Privacy notice in respect of General Meeting and shareholders 2024

Download Privacy notice in respect of General Meeting and shareholders 2024

OEM’s privacy notice in respect of General Meeting and shareholders

Updated April 2020

To whom is this privacy notice directed and what does it cover?

This privacy notice applies to individual shareholders of OEM International AB (“the Company”)), which is holding a general meeting of shareholders (““General Meeting”) ), as well as any other individuals attending or otherwise connected to such meeting (“you” or “your”).

This privacy notice explains what types of personal data are gathered about you, how the personal data is used and with whom the data is shared. It also describes your rights in relation to your personal data.

Who controls your personal data?

The Company is the controller of the processing of your personal data performed by the Company at the General Meeting.

Personal data and how it is processed

What personal data does the Company process and why?

During the General Meeting, during the preparations for the General Meeting and in the work after the General Meeting, the Company may process the following personal data:

• Contact details (e.g. name, title, address, telephone number and email);
• Identification details (e.g. date of birth and personal ID number);
• Financial information (e.g. voting rights at General Meeting, information regarding shareholdings and rights entitlements connected to the holdings);
• If the shareholder is represented by a proxy, information about who you represent or are represented by (as applicable); and
• Information on how you voted may be processed, e.g. if voting devices are used or vote counting is carried out, and to the extent that your votes can be connected to you based on the number of votes (e.g. if the number of votes corresponds to the number of shares held by you).

  The Company’s purpose for collecting and processing your personal data is to carry out the General Meeting and provide services in connection therewith, as well as to comply with applicable laws and regulations.

  What is the Company’s lawful basis for the processing of your personal data?

  The Company processes your personal data as follows:

• In order to fulfil the Company’s legal obligations under legislation in force; or
• It is in the Company’s legitimate interests to do so in order to, e.g., maintain adequate security and order during the General Meeting, and this interest is not overridden by your interests or fundamental right to protection against the processing of your personal data.

How long does the Company keep the personal data?

Personal data related to the General Meeting is kept for as long as necessary given the purpose of the processing, unless otherwise required under legislation in force.

Personal data regarding attendance at the General Meeting, shareholding, voting, etc. which is processed to carry out and document the General Meeting in accordance with applicable legislation is normally kept for one year after the General Meeting, unless a longer storage period is justified based on the resolutions adopted at the General Meeting or otherwise.

Where does your personal data come from?

The personal data the Company collects about you comes from the following sources:

• Personal data you give to the Company

  The Company collects personal data you give to the Company, e.g. when you:

  • send the Company personal data via forms, e-forms or email;
  • give the Company personal data over the phone; or
  • give the Company personal data during the General Meeting.

   

• Personal data the Company receives from other sources

  The Company may receive your personal data through:

  • information from the Company;
  • information received from public records;
  • information received from other service providers in connection with the General Meeting (such as e.g. Euroclear or legal representatives); or
  • the shareholder you represent or your proxy (as applicable).

  With whom may the Company share your personal data?

  Transfers within the Group or to a third party

• The Company may transfer your personal data to other companies or business partners in connection with the General Meeting. The Company only allows access to personal data to staff members who have a legitimate interest in the service and are contractually prohibited from using the personal data for any other purposes.
• The Company may disclose personal data to authorities, courts or other third parties, including, but not limited to, the Police, the Swedish Financial Supervisory Authority and the Swedish Tax Agency, if the Company deems the disclosure of personal data to be necessary (i) to ensure compliance with applicable legislation, or (ii) to exercise, establish or defend the legal rights of the Company or its representative.
• The Company may disclose personal data to third party vendors and partners who provide services to the Company (e.g. consultants working on the General Meeting, solicitors or security personnel), who are or will be involved in providing services to the General Meeting or who otherwise process personal data for the purposes described in this Privacy Notice or as notified to you when the Company collects your personal data.
• We may disclose personal data to our auditors, advisors or legal representatives and similar agents as necessary in connection with the services they provide, and subject to contractual prohibitions on using the personal data for any other purposes.

International transfers of personal data

The Company has third-party vendors and consultants who from time to time may conduct operations worldwide. This means that the Company may process personal data outside the European Economic Area (EEA) in jurisdictions with inadequate levels of protection for the processing of personal data. The Company has imposed appropriate safeguards through contractual obligations in order to ensure that your personal data remains protected in accordance with this privacy notice. These measures include, where applicable, implementation of contractual clauses in accordance with EU standard with the Company’s third-party vendors (these clauses are available at https://ec.europa.eu/info/law/law-topic/data-protection/data- transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en ).

What are your rights in respect of your personal data?

The Company has published this privacy notice to keep you informed of what the Company does with your personal data. The Company strives to be transparent about how the Company uses your personal data.

You have the right to access your personal data. You have the right to receive a copy of your personal data processed by the Company.

If your personal data kept by the Company is inaccurate, incomplete or not up to date, you have the right to have your personal data rectified or updated. If such personal data has been disclosed to a third party in accordance with this privacy notice, the Company must also ask them to rectify or update your personal data.

You have the right to request that the Company erase your personal data and if the Company does not have a lawful basis to hold or continue to process the data, the data will be erased.

You have the right to object to certain processing of your personal data by the Company.

In some cases, you have the right to request that the Company restrict the processing of your personal data. This means that we are permitted to store the data but not to process it further.

In some cases, the Company allows you to obtain the personal data we hold about you in a structured, commonly used and machine-readable format and to transfer those personal data to another controller without hindrance.

You have the right to lodge a complaint with your local supervisory authority about the Company’s collection and use of your personal data if you believe that the Company’s handling of a problem or complaint has been inadequate. Contact details for the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten): www.imy.se/en/.

Please contact the Company if you wish to exercise any of your rights as described above, using the contact details stated in the Notice of the General Meeting.

Data security and quality

The ensure the security of your personal data, the Company has implemented a number of security measures, including:

• Secure operating environments – The Company uses Euroclear for the storage of your data in secure operating environments and only Euroclear employees, representatives or contractors have access to the data on a need-to-know basis. Euroclear also follows generally accepted industry standards in this respect.
• Encryption – Euroclear uses industry standard encryption to protect information that is transferred digitally.
• Authentication for IT access and access to premises – The Company and Euroclear require staff and consultants to verify their identity (e.g. through login-ID, password, PIN codes and badges) before they can access IT environments and business premises. The aim is to prevent unauthorised access to personal data.

What if you choose not to give the Company your personal data?

If you do not want to give the Company your personal data and the personal data is necessary in order to (i) admit you as an attendee to a General Meeting; or (ii) provide you with further information on the processing by the Company, the Company will not be able to admit you to the General Meeting or give you the requested information.

Updating this privacy notice

The Company may update this privacy notice from time to time to comply with changes to legal, technical or business requirements. You can see when it was last updated by checking the date at the top of the privacy notice. Please note that the version available on the website oem.se shall be considered to be the latest version.

Any questions or concerns? Contact us!

If you have any comments on this policy, you can contact the data controller through CFO Johan Broman by email on [email protected] or by post to Johan Broman, OEM International AB, PO Box 1009, SE-573 28 Tranås, Sweden.