Privacy Policy
Glad you have found our policy for the processing of personal data! We at Invono think that personal integrity is important and we therefore welcome the extended privacy protection that the European data protection regulation GDPR entails.
But we also know that it is not always so easy to absorb the rather extensive information that must be provided according to the GDPR and to understand what it means. We therefore want to start by highlighting some of the main principles of our privacy policy before we go further into the details. The policy has four main purposes:
Make sure you understand what data we collect and what we do - and don't do - with it.
Explain how we use the data, namely to be able to give you what you expect, to be able to keep you informed about Invono's operations and to be able to build really good products for companies and investors and give you the best possible experience with them.
Inform you about our responsibilities and your rights regarding our processing of your personal data.
Make it clear that we only use the information to be able to provide, inform about and develop our products and that we never disclose your personal data to anyone else for any other purpose.
In the four points above, our policy for personal data is described in a nutshell. Not that complicated, right! However, please read the entire policy carefully so that you get full clarity on our handling of your personal data and do not hesitate to contact us if you have any questions.
Parties and responsibility for the processing of your personal data
Personal data is used to be able to communicate with or deliver services to you or your company - and it is mainly the handling of such personal data that is described below.
In regards to Invono's cloud service INVONO One, Invono is thus responsible for processing such personal data that Invono collects when someone registers an account, logs in, edits their user profile or the contact details in a company profile, leaves payment details or uses the support function. All other processing of personal data in INVONO One, e.g. in connection with the creation of a digital share book, when uploading an employment contract or during a process for electronic signing of documents, the holder of the account in INVONO One where the processing takes place or is initiated is responsible for. For such personal data, Invono is the personal data assistant of the person who created an account in INVONO One and takes technical and organizational security measures so that the personal data can be processed safely and legally in INVONO One. You can read more about our security measures in Invono's Data Security Description.
What personal data do we process and why?
Contact request, newsletters and seminars, etc.
On Invono's website, it is possible to register as a recipient of news information, register interest in our seminars, events and information meetings, register for our web demo or for specific seminars and events, etc. and fill out a contact request.
The personal data (contact information such as e-mail) that you provide in connection with registration or notification as above will in each individual case be saved and processed by Invono - or whoever Invono hires - for the purpose of; answer a contact request, administer the sending of newsletters or invitations/information about seminars and the like to you, respectively provide web demo or specific seminar/event etc. for you. Consequently, if you do not provide the requested personal data, Invono will not be able to get back to you, provide web demo or specific seminar/event etc. for you or send you any newsletters or invitations/information.
The Investor Network
On Invono's website, there is also the option to sign up for our investor network. If you register for the investor network, the personal data you provide in connection with the registration (such as contact details, investment amounts, areas of interest, etc.) will be saved and processed by Invono in order to be able to send you information and contact you regarding relevant investment opportunities and to be able to offer enter relevant events, seminars and investment pitches etc. Consequently, if you do not provide the requested personal data, Invono will not be able to get back to you with information/invitations regarding investment opportunities.
Invono's digital platform INVONO One and Invono's service for e-signing documents
Invono saves and uses the personal data provided when creating an account in INVONO One (social security number, name, e-mail, password and in some cases credit card details) as well as later updates, changes and/or additions to such personal data that can be made in the user profile (profile picture , phone number, address, language setting). Invono also saves and uses the unique Invono ID that is created for every person who uses INVONO One.
When creating an account or logging in using BankID, Invono also processes personal data that BankID shares with Invono, namely information about which bank issued your BankID, technical information about IP address, type of BankID, type and version of mobile phone or computer as well as geographical location information at the time you use BankID.
Personal data submitted in connection with the creation of an account - and any changes/completions thereof - as well as data submitted in connection with the use of BankID are processed by Invono in order to: create the account; identify users; enable persons to log into and use INVONO One with its services and functions; make it possible for companies that use INVONO One to connect people who use INVONO One to their company accounts in order to e.g. register them as shareholders, grant them certain access to the company's account or communicate certain information to them; manage the payment – where applicable – for account in INVONO One; as well as being able to offer an introduction/demonstration and announce news and updates about INVONO One.
When you use INVONO One or Invono's document e-signing service, Invono may also collect information about how INVONO One or the e-signing service is accessed and used (e.g., how much time you spend on which pages and which links you choose to click on) as well as about technical data (e.g. IP address, screen size, browser and language setting). This information is processed by Invono partly so that we can use such direct feedback in our development to make INVONO One work better and become more relevant and user-friendly, and partly to prevent or prevent misuse of INVONO One and to facilitate investigation of possible authorization violations and/ or rights infringement.
With regard to social security numbers, we only process it when it is clearly justified with regard to the purpose, necessary for secure identification or if there is some other noteworthy reason. We always minimize the use of social security numbers as much as possible by, in cases where it is sufficient, instead using other data less worthy of protection.
Support regarding INVONO One and Invono's service for e-signing documents
Invono is the data controller for the processing of the personal data that you share with us when you have a question about INVONO One or the e-signature service or contact us via our support function. The personal data is saved and processed by Invono in order to answer questions and provide support regarding INVONO One and the e-signature service. The amount and nature of personal data may vary depending on which communication channel is used, and which personal data you choose to include in the question/contact. Categories of personal data are usually contact details and the case itself as unstructured material.
In cases where e-mails sent to Invono contain personal data, Invono's receipt and further handling of such e-mail means that we process the personal data. E-mail almost always contains personal data because the e-mail address itself is usually personal data. All other information in the message that can be linked to an individual is also personal data.
Since the content of incoming e-mail is usually unknown when the e-mail arrives at Invono, we initially process personal data in incoming e-mail by receiving and reading the e-mail in order to be able to assess whether we should take any further measures due to of the email and, if so, which ones. Invono may also process personal data, such as e-mail addresses and names, by sending e-mails for the purpose of e.g. respond to incoming email, ask a specific question or initiate – or communicate regarding – a specific matter.
The subsequent treatment of incoming and outgoing e-mails may consist of deletion of the e-mail and/or other measures that may vary depending on the individual content of each e-mail. If, after reading an incoming e-mail - or after sending an e-mail - Invono determines that Invono needs to take any action other than deleting the e-mail, then Invono will decide on a case-by-case basis what further treatment is legal and must be taken and we will handle the e-mail in the way that involves the smallest possible dissemination and storage time of the personal data. Invono will also make a security assessment on a case-by-case basis as to whether it is appropriate to continue the correspondence/processing via e-mail or whether it should be done in another way.
If an e-mail sent to us contains information about a third person, Invono will only inform such third person that we are processing personal data about him in that case; (i) it is clear from the information in the e-mail who the person is, (ii) no major efforts are required to get hold of the person, and (iii) the information about the person that the e-mail contains is of a sensitive nature.
With regard to e-mails sent from Invono, Invono avoids as much as possible including sensitive information about third parties in e-mail messages. If e-mails from Invono should still contain such information, such third parties will be informed.
Business benefit for Invono
The personal data provided in connection with notifications and registrations on Invono's websites invono.se and app.invono.se may also be used for information and marketing mailings from Invono and internal market research as well as as a basis for Invono's market and customer analyses, business and product development and statistics.
Cookies
When you use Invono's website, Invono also collects, with the help of so-called cookies, information about how the website is accessed and used, as well as about technical data regarding IP address(es), browser, device(s) and operating system. By using our website, you agree to our use of cookies in accordance with Invono's Cookie Policy.
With which right do we process your personal data?
The contact request, the investor network, newsletters and seminars, etc.
The treatment is based on a balancing of interests. In Invono's judgment, the processing is necessary for our legitimate interest in responding to a contact request or providing a web demo or a specific seminar/event etc. respectively administer the sending of newsletters, information and invitations to you in accordance with your wish to be contacted or participate in a web demo or a specific seminar/event etc. respectively receive mailings.
Invono's digital platform INVONO One and Invono's service for e-signing documents
Invono's processing of personal data as a data controller is based on an agreement between the person whose personal data Invono processes and Invono according to which Invono undertakes to provide INVONO One and its services. The processing is necessary for Invono to fulfill its contractual obligations.
As regards Invono's processing of personal data to analyze user behavior in INVONO One and the e-signature service, this is based on a balance of interests and is necessary for Invono's legitimate interest in partly continuously improving INVONO One and the e-signature service, and partly avoiding and preventing that INVONO One or the e-signature service is misused.
Support regarding INVONO One and Invono's service for e-signing documents
The processing is based - depending on which personal data is processed - partly on an agreement with the person whose personal data Invono processes according to which Invono undertakes to provide support regarding INVONO One and the e-signature service, partly on a balancing of interests. The processing is necessary for Invono to be able to fulfill its contractual obligations and for our legitimate interest in being able to provide relevant support to our customers.
In the case of incoming e-mail, the initial processing (reception and reading) of the e-mail is based on a balancing of interests. The processing is necessary for Invono's legitimate interest in handling incoming e-mail.
Regarding the sending of outgoing e-mails from Invono and the subsequent processing of both incoming and outgoing e-mails, the following applies. Subsequent processing may consist of deletion of the e-mail and/or other measures which may vary depending on the individual content of each e-mail. Processing in the form of deletion is based on Invono's legal obligation to minimize its personal data processing in accordance with the GDPR. What legal support Invono has for processing other than deletion (including the sending of outgoing e-mails) depends on the content of the e-mail and on the possible relationship Invono has with the sender. In the event that the e-mail comes from, or is sent to, a person (or indirectly a company) with whom Invono has a contractual relationship, the processing may be based on the contract. In other cases, the processing is usually based on a balance of interests where, according to Invono's assessment, the processing is necessary for our legitimate interest in the individual case.
Business benefit for Invono
Even Invono's processing of your personal data for information and marketing purposes, for internal market research and as a basis for Invono's market and customer analyses, business and product development and statistics is based on a balancing of interests. According to Invono's assessment, the processing is necessary for our legitimate interest to partly market our products and services, partly to analyze and develop our business.
How long we process your personal data?
Contact request
Personal data provided in connection with a contact request is stored by Invono until its feedback has taken place.
Newsletters and seminars, etc.
Personal data provided in connection with registration for newsletters or registration of interest for seminars, events and information meetings is stored by Invono until you unregister from the service in question. After unsubscribing, however, Invono will continue to process the e-mail you provided in connection with registration in order to technically ensure that no further mailings of newsletters or invitations/information about seminars and the like are sent to you. If Invono does not save your email, Invono will not be able to ensure that no further newsletters or invitations/information are sent to you. The continued processing of your e-mail is, in Invono's judgment, necessary for Invono's legitimate interest in preventing the sending of newsletters, information and invitations to you in accordance with your wish to no longer receive such mailings.
Note that Invono still needs to be able to communicate with you via email if you use INVONO One or Invono's document e-signing service. If you have provided the same e-mail address when registering for newsletters as in your account in INVONO One (or if that e-mail address has been entered by someone else in an e-signature process) then de-registration according to above will not mean that we will stop sending to the current email address related to you as a user in INVONO One or the e-signature service.
Personal data provided in connection with registration for a specific seminar/event etc. is deleted by invono within a reasonable time after the completion of the event/seminar etc.
As regards personal data collected prior to a web demo, these are saved for a period of one year from the initial web meeting in order for us to be able to fulfill our commitment in the best way and provide relevant demonstration/support.
The Investor Network
Personal data provided in connection with registration to the investor network is stored by Invono until you unsubscribe from the network.
Invono's digital platform INVONO One and Invono's service for e-signing documents
Personal data provided in connection with registering an account in INVONO One - or when changing/completing such data - is saved as long as there is a customer relationship or is necessary to achieve the purposes described in this policy. Upon termination of the agreement, the account in INVONO One will be closed and Invono will no longer process the personal data on its own behalf. If the personal data is not processed on behalf of anyone other than Invono, the personal data will be deleted within a reasonable time after the termination of the agreement, unless storage of the personal data is required by applicable law.
Personal data that BankID shares with Invono in connection with account creation or logging in using BankID is only temporarily processed by Invono in connection with the current use of BankID.
The data that is processed to partly improve INVONO One and the e-signature service, partly to prevent or prevent abuse of INVONO One or the e-signature service is processed as long as it is necessary to achieve the purposes described in this policy.
In the event that the corresponding personal data is also used by companies that use INVONO One, e.g. in the share register or company documents, the personal data will continue to be processed on behalf of such company, whereby Invono only acts as a personal data processor. However, any profile picture and/or credit card information will always be deleted in connection with the termination of the agreement.
Notwithstanding the above, personal data may also be saved after a customer relationship or e-signing process has ended if Invono has a legitimate interest in saving such data as evidence in an ongoing or anticipated dispute with the customer or to investigate a security issue. The data is then anonymized as far as possible and the storage is limited to a system to which authorization is limited to the person or persons who handle the dispute or the security issue.
Support regarding INVONO One and Invono's service for e-signing documents
In the event that the e-mail does not prompt any further action on the part of Invono, the e-mail will be deleted within a reasonable time after the e-mail was received by or sent from Invono. In the event that Invono processes the e-mail in a different way than by deleting it, it depends on the content of the e-mail as well as the continued processing and purposes of the same, how long the e-mail and the personal data in it will be saved. In the event that the e-mail comes from, or is sent to, a person (or indirectly a company) with whom Invono has a contractual relationship, the e-mail may be saved as long as the contractual relationship continues. If an e-mail containing personal data is to be saved for a slightly longer period of time, Invono will especially consider whether the personal data should be transferred to a system other than the e-mail system. In such event, the email shall be deleted within a reasonable time after such transmission.
Notwithstanding the above, personal data may also be saved if storage is required by applicable law or if Invono has a legitimate interest in saving such data as evidence in an ongoing or anticipated dispute. The data is then anonymized as far as possible and storage is limited to a system to which authorization is limited to the person or persons handling the dispute.
In the event that the e-mail does not prompt any further action on the part of Invono, the e-mail will be deleted within a reasonable time after the e-mail was received by or sent from Invono.
In the event that Invono processes the e-mail in a different way than by deleting it, it depends on the content of the e-mail as well as the continued processing and purposes of the same, how long the e-mail and the personal data in it will be saved. In the event that the e-mail comes from, or is sent to, a person (or indirectly a company) with whom Invono has a contractual relationship, the e-mail may be saved as long as the contractual relationship continues. If an e-mail containing personal data is to be saved for a slightly longer period of time, Invono will especially consider whether the personal data should be transferred to a system other than the e-mail system. In such event, the email shall be deleted within a reasonable time after such transmission.
Notwithstanding the above, personal data may also be saved if storage is required by applicable law or if Invono has a legitimate interest in saving such data as evidence in an ongoing or anticipated dispute. The data is then anonymized as far as possible and storage is limited to a system to which authorization is limited to the person or persons handling the dispute.
Your rights
You can at any time request that your personal data be corrected or deleted or that the processing concerning you be restricted. In some cases, you may also have the right to have your personal data moved (data portability). You can also get information free of charge, at least once a year, about which personal data Invono processes about you and get access to it.
You also have the right, at any time, to object to the personal data being used for direct marketing. Users also have the right to object to such processing of personal data that takes place in connection with support cases (refers to information about someone other than the person who contacted the support), for marketing purposes, for internal market research and as a basis for Invono's market and customer analyses, business and product development and statistics, if you consider that Invono has no legitimate interest in processing the personal data for such purposes.
Finally, you have the right to submit a complaint regarding Invono's processing of your personal data to the Swedish Data Protection Authority.
You can always contact Invono as below for more information about your rights.
Who does Invono share your personal data with?
Invono may be required to save certain data and in some cases provide data to authorities in accordance with the applicable law. Invono also engages certain collaboration partners and subcontractors both within and outside the EU/EEA, e.g. to store information on servers, manage the sending of newsletters and be able to provide support regarding INVONO One. These collaboration partners and subcontractors will receive such personal data that is necessary for them to be able to perform their tasks for Invono and their processing of personal data on Invono's behalf is regulated by personal data processing agreements between Invono and the respective collaboration partner/subcontractor. A complete overview of Invono's relevant collaboration partners/subcontractors – and the locations of their respective personal data processing – is included at the end of this policy.
As regards personal data provided when creating an account in INVONO One - and any changes/completions thereof - they can be used to enable companies that use INVONO One to link people to their company accounts in order to e.g. register them as shareholders, assign them certain authorization to the company's account or communicate certain information to them.
In addition to the possible situations mentioned above, Invono does not share personal data with third parties and Invono protects your personal data according to good standards and practices. You can read more about Invono's security measures in Invono's Data Security Description.
Information about the personal data controller
The personal data controller for processing your personal data as above is Invono AB, org. No. 556987-2335, with address Krapperupsvägen 343 13, 263 76 Nyhamnsläge.
Collaboration partners and subcontractors (subcontractors of Invono)*
Company | Place for processing personal data | Task | Third country transfer mechanism |
|---|---|---|---|
Google Commerce Limited | Germany | Storage of data in INVONO One on server | Not relevant (within the EU) |
Stripe Payments Europe, Ltd. | USA | Payment services | EU Standard Contractual Clauses (SCC) |
Help Scout | USA | Customer Support Platform | EU Standard Contractual Clauses (SCC) |
* Information about companies that have placed so-called third-party cookies on the Invonos website can be found in Invonos Cookie policy.