed for a specific purpose. E.g., if you do not want us to send you advertisements in the future, we need to retain your name to know that we should not contact you.
    • In cases where we no longer need the data for the purpose they were collected but you want us to retain the data to assert a legal claim.
  • Data Portability: We can provide you with the data you have given to us or that we have obtained from you when entering into an agreement. You receive your data in a commonly used and machine-readable format that you can then bring to another Data Controller.

How to Use Your Rights

Contact us at support@ProMiner.se, and we will assist you.

Transfer of Personal Data

To run our business, we may need to enlist others who process Personal Data on our behalf, known as Data Processors.

In cases where our Data Processors transfer Personal Data to a country outside the EU/EEA, we have ensured that the processing is lawful according to Applicable Law by meeting one of the following requirements:

  • There is a decision by the EU Commission that the country ensures an adequate level of protection;
  • Application of the EU Commission’s standard contractual clauses for third-country transfers; or
  • Other appropriate safeguards that meet Applicable Law.

We have entered into data processing agreements (DPA) with all our Data Processors. The DPA regulates how the Data Processor may process the Personal Data and the security measures required for processing.

We may also need to provide your Personal Data to certain specified authorities to fulfill obligations according to law or regulatory decision.

Our Data Processors

ProMiner does not sell your Personal Data to anyone, and we do not distribute your Personal Data to just anyone. In certain cases, we may share your Personal Data with selected third parties. If this happens, we ensure the transfer is done safely and maintains your privacy. Below are categories of recipients we may share your data with:

  • Marketing service providers, e.g., advertising agencies for campaigns or providers for mail or postal distribution.
  • HR system or HR service providers, e.g., through systems for contract management or payroll.
  • IT providers, e.g., business systems and case management systems. To carry out our assignments and services, we store your data in our business systems.
  • Systems for customer analysis and statistics to contribute to industry statistics and improve the customer experience.

Security Measures

ProMiner has taken technical and organizational measures to ensure that your Personal Data is processed securely and protected from loss, misuse, unauthorized or unlawful access.

Our Security Measures:

  • Organizational Security Measures:
    • Internal guidelines (policies/instructions)
    • Login and password management
    • Information security policy
    • Physical security (premises, etc.)
  • Technical Security Measures:
    • Encryption
    • Pseudonymization
    • Access List
    • Secure Network
    • VPN
    • Firewall
    • Backup
    • Regular security level checks
    • Two-step verification

Cookies

ProMiner uses cookies and similar tracking technologies to analyze how our Features are used to provide you with the best user experience possible. More information on how we use cookies can be found in our Cookie Policy.

If We Do Not Meet Our Promises

If you feel that we are processing your Personal Data incorrectly, even after notifying us, you have the right to file a complaint with the Swedish Data Protection Authority.

More information about our obligations and your rights can be found on the Swedish Data Protection Authority’s website (https://www.imy.se/). You can also contact the authority at imy@imy.se.

Changes to This Policy

We reserve the right to make changes to this Policy. In cases where the change affects our obligations or your rights, we will inform you in advance so that you can review the updated policy.

Contact Information

We have appointed a Data Protection Officer who can answer questions about your rights and other questions regarding how we process your personal data.

Contact details for ProMiner’s Data Protection Officer: Jean-Pierre Harzdorf jean-pierre.harzdorf@ProMiner.se