At Winona, we care about protecting your personal integrity. To make sure that the personal data we collect is processed in a responsible and secure manner, we work actively with data protection issues. On this page, you can learn more about how we process your personal data and what rights you have according to applicable privacy regulations. If you have any questions about our privacy work or our processing of your data, you are always welcome to contact us at legal@akindgroup.com
Please note that if you interact with Winona in or from Sweden, Winona Sweden AB (company registration number: 559162-1445, address: Gamla Tanneforsvägen 92, 582 52 Linköping, Sweden) is considered the issuer of this Privacy Policy. Similarly, if you interact with Winona in or from Finland, Winona Finland Oy (company registration number: 3283808-6, address: Keilaranta 4, 02160 Espoo, Finland) is considered the issuer of this Privacy Policy.
What personal data do we collect and why?
Winona will collect personal data about you within the scope of the services we provide. The collection and subsequent processing of your data is necessary in order for us to fulfil our obligations towards you in accordance with the User Terms or as further needed to fulfil the data processing purpose. We may need to keep certain data about you in order to fulfil legal obligations, such as those imposed by labour laws or accounting regulations.
We will also collect your personal data when you visit our website by using cookies – with your approval. You can read more about how and when we use cookies here. As a website visitor, you are not obligated to give us access to your personal data and can avoid this by not accepting our use of cookies on your device.
How do we get access to your personal data?
The personal data that we store about you is data that you provided us with yourself, such as when you register as a user on our website, when you apply for a job via Winona, when you contact us regarding other matters like our services and business, or information that you have made public via professional networks that you are a user of, such as LinkedIn.
Who will we share your personal data with?
In some cases, we might share your personal data with external parties. The external parties are other companies within our Group, vendors to Winona, third-party end clients when Winona has been subcontracted to perform recruitment services, authorities that we are under a legal obligation to provide with certain information, or customers when applicable. When we share your personal data with an external party, it will only be for those purposes for which the data was initially collected. We will always take the necessary precautions to ensure that the external party processes your data in a correct and secure manner, such as by entering into binding agreements with our vendors.
You personal data may be shared with the following external parties:
Entities in Akind Group – We may share your information with other entities in Akind Group (the Group that Winona belongs to). This may occur when another Group company provides services to us that may result in processing your data on our behalf or when we work in group-wide applications.
Vendors and third parties – Your personal data may sometimes be shared with our main contractors, of which we are subcontractors or vendors who perform services on our behalf and based on our instructions. These may be vendors of IT vendors used for storage and operations management, vendors of marketing tools, font embedding tools on our website, recruitment tools, and personality tests.
Authorities – If required by national or international legislation, we may need to share your personal data with authorities, such as the Swedish Tax Authority (Skatteverket) or the Swedish Social Insurance Authority (Försäkringskassan).
Clients – If you apply for a job via Winona and progress through the recruitment process, we will present your information to our client at the end of the process. The recruiting client is responsible for how they handle the data that they receive. If you have questions about how our clients handle your personal data, we recommend that you turn directly to them. Winona is happy to assist you in contacting them.
You are always welcome to contact us for more detailed information about which external parties we share your personal data with.
Where do we process your personal data?
We always do our best to make sure that your personal data is not stored or otherwise processed in countries outside of the EU/EEA. However, your personal data may be transferred or processed at our suppliers in Canada, Norway, Switzerland, the UK, or the USA. In such circumstances, either a decision on an adequate level of protection is applied, in accordance with Article 45 of the General Data Protection Regulation, or appropriate protective measures are applied in accordance with Article 46 of the General Data Protection Regulation in the form of the European Commission's decided standard contractual clauses. If your data is transferred or handled in countries outside the EU/EEA, we will ensure that we have taken sufficient security measures (such as Standard Contractual Clauses (SCC), contractual, organizational and/or technical safeguards) which mean that your data is handled in a way that achieves a sufficient level of protection according to applicable regulations. If you would like a copy of the safeguards used or if you would like more information about where your personal data is processed, you are always welcome to contact us.
Legal basis
Winona must document a lawful basis for each processing of personal data. If there is no legal basis, the processing is not lawful and thus not permitted. Private companies and organizations can rely primarily on these following four bases:
- Consent
- Performance of contract
- Legal obligation
- Legitimate interest
When using legitimate interest as a basis, we always conduct a balancing test from which we assessed that our legitimate interest in carrying out the processing outweighs your interest in not processing your personal data. What Winona's legitimate interest is in each type of processing is stated in the detailed summary available in here.
What rights do you have?
Applicable privacy regulations provide you with a number of rights when your personal data is processed. Below you will find a short description of those rights. What rights you have may vary depending upon the purposes for which we are processing your data.
Right to information – You have the right to receive information about our processing of your personal data. Information about the processing of personal data must be provided by us as the data controller both when the data is collected and when you request access to it, which you can read more about under the heading.
Right to access – You have the right to know if Winona processes your personal data and to receive a copy of your personal data – a register extract – free of charge. The register extract will state what information we have about you, the purpose of the personal data processing, and how we process your personal data. Please contact legal@akindgroup.com, and we will assist you with this.
More information about the right of access can be found on the Swedish Authority for Privacy Protection's website and on the Finnish Office of the Data Protection Ombudsman’s website.
Right to withdraw consent - When our right to process your personal data is based on your consent, you always have the right to withdraw your consent. The easiest way for you to do this is by contacting legal@akindgroup.com.
Until you withdraw your consent, we have a legal basis and thus the right to process your personal data. After your consent is withdrawn, we will stop processing your personal data.
Right to rectification – You always have the right to demand that Winona corrects incorrect or incomplete information about you and that we supplement your information. Additionally, you always have the opportunity to change the information you provided in your candidate profile. More information about the right to rectification can be found on the Swedish Authority for Privacy Protection's website and on the Finnish Office of the Data Protection Ombudsman’s website.
Right to object – You have the right to object to Winona’s processing of your personal data, such as when it concerns direct marketing (including profiling). In all cases where we process your personal data based on our legitimate interest (including profiling), you have the possibility to object to the processing. If you object and notify us, we will stop processing your personal data.
More information about the right to object can be found on the Swedish Authority for Privacy Protection's website and on the Finnish Office of the Data Protection Ombudsman’s website.
Right to restriction – In some cases, you have the right to request that Winona restricts the processing of your personal data. This applies if, for example, you question that the personal data we process is correct. You can then request a restriction of processing for the time that we need to verify whether the personal data is correct. In that case, we may only (in addition to the storage itself) process the data upon your consent. It applies with the exception of establishing, asserting, or defending legal claims, to protect someone else’s right, or to protect an important public interest.
More information about the right to restriction can be found on the Swedish Authority for Privacy Protection's website and on the Finnish Office of the Data Protection Ombudsman’s website.
Right to erasure – As a starting point, you have the right to request that Winona delete your personal data. This applies in the following cases (among others):
- If the data is no longer necessary for the purposes it was collected for.
- If you withdraw your consent and we do not need to keep your data for other purposes, such as legal obligations.
- If you object to processing based on legitimate interest and your reason for objection outweighs our interest.
- If you object to our processing of your data for direct marketing purposes and we do not need to process your data for other purposes.
- If your personal data is processed in an illegal manner.
- If your personal data must be deleted due to legal obligations.
In some cases, Winona does not have the possibility to delete your personal data. This occurs when the data is either still necessary to process for the purpose for which it was collected or because there is a legal requirement that Winona must keep it for a certain period of time. It may also be because Winona's interest in continuing to process the data outweighs your interest in having it deleted, which we then need to be able to demonstrate decisive justified reasons why our processing outweighs your interests. You can read more about the legal requirements that apply to Winona regarding saving information even if you request to have your personal data deleted on the Swedish Authority for Privacy Protection's website.
The laws described in this document therefore prevent us from immediately deleting certain data. You also have the right to object to us using your personal data for certain purposes such as direct marketing, which you can read more about under the heading "Right to object" which you can find above.
More information about the right to be deleted can be found on the Swedish Authority for Privacy Protection's website or on the Finnish Office of the Data Protection Ombudsman’s website.
Right to data portability – In cases where we process your personal data with your consent, or to fulfil an agreement you entered with us, you have the right to demand that Winona provide you with the personal data you have given us in a machine-readable format. When exercising the right to data portability, you have the right to transfer your personal data directly from Winona to another personal data controller when this is technically possible. You can make such an extract yourself under My pages on our website.
More information about the right to portability can be found on the Swedish Authority for Privacy Protection's website or on the Finnish Office of the Data Protection Ombudsman’s website.
If you would like to exercise your rights, you are always welcome to contact us at legal@akindgroup.com.
Right to lodge a complaint – If you are dissatisfied with the way Winona's processes your personal data, you always have the right to lodge a complaint with a supervisory authority, in particular in the Member State where you have your domicile or place of work or where the alleged infringement was committed (stated in Article 77 of the GDPR). The Swedish Privacy Protection Authority can be reached through the following link and the Finnish Office of the Data Protection Ombudsman can be reached through the following link.
Cookies
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Changes in our privacy information
From time to time, we might make changes to this privacy information text. The latest version will always be available at our website. When more extensive updates are made (such as changes in the purposes for which we process your information or changes regarding what personal data we process about you) we will send out a new version of the information text to the email address you provided us.