ComAround and GDPR, May 2018

ComAround understands that when you use our services or websites you entrust us with your data. You trust that its privacy will be protected and that it will be used only in a manner that is consistent with your expectations and the regulations.

Important definitions

Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Personal data means any information relating to an identified or identifiable natural person (‘data subject’) and identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Data Subject means the identified or identifiable person to whom Personal Data relates.

Legitimate interest; Processing shall be lawful only if and to the extent that at least one of the following applies:

(a) the data subject has given consent to the processing of his or her personal data for one or more specific purposes; (b) processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; (c) processing is necessary for compliance with a legal obligation to which the controller is subject; (d) processing is necessary in order to protect the vital interests of the data subject or of another natural person; (e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; (f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

Point (f) of the first subparagraph shall not apply to processing carried out by public authorities in the performance of their tasks.

Data processor and controller

In general, Customer is the controller of Customer Data, and ComAround is the processor of Customer Data and the controller of other Information. If you are a customer and use our services, the processing of Customer Data is regulated in separate DPA (Data Processing Agreement).

Website privacy policy

This policy describes the privacy practices on our websites.

Why do we collect personal data

ComAround collects personal data and relevant information that is needed to properly provide our services and / or enhance the experience of visiting our websites. We need to process personal data in order to administrate user accounts, manage event and training session reports and we also use the data for marketing. If you no longer want to receive digital marketing, you can unsubscribe/opt-out.

What data we collect

Most of our web pages contain information which does not require any personal information from the web site visitor. However, in some cases we need to collect and store personal data in order to provide services or information that you request from the website.

We collect non sensitive data, i.e. first and last name, email address, workplace, position as well as company information and information regarding your website behaviour, your communications and interactions with the website.

How we collect and process personal data

The data is collected when you visit our web site and accept cookies or contact us by e-mail, are in a process to become a customer or a partner of ComAround, sign up for any of our events or training sessions, download material e.g whitepapers, apply for a job at ComAround or any other act that requires you to submit a form.

We generate statistics and aggregate reports for internal use, as well as for sharing with ComAround group companies, trusted partners and subcontractors. Our third-party web analytic providers may also create and publish aggregate reports of the data collected. The statistics and aggregate reports do not contain any data that could be linked to an individual website visitor.

If you have voluntarily submitted your contact information to ComAround— when purchasing a product, downloading a product trial, completing a survey or entering a contest, for example — we may, with your consent, tie your website usage to your individual record through the use of cookies. If you are a visitor interested in our corporate-oriented communication, this will also include your previous browsing on ComAround websites. If you already have a business relationship with ComAround this will be combined with the pre-existing information we have about you stored in our CRM-platform. We do not sell your personal data to third-party advertisers.

The processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest.

About cookies

The ComAround websites use cookies.

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

ComAround use session-cookies, cookies to identify language. There are two types of cookies, a permanent cookie that saves a file on your computer to enhance the website depending on your choices, interests or the fact that you have previously visited the website.

Our website is using both permanent cookies and session cookies. Permanent cookies are used to avoid requesting repeats of one-time information and session cookies are used to enable you to login to our services.

If you do not agree with the usage of cookies you can turn cookies off in your browsers security settings. There are also settings allowing your browser to show you a warning every time the browser is trying to put a cookie on your computer.

ComAround websites use the following cookies

  • Pll_language Identifies browser language and serves website in corresponding language.
  • Session- cookies
  • Google Analytics; Collects information in an anonymous form, including the number of visitors to the websites, where visitors have come to the websites from and the pages they visited.

About beacon tracking and scripts

ComAround uses web beacons and scripts from third party suppliers which, on behalf of ComAround, collect information about how website visitors use and communicate with the website. The same applies to our ditigal marketing. This way we can see how we acquire web traffic, which parts of the website that are most used and which links visitors click most.

We use this information to further improve and develop the content of our website and our digital advertising.

Access, Amendment, and Deletion

You may request to review, correct, delete or otherwise modify any of the personal information that you have previously provided to us through our Web sites.

To access, correct, modify or delete Your Data, please review the “Contacting ComAround” section below.  Requests to access, change, or delete your information will be addressed within a reasonable timeframe. If you are an employee of a ComAround customer, you may also wish to contact your company’s system administrator for assistance in correcting or updating your information.

ComAround may retain your information for a period of time consistent with the original purpose of collection. For instance, we may retain your information during a time needed for ComAround to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.


The security of your personal information is important to us. We adhere to the law, regulations and general recommendations within our business sector, regarding security of the personal information that is shared with us.

Questions regarding our privacy policy

By visiting our website and submitting your personal information, you accept that your personal data will be processed according to this privacy policy. ComAround reserves the right to revise the privacy policy without prior notice. Therefore we ask you to review this policy now and check it regularly if you are a frequent visitor to our website.

Contacting ComAround

ComAround Scandinavia AB
Holländargatan 13
111 36 Stockholm, Sweden

+46 8 580 886 40