Introduction
Within the scope of our operations, Brilliant Future AB processes a range of personal data that you have provided to them yourself or that they have obtained from someone else (so-called third parties). Your personal data is processed e.g., in connection with the provision of digital services, our events and webinars and recruitment processes. Because we protect your personal privacy and take questions about data protection very seriously, we want to describe in this privacy policy how Brilliant Future AB processes your personal data.
In the Policy, we will therefore explain which categories of personal data Brilliant Future AB processes, for which purposes we process them and which legal basis the processing is based on. We also explain who can have access to and process the data, the principles for thinning, which third parties Brilliant Future AB may share the personal data with, where the personal data is processed and your rights as a registered person in the form of the right to information, correction and deletion, etc. We ask you to read the Policy carefully and familiarize yourself with its content, as it is applied to all processing of personal data within Brilliant Future AB.
Brilliant Future AB processes your personal data as a data controller and therefore has an obligation to ensure that the processing takes place in accordance with this Policy and the personal data legislation in force at any time. As a registered user, you always have the right to contact Brilliant Future AB to enforce your rights.
It may happen that we sometimes need to update or change the Policy. If this happens, we will inform you in an appropriate way and ask you to take note of the changes made. You can always find the latest version of the Policy on our website.
We hope this Policy answers your questions about our collection, use and disclosure and the protection of your personal data.
If you have further questions or concerns, you are most welcome to contact us dpo@brilliantfuture.se
Personal data and personal data processing
By “personal data” is meant any kind of information that can be directly or indirectly attributed to a natural person who is alive. This may therefore involve information such as names, e-mail addresses or telephone numbers, but also information such as photos or IP addresses may be covered if the information can be linked to a natural person. “Personal data processing” refers to any action or combination of actions concerning personal data, regardless of whether the action is automated or not. Examples of common treatments are collection, registration, organization, structuring, storage, disclosure through transfer and deletion.
Expressions of interest via the website
Establishing and maintaining business relationships with customers and other stakeholders in order to develop Brilliant Future AB’s services, products and systems is an important part of Brilliant Future AB’s core business. In order to be able to contact you as an interested party regarding Brilliant Future AB’s services and products as well as market activities, the company collects your personal data. This personal data is collected from you in connection with your registration of interest via Brilliant Future AB’s website. The data will be stored in Brilliant Future AB’s market tool with the goal that the company will be able to establish a business relationship with you.
Your personal data is also saved on Brilliant Future AB’s platforms for marketing mailings for communication and information purposes. Brilliant Future AB will only make such mailings that Brilliant Future AB deems relevant to your professional role. For each mailing, you will be given the opportunity to deregister, a so-called opt-out.
Brilliant Future AB will process your personal data until it is no longer needed to fulfill the above-mentioned purposes or until you request to no longer be registered with Brilliant Future AB. In such a case, the personal data will be deleted without undue delay. If a business relationship has not developed within three years from when Brilliant Future AB received your notification of interest, your personal data will be deleted. Brilliant Future AB has also established thinning routines in order to be able to regularly delete contact information that no longer fulfills its purpose.
THE PERSONAL DATA COLLECTED AND PROCESSED FOR THE PURPOSES MENTIONED ABOVE ARE:
- First and last name
- Contact details such as email address and phone number
- Correspondence between you and Brilliant Future AB
- Technical information about how you have interacted with Brilliant Future AB’s IP address and browser settings
The processing of this personal data is based on the consent you give in connection with submitting your expression of interest.
Seminars and trainings
In order to be able to provide seminars and trainings, register the number of participants, print the necessary documentation and to be able to send marketing mailings, Brilliant Future AB has a need to process the participants’ personal data.
The processing of your personal data is based on Brilliant Future AB’s legitimate interest in being able to draw up participant lists, etc. and otherwise administer the seminars and trainings you have registered for. It is also in your employer’s interest that you participate in the training courses you have shown interest in. Your personal data included in a participant list may be transferred to external lecturers who teach the training and to contracted printing companies. This takes place for preparatory purposes, such as printing teaching materials, certificates and diplomas.
Your personal data will be processed by Brilliant Future AB during the relevant training and for one year thereafter for marketing purposes. However, Brilliant Future AB’s processing of the personal data will end earlier if you explicitly request it.
THE PERSONAL DATA BRILLIANT FUTURE ABS PROCESSES FOR THE PURPOSES MENTIONED ABOVE ARE:
- First and last name
- Contact details such as e-mail address, telephone number, workplace address and professional title
- Billing information
- Notes for educational opportunities
- Data on dietary preference
This information is collected either from you as a participant or from the customer’s contact person who manages registrations and coordination with Brilliant Future AB before each training session.
For customers or users of Brilliant’s digital services
In cases where Brilliant provides digital services, such as customer and employee surveys, the company assumes a position as a personal data processor. This is because the customer, when using these services, provides the companies with personal data and decides for which purposes they may be processed. Brilliant Future AB’s position as personal data processor means in these cases that it is the customer who is responsible for the processing of users’ personal data and that it is the customer’s privacy policy or corresponding information document that is applied to the users. If you have used a digital service in your work or participated in a customer or employee survey and want to find out what personal data Brilliant processes about you, please contact the customer or your employer who is responsible for the processing of your personal data. It is only after instructions from the responsible customer or employer that Brilliant may release the personal data to you.
Processing of social security numbers
To the extent that Brilliant Future AB processes social security numbers without your consent, this will only be done when it is clearly justified with regard to the purpose, which is secure identification, background checks or any other considerable reason. This means that social security numbers as a starting point will only be processed during background checks or in cases where a customer’s business is conducted in the form of a sole proprietorship. As a candidate in our recruitment processes, you should therefore not state your social security number in your resume or application.
Direct marketing
You have the right to object to your personal data being used for direct marketing. Direct marketing refers to all types of outreach marketing measures, e.g., via post, e-mail and SMS. You have the right to object, free of charge, to your data being used for such purposes and every mailing from Brilliant Future AB for marketing purposes contains an opportunity to deregister, so-called. opt-out. If you choose to unsubscribe from further mailings, Brilliant Future AB will make a note in its business system to cease direct marketing to you.
Contact person at potential customer
Establishing business relationships with customers in order to develop Brilliant Future AB’s services, products and systems is an important part of Brilliant Future AB’s core business. In order to be able to contact you as a potential customer contact regarding Brilliant Future AB’s services and products as well as market activities, Brilliant Future AB collects your personal data. These are either collected via internal networks or from third parties, such as public registers or social media, and are stored in Brilliant Future AB’s system with the aim of being able to establish a business relationship with you and to be able to invite you to market activities. The processing of this personal data is based on Brilliant Future AB’s legitimate interest in being able to establish and maintain business relationships and to be able to develop its services, products and systems.
Brilliant Future AB has as a matter of routine that every employee who initiates contact with you via telephone or digital channel and where you have shown an interest in creating or exploring a further relationship with Brilliant Future AB during the conversation, follows up with an e-mail message containing a link to this Policy. In cases where Brilliant Future AB initiates the first contact through an e-mail message or printed material, a reference to the Policy is always included so that you, as a registered user, will receive the necessary information about the processing of your personal data. Your personal data is saved on Brilliant Future AB’s platforms for marketing mailings for communication and information purposes.
Brilliant Future AB will only make mailings that are deemed relevant to your professional role. For each mailing, you will be given the opportunity to deregister, a so-called opt-out. In cases where Brilliant Future AB has contacted you and you decline to create or explore a further relationship, the personal data in Brilliant Future AB’s part of the business system will be marked with a note not to resume contact. We will also stop sending you marketing mailings.
Brilliant Future AB will process your personal data until it is no longer needed to fulfill the above-mentioned purposes or until you request to no longer be registered with Brilliant Future AB. In such a case, the personal data will be deleted without undue delay. If a business relationship has not developed within a year from the time Brilliant Future AB made the first contact, your personal data will be deleted. Brilliant Future AB has also established thinning routines in order to be able to regularly delete contact information that no longer fulfills its purpose.
THE PERSONAL DATA BRILLIANT FUTURE ABS MAY COLLECT AND PROCESS FOR THE PURPOSES MENTIONED ABOVE ARE:
- First and last name
- Contact details such as e-mail address, telephone number, professional title
- Correspondence between you and Brilliant Future AB
- Technical information about how you have interacted with Brilliant Future AB
- IP address and browser settings
- Data on dietary preference (in connection with lectures, events, etc.)
Contact person at existing customer
Maintaining business relationships with customers in order to develop Brilliant Future AB’s services, products and systems is an important part of Brilliant Future AB’s core business. In order to be able to maintain contact with you as a customer regarding Brilliant Future AB’s services and products as well as marketing activities, Brilliant Future AB processes your personal data. These are either collected via internal networks or from third parties, such as public registers or social media, and are stored in Brilliant Future AB’s system with the aim of being able to maintain a business relationship with you and to be able to invite you to marketing activities. The processing of this personal data is based on Brilliant Future AB’s legitimate interest in developing the business relationship with you and for Brilliant Future AB to be able to communicate with you as a contact person. Your personal data is saved on Brilliant Future AB’s platforms for marketing mailings for communication and information purposes. Brilliant Future AB will only make mailings that are deemed relevant to your professional role. For each mailing, you will be given the opportunity to deregister, a so-called opt-out.
Brilliant Future AB will not process your contact details longer than is necessary for the above-mentioned purposes. Personal data that has become out of date, e.g. due to retirement or terminated business relationship, is deleted without undue delay as soon as Brilliant Future AB receives information about this. The data will also be deleted without undue delay at your express request. Brilliant Future AB has also established thinning routines to be able to regularly delete such contact details that no longer fulfill their purpose.
THE PERSONAL DATA BRILLIANT FUTURE ABS MAY COLLECT AND PROCESS FOR THE PURPOSES MENTIONED ABOVE ARE:
- First and last name
- Contact details such as e-mail address, telephone number, professional title
- Correspondence between you and Brilliant Future AB
- Technical information about how you have interacted with Brilliant Future AB
- IP address and browser settings
- Data on dietary preference (in connection with lectures, events, etc.)
Potential candidates
In order to be able to contact you as a potential candidate regarding relevant career opportunities and professional communication, Brilliant Future collects personal data both through internal networks and external searches with third parties and processes them in Brilliant Future candidate system.
The personal data is stored in Brilliant Future candidate system in order to be able to create a relationship between you and Brilliant Future with the goal that the contact will turn into a recruitment process.
If, when contacting an employee of ours, you state that you are not interested in a further dialogue with Brilliant Future, Brilliant Future will no longer process your personal data in its candidate system.
THE PERSONAL DATA THAT BRILLIANT FUTURE COLLECTS AND PROCESSES FOR THE PURPOSES MENTIONED ABOVE ARE:
- First and last name
- Contact details such as e-mail address, telephone number, professional title and home address
- Third party candidate profile URLs
- Competency-based fitness for duty
- Data posted in social media, e.g., LinkedIn, and which are deemed to be relevant and of essential importance to assess your professional qualifications
- Photography
Candidates who have agreed to be included in our networks
In order to be able to contact or convey career offers to candidates who have consented to being stored in Brilliant Future candidate database and to be able to maintain a relationship with these candidates, Brilliant Future processes the candidates’ personal data. Brilliant Future has collected the personal data from you as a candidate, through Brilliant Future internal network and/or through searches with third parties.
In addition to dietary preference (in connection with lectures, events, etc.), Brilliant Future AB will not actively collect or process sensitive personal data (such as information about trade union membership, political opinions, sexual orientation or religious beliefs) or information that is not relevant for recruitment. It is therefore important that you as a candidate do not provide information such as sensitive personal data or information that is not relevant to the positions you are applying for. It is also important that you inform any references that their personal data has been provided to Brilliant Future. The processing that takes place in Brilliant Future database in order to carry out recruitment processes takes place with the support of your consent.
Brilliant Future will save your personal data for future career opportunities. You can at any time send an email to dpo@brilliantfuture.se to withdraw your consent.
However, information that is relevant to an individual recruitment process such as interview notes and information from references is only saved as long as it is necessary for the process in question and then for up to two years after the end of the recruitment process. This is done so that Brilliant Future AB can exercise its right in the event of a possible discrimination dispute. Brilliant Future AB also regularly refines its candidate system so that it fulfills its purpose and is kept up to date.
THE PERSONAL DATA BRILLIANT FUTURE MAY PROCESS FOR ABOVE-MENTIONED PURPOSES IN THE BRILLIANT FUTURE DATABASE ARE:
- First and last name
- Contact details such as e-mail address, telephone number, professional title and home address
- Data posted in social media, e.g., LinkedIn, and which are deemed to be relevant and of essential importance to assess your professional qualifications.
- IP address and browser settings
- URLs
- Sex
- Year of birth
- Competency-based fitness for duty
- Interview notes
- Test results from test tools used in selection and development work
- References provided
- Correspondence between you and us
- Information about how you have interacted with us
- Data on dietary preference (in connection with lectures, events, etc.
Reference persons
In order to be able to carry out well-founded recruitment processes, Brilliant Future will process personal data for you as a reference provided by the candidate.
The processing of references’ personal data is based on Brilliant Future legitimate interest in being able to contact provided references in order to carry out as thorough and well-founded recruitments as possible.
It is routine for Brilliant Future to send out this Policy at the first contact with you as a reference so that you can learn how your personal data is processed.
The protection of your personal data
Brilliant Future AB has taken a series of security measures to ensure that Brilliant Future AB’s processing of personal data takes place in a secure manner and to protect the personal data that is processed against illegal access, unauthorized processing and abuse. For example. access to the systems in which the personal data is stored is limited to Brilliant Future AB’s employees and service providers who need to access the data within the scope of their duties. These are also informed of the importance of maintaining the security of personal data and internal routines have been established which, among other things, regulates the use of passwords and work that takes place outside the office and abroad. Brilliant Future AB also continuously monitors its systems to detect vulnerabilities and to protect your personal data.
Use of personal data assistants
In cases where it is necessary for Brilliant Future to be able to offer its services, it will transfer your personal data to companies that, in relation to Brilliant Future, are so-called personal data processors. These may only process the transmitted data on behalf of Brilliant Future and in accordance with Brilliant Future express instructions. Brilliant Future only transfers your personal data to such personal data processors for purposes that are compatible with the purposes for which Brilliant Future has collected the data. Brilliant Future has entered into written agreements with all personal data processors to ensure that they comply with Brilliant Future security requirements, restrictions and requirements regarding the international transfer of personal data.
The place for processing personal data
Brilliant Future AB aims to always process your personal data within the EU/EEA where all Brilliant Future AB’s own IT systems are located. However, it may happen that your personal data is shared with personal data assistants who either themselves or through subcontractors are established or store information in a country outside the EU/EEA. In such case, Brilliant Future AB will take all reasonable legal, organizational and technical measures required to ensure that the level of protection is the same as within the EU/EEA. This will take place either through a decision by the European Commission that the country in question ensures an adequate level of protection or through the use of appropriate protective measures such as standard contract clauses or approved codes of conduct in Brilliant Future AB’s agreement with such personal data assistants.
Your rights as a registered user
As a registered user, you always have the right to assert your rights against Brilliant Future AB by contacting us via dpo@brilliantfuture.se.
The right of access
If you want to gain a better understanding of which personal data we process about you, you can request access to the data. The information will be provided in the form of a register extract that indicates which personal data we process, for which purposes we process it, where the data has been obtained from, which third parties the data has been transferred to and how long the data will be stored. If your request is made in electronic form, the information will be provided in a commonly used electronic format, unless you request otherwise.
The right to rectification
You have the right to have incorrect information about you corrected without delay. You also have the right to complete incomplete information, e.g., by providing a supplementary statement.
The right to erasure
You have the right to request the deletion of your personal data that we process about you if:
- The personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
- You withdraw your consent for processing based on consent and there is no other legal basis for the processing.
- You object to processing based on a balance of interests and your reason for objecting outweighs our legitimate interest
- The personal data is processed in an illegal manner.
- The personal data must be deleted as a result of a legal obligation that we have to fulfill.
If there are legal obligations that prevent us from immediately deleting certain personal data, we may deny your request for deletion. These obligations exist, e.g. in the accounting legislation. It is also possible that continued processing is necessary for us to assert, defend or establish legal claims. Should it be the case that our legal obligations prevent us from deleting your data, we will instead mark it so that it is no longer actively used in our systems.
In addition to the above rights, you also have the right to request that the processing of your personal data be limited and to object to any processing of personal data based on a balancing of interests. If this happens, we must demonstrate compelling legitimate reasons that outweigh your interests, rights and freedoms in order to continue the processing. In cases where our processing of personal data is based on your consent, you also have the right to request that the data that concerns you and that you have provided be transferred to another personal data controller (so-called data portability). However, a prerequisite for data portability is that the transfer is technically possible and that it can take place automatically.
The right to restriction of processing
You have the right to request that the processing of your personal data be restricted if one of the following options is applicable:
- You dispute the correctness of the personal data for a period of time that gives Brilliant Future AB the opportunity to check whether the data is correct;
- The processing is illegal and you object to the deletion of the data and instead request a limitation of their use;
- Brilliant Future AB no longer needs the personal data for the purposes of the processing, but you need them to be able to establish, assert or defend legal claims;
- You have objected to treatment based on a balance of interests, and Brilliant Future AB checks whether the company’s legitimate reasons outweigh your legitimate reasons.
If the processing has been restricted in accordance with this point, such personal data for which the restriction of processing shall take place, with the exception of storage, may only be processed to establish, assert or defend legal claims or to protect the rights of third parties or reasons relating to an important public interest for the EU or for an EU member state.
The right to data portability
In cases where Brilliant Future AB’s processing of personal data is based on your consent or fulfillment of an agreement, you have the right to request that the data concerning you and which you have provided to Brilliant Future AB be transferred to another personal data controller. A prerequisite for this, however, is that the transfer is technically possible and that it can take place automatically Such personal data for which limitation of processing must take place, except for storage, is only processed to establish, assert or defend legal claims or to protect third parties rights or reasons relating to an important public interest for the EU or for an EU member state.
Withdrawal of consent
In cases where Brilliant Future AB’s processing of your personal data is based on your consent, you always have the right to withdraw your consent at any time. A withdrawal does not affect the legality of the processing that took place based on your consent before this was withdrawn. If you withdraw your consent, Brilliant Future AB will no longer process the personal data based on your consent, unless Brilliant Future AB is obliged for legal reasons to continue processing them. Should it be that Brilliant Future AB’s legal obligations prevent Brilliant Future AB from deleting your data, Brilliant Future AB will instead mark it so that it is no longer actively used in Brilliant Future AB’s system.
You can at any time send an email to dpo@brilliantfuture.se to withdraw your consent. Brilliant Future AB will respond to your request promptly.
Submission of complaints
The Privacy Authority is the authority responsible for monitoring the application of legislation among companies that process personal data. If you believe that we or Brilliant Future AB are processing your personal data incorrectly, you can, in addition to contacting us via dpo@brilliantfuture.se to submit a complaint to the Swedish Privacy Authority.
The use of cookies, tags and pixels
Brilliant Future AB’s website uses cookies, tags and pixels to improve your website search, as well as Brilliant Future AB’s website. A cookie is a text file sent from Brilliant Future AB’s web server and saved on your browser or device. Brilliant Future AB also uses cookies for overall analytical information regarding your use of Brilliant Future AB’s services, to save functional settings and to be able to direct relevant marketing to you. You can change the settings in your browser for the use and extent of cookies. Examples of such adjustments are blocking all cookies or deleting cookies when you close your browser. You can read more in our digital communication policy.
If you have any further questions about Brilliant’s attitude to GDPR, feel free to contact us at dpo@brilliantfuture.se