Privacy Notice
Your privacy is important for us at Areim. On this page, you will find information about our processing of your personal data.
We process your personal data as part of our work, and we are committed to being transparent with the information we process about you and why. We have therefore prepared this privacy notice which describes our processing of your personal data.
The final responsibility for personal data processing lies with Areim AB, org. no 556719-4203 (“Areim”, “we”, “us” and “our”) as it is deemed the data controller for all alternative investment funds managed by it (the “Funds”), all subsidiaries wholly owned by the Funds and for all other entities operating within the Areim Group. This means that we are responsible for ensuring that the processing of your personal data as described herein is carried out in accordance with the rules set out in the General Data Protection Regulation (“GDPR”) and other applicable data protection and privacy laws and regulations (together “Privacy Laws”).
Areim has an internal personal data protection policy, based on the Privacy Laws. This internal policy applies to all situations where Areim processes personal data and must be adhered to by all Areim employees and consultants. Areim also maintains a so-called data processing register containing our personal data processing activities.
If you have any questions or complaints about the way we process your personal data, or wish to request exercise of your rights as a data subject, you are welcome to contact us by email at dataskydd@areim.se or by post to the following address: Areim AB, Regeringsgatan 30-32 B, 111 53 Stockholm, Sweden. You can find more information about what rights you have and how you may exercise them under the headline “What are your rights as data subject” below.
You can find directed information relating to our processing of personal data under the separate headings below.
The information on this page applies in general. In some cases, more specific information is provided in a separate contract or in another manner for other forms of involvement with Areim. Such information is intended to complement, and where appropriate, amend the information herein.
Areim also collects and processes personal data in contact with suppliers or their representatives and other external parties or in conjunction with press releases, recruitment processes and the fulfillment of its legal obligations.
Areim aslo collects and processes personal data in relation to potential and current tenants relating to the assets owned by the Funds.
The personal data we process in the above contexts may consist of contact details (e.g., name, title, employer, postal address, telephone number and email address), identification details (e.g., passport details and date of birth/ID number), and invoicing information (e.g., account number and tax details). We may also process personal data in the form of sound or image recordings in conjunction with marketing activities and other social events.
- If you are a service provider providing services to us under an agreement, we may also save information that relates to the engagement including but not limited to your CV. We may also collect information relating to you that we find in public registers or social media.
- If we have arranged or participated in an event, a conference or other social arrangement, we may save photos or films in conjunction with such the occasions, where you might be included, and use this for documentation or for marketing of future events.
- If you’re a resident, or a lease holder of a commercial facility with a private company in one of our properties, we also collect and process your personal security number, your flat number or the identification code of your lease engagement, and information about your bank, bank account and any credit information used to fulfill our legal agreement. If necessary, we will also save information about you in relation to any incoming complaints or investigations that we carry out regarding breach of contract etc.
- If you are a representative of an investor, or a potential investor or representative of such in one of our investment funds, we will due to regulatory requirements regarding measures against money laundering and financing of terrorism also collect and process data to understand whether you are 1) a beneficial owner of a company we are conduction business with, 2) a politically exposed person that might be subject to bribery or corruption, 3) or has been sanctioned by the European Union (“EU”) or the United Nations (“UN”) in the EU’s resp. the UN´s sanctions lists.
Areim also processes personal data for marketing purposes, statistics, system testing, market and customer analyses, in order to provide an overall understanding of Areim´s customer involvement and satisfaction. Additionally, personal data relating to existing and potential tenants, stakeholders and other partners may be processed to be further analyzed to develop and improve our business. Moreover, personal data may also be used to evaluate, develop, and improve our services, products, and it-systems for our customs in general.
We will only process your personal data for the purposes it was collected, and we will not share it with other persons or parties than as described herein this Privacy Notice.
Lease agreements for commercial or residential facilities
If you have signed an agreement for lease of a commercial or residential property in one of our properties, we will use your personal data to contact your, provide rent notices, receive rent or fees, and to information you of any activities in the property, or to uphold or fulfill our legal rights and obligations under the agreement.
The legal ground relied upon for this processing is fulfilling rights and obligations under an agreement and/or, where applicable, Areim´s legitimate interest after balancing of interests has been carried out.
The legal ground relied upon for this processing is legal obligations under mandatory laws and Areim´s legitimate interest after balancing of interests has been carried out.
The legal ground relied upon for this processing is Areim´s legitimate interest after balancing of interests has been carried out.
The legal ground relied upon for this processing is Areim´s legitimate interest after balancing of interests has been carried out.
The legal ground relied upon for this processing is Areim´s legitimate interest after balancing of interests has been carried out.
The legal ground relied upon for this processing is Areim´s legitimate interest after balancing of interests has been carried out.
In case we want to store your personal data for future recruitment purposes, we will ask for your consent to this.
The legal ground relied upon for this processing is Areim´s legitimate interest after balancing of interests has been carried out.
The legal ground relied upon for this processing is Areim´s legitimate interest after balancing of interests has been carried out.
Areim may share your personal data with our branch offices in Denmark, Finland and Norway and our sister company Areim Advisory (property adviser in Sweden), to be able to conduct our business and fulfill our obligations to our clients. In general, we do not share your personal data with parties outside the EU/EES area.
Areim does not sell personal data or other information about our relations to third parties.
Personal data processed within the IT-systems that we use to provide our services may be shared with IT-service providers outside EU/EES. This processing will in such a case be necessary to ensure our interests in providing qualitative and reliable services with secure techniques to you. We will ensure in agreements that the provider uses adequate technical and organizational measures to protect your personal data. Such providers will be obliged to fulfil contractual obligations which ensure that their processing of your personal data is compliant with the Privacy Laws.
If you are a tenant or a leaseholder in one of our properties, your personal data will be shared with our accounting firm, with the payment service provider, with the property manager, and as necessary any maintenance providers. In case of litigation, legal processes or other circumstances that might require external advice, the personal data may also be shared with a legal firm, an authority or other relevant party.
We may also share personal data with authorities acting on their own mission in accordance with laws or authority decisions, for example Swedish Financial Supervisory Authority, Swedish Authority for Privacy Protection (“IMY”), the courts, the tax authority, or the police.
- Areim is a licensed alternative investment funds manager (fund manager) under the supervision of the Swedish Financial Supervisory Authority. This means that certain information, including personal data, relating to our business, our services, business relations, clients etc. must be archived and retained for at least five (5) years, however, an even longer archiving period may be necessary.
- Should the personal data be collected on basis of the Know Your Customer rules in the regulations for measures against money laundering and financing of terrorism the personal data will be saved for at least five (5) years. If the individual that the data belongs to has been subject to an investigation, in which case we are prohibited from informing the individual of this, it will have to be saved for ten (10) years.
- The requirement to retain information regarding our fund management may mean that we are prevented to dispose personal data on you before the five (5) years have elapsed since collection if it is needed to fulfil rights and obligations under an agreement, or if they are subject to specific regulatory requirements.
- Information needed for accounting and book-keeping shall be saved in accordance with the Accounting Act for at least seven (7) years.
- Information needed for investigation of incidents, any breach of contract, and any suspicion of crime in, or that concerns, our properties for the purpose of substantiating legal claims may be saved for two (2) years unless there is a dispute that requires longer processing. Reports of crime may only be saved for such time we are able to act.
What are your rights as data subject?
Areim is the controller of the processing of personal data described above. This means we are responsible for ensuring that the personal data are processed in accordance with current the Privacy Laws.
Data subjects have the right:
(i) to know what personal data we process about them;
(ii) to request that we rectify inaccurate or incomplete personal data about them;
(iii) to request that we erase their personal data (e.g., if the data are no longer needed for the purpose or if consent is withdrawn) or request that processing of the personal data be restricted;
(iv) to object to specific processing of personal data; and
(v) in some circumstances, to receive the personal data they have provided in machine-readable form, and to transmit them to another controller.
In some cases, restriction or erasure of personal data may also prevent us from meeting our commitments, e.g., to provide certain invitations or certain information. In the context of recruitment, restriction or erasure of personal data may prevent us from proceeding with a person’s application.
Anyone with objections about, or comments on, the way we process personal data has the right to contact or file a complaint with the Swedish Authority for Privacy Protection, which is the supervisory authority for our processing of personal data.
If you have any questions or complaints about the way we process personal data or wish to request exercise of rights as described above, you are welcome to contact us by email at dataskydd@areim.se or by post to the following address: Areim AB, Regeringsgatan 30-32 B, 111 53 Stockholm, Sweden.