Integrity Policy

2. WHO IS RESPONSIBLE FOR PERSONAL DATA?

2.1 Zington has a corporate structure with a number of subsidiaries that fall under a parent company, where the parent company has a controlling influence over the group.

2.2 The parent company Zington AB, org. no. 556651-7131, with address Birger Jarlsgatan 9, 111 45 Stockholm, is responsible for the processing of your personal data when Zington provides and markets the group's services, recruits and administers staff, and in all other contacts between you and Zington where you provide personal data to us. This includes visits to our website, service matters via email and telephone, and contacts with companies within the Zington group. As the data controller, it is Zington AB's responsibility to ensure that your personal data is handled in a correct and secure manner in accordance with applicable legislation.

2.3 For GDPR-related questions, comments, and requests, you are welcome to contact Zington's GDPR officer at the email address dataskydd@zingtongroup.com, or the relevant subsidiary CEO at his personal email or phone number, or by calling our switchboard at phone number 08 - 406 68 00.

3. WHO WE COLLECT PERSONAL DATA FROM

3.1 We collect personal data about you in connection with your application for vacant positions or expressing your interest in employment, when you hire one of our employees, when you purchase or show interest in our services, when you register to participate in our events, when you sign up for our newsletter subscription service, when you respond to surveys and participate in studies, when Zington hires you as a supplier of products or services, or when you or we otherwise come into contact with each other in a context where Zington's business is of interest to you.

3.2 We collect personal data from:

• Yourself – Information that you provide when you contact us, for example, to apply for a job or register for one of our open events or other online participation.
• Reference persons for those applying for jobs with us.
• Suppliers or potential suppliers we want to contact, or who want to contact us.
• Customers or potential customers we want to contact, or who want to contact us.

3.3 As a visitor to our website, you do not need to provide any personal data to use it. Our website only collects personal data that is specifically and voluntarily provided by you. Such personal data may consist of, for example, name, address, current title, your employer, phone number, and email address. You can also find information about how we use cookies in Zington's cookie policy.

3.4 Zington sometimes collects personal data from minors when we organize code school for school students and also leadership courses for young sports leaders. The collection of personal data is then done with special care by the event managers and with transparency towards the concerned guardians. We do not publish photography or film from such an event with visible faces without the guardian's written consent.

4. WHAT PERSONAL DATA WE COLLECT

4.1 Zington is committed to personal privacy and only collects personal data that are necessary, relevant, and not excessive for the purpose they are intended for.

4.2 Regarding you who apply for vacant positions or express your interest in employment, we process relevant details such as name, contact information, CV, position, possible current employer, terms of employment, and dialogue history. Sensitive data in the form of health-related information may occur in rare cases.

4.3 Regarding you who want to register to participate in our events, want to subscribe to our newsletter service, or you who respond to surveys and participate in studies, we inform you in connection with your registration which personal data we collect and the purpose of this. You consent to the processing of your personal data by submitting your registration.

4.4 Regarding you who are - or may be about to become - a partner, supplier, or customer, we process relevant details such as name, position, company/organization, contact information, invoice information, purchase and delivery history, and dialogue history.

4.5 We generally recommend that you refrain from providing sensitive personal data. If you still provide such information, Zington considers this as you have given your consent to the registration of the data in the manner described in this policy and in accordance with the purpose specifically indicated in connection with the provision of the data. For example, if you indicate that you have allergies and request certain food in connection with an event.

5. PERSONAL DATA PROCESSED AND PURPOSE

5.1 If you, for example, apply for vacant positions, submit inquiries regarding employment with us, participate in surveys and studies, or indicate that you wish to be contacted by us, we use your personal data only for the purpose for which you have provided them. We do not use or share personal data in a way that is incompatible with the original purpose for which they were collected, unless subsequent consent has been obtained.

5.2 In connection with you ordering newsletters via our website, by phone, email, or letter, or registering for our events or requesting information about specific areas of interest, you are registered as an interested party to Zington. Information that you provide is recorded and used for the administration of ordered services and to personalize and improve our website. The data may also be used for communication regarding services that we believe may be of interest to you and follow-up for the development and improvement of Zington's services.

5.3 Our main purposes for processing your personal data are:

• to be able to perform activities within the company's regular operations, such as matching new assignments with available skills, preparing business-relevant documentation, and communicating with relevant parties;
• to accommodate your requests as well as we can and fulfill any agreements with you;
• to fulfill our employer responsibilities, accounting responsibilities, and our legal obligations in general;
• to establish or develop business relationships;
• to pay for your services performed;
• to invoice customers for our services performed;
• to be able to offer suitable food in connection with various open events organized by the company.

6. LEGAL BASIS FOR OUR PROCESSING

6.1 When you apply for vacant positions or express your interest in employment, when you hire one of our employees, when you purchase or show interest in our services, when you register to participate in our events, when you sign up for our newsletter subscription service, when you respond to surveys and participate in studies, when Zington hires you as a supplier of products or services, or when you or we otherwise come into contact with each other in a context where Zington's business is of interest to you, we process the personal data that you then provide us with based on the legal basis of Legitimate interest. The balancing of interests is then that we process your personal data within the framework of our business.

6.2 To the extent that we process your personal data in accordance with legal requirements (e.g., labor law and accounting responsibilities), we do so based on the legal basis of Legal obligation.

6.3 We process invoices to and from Zington based on the legal basis of Fulfillment of contract.

6.4 If we process sensitive data about you, we always do so based on the legal basis of Consent.

6.5 If the purpose is follow-up to develop and improve our services or if your employer is or has been a customer of Zington, we base such processing of your personal data on the legal basis of Legitimate interest. The balancing of interests is then that we process your personal data within the framework of our business.

7. STORAGE

7.1 We save your personal data for as long as it is necessary to assess your job application, perform our services according to the contract, and send invitations to events or newsletters.

7.2 We retain suppliers' and customers' personal data as long as it is necessary for us to fulfill our commitment, and as long as it is otherwise commercially reasonable.

7.3 Zington will take reasonable measures to preserve personal data only as long as required for the purposes for which they were collected.

7.4 If you have consented to your contact details remaining in our client register for marketing purposes even after the customer relationship has ended, they will remain until you wish the data to be removed.

8. TRANSFER OF PERSONAL DATA

8.1 As a company belonging to a global group of companies, VASS Group, Zington manages the transfer of users' personal data, both internally and with specific third parties. This transfer of information includes companies within its corporate group, external service providers, other external parties and is done in situations related to business transactions and legal requirements.

Users' personal data is shared with third parties in the following circumstances:

8.2 Companies of the same corporate group as Zington. The treatment by the VASS Group of the data of the companies of its group is carried out in accordance with its privacy policy.

8.3 Collaboration with External Service Providers: Zington shares data with external entities to respond to requests, answer queries, fulfil orders, validate coupons, offer samples, facilitate participation in sweepstakes and enable various functionalities through its web platforms. These providers perform tasks on behalf of Zington, such as hosting or operating its websites, payment processing, data analysis, customer service, postal or delivery services, as well as handling promotions. Although they access personal data necessary for their tasks, they are not authorised to use it for other purposes. They must comply with the guidelines in this Privacy Notice and with applicable data protection laws and regulations.

8.4 Relationship with Other Third Parties: User data is used or shared by Zington with sponsors, advertisers, ad networks, ad servers, social networks, analytics companies and other third parties in activities related to marketing, promotions, data enrichment and disclosure of product information.

8.5 Commercial Transfers: Zington may use or share user data within the VASS Group for commercial and operational purposes. In the course of its business, Zington may acquire or sell assets, subsidiaries or business units. In these transactions, users' personal data are usually considered transferable assets, although they remain subject to the terms previously set out in existing Privacy Notices, unless users give their explicit consent.

8.6 Disclosure for Legal Requirements: Zington may transfer and disclose users' personal data to third parties:

• To comply with legal obligations.
• When it believes in good faith that an applicable law requires it.
• At the request of governmental authorities in ongoing investigations.
• To verify or enforce compliance with the "Terms of Use" or other relevant policies.
• To detect and protect against fraud, technical or security vulnerabilities.
• To respond to emergency situations; or
• To protect the rights, property, safety or security of third parties, visitors to the Zington website, Zington or the general public.

8.7 In Zington's core business as an IT consulting company, it includes matching assignments against suitable candidates among the group's employed consultants, whereby Zington processes the candidate's personal data, e.g., by sending their CV to a customer or potential customer.

8.8 Within the framework of our other operations, we normally process personal data when we handle salaries, HR issues, event planning, marketing, etc., by using business systems, recruitment systems, CRM, and IT support companies owned and operated by external parties. Therefore, to be able to perform, deliver, and invoice Zington's services, personal data mainly belonging to our employees, customers, and suppliers need to be transferred to an external party in this way.

8.9 To ensure that the personal data is handled correctly according to applicable regulations and Zington's responsibility towards you as the owner of the personal data in question, we have data processing agreements with the external parties with whom we have established business contact and who handle personal data on Zington's behalf in accordance with points 8.7 and 8.8.

8.10 In Zington's choice of suppliers who process personal data on our behalf, we primarily choose suppliers within the EU/EEA, secondarily suppliers who guarantee that they process personal data securely even if they have subcontractors outside the EU/EEA. Zington uses NAB Solutions as a business system, Visma Addo for digital signing, and Linkedin, Instagram, Facebook, and Rule for publishing.

8.11 Zington may, upon request from an authority, share or continue to process your personal data in response to a legal request (such as a search warrant, court order, subpoena, or similar), or when we believe it is necessary to detect, prevent, and address fraud and other illegal activity, to protect ourselves, you, and other users. Zington's GDPR officer always responds together with Zington Group's CEO for such a decision.

9. SECURITY

9.1 The personal data provided to any company within the Zington Group is processed in accordance with the legislation in force at any given time and in accordance with Zington's internal guidelines, policies, and procedures for the processing of personal data.

9.2 To protect your personal data against improper access, processing, deletion, or alteration, Zington has taken appropriate organizational and technical security measures. These security measures are commensurate with the amount and sensitivity of the personal data.

9.3 Zington's organization, internal procedures, and processes follow the GDPR. We have data processing agreements with instructions on how relevant external parties with whom we have established business collaborations should process personal data on Zington's behalf. Zington has an appointed GDPR officer, and we have procedures for regularly reviewing our organizational and technical security needs.

9.4 Technical security measures that Zington uses include managed firewalls, network separation, access control in the systems used, and entry control to our office premises.

10. YOUR RIGHTS

10.1 Access to your personal data

You have the right to obtain confirmation from Zington that your personal data is being processed by us, and to access the personal data in question. Contact our GDPR officer if you want a registry extract, or have any other questions of such kind.

10.2 Correction of personal data

If you believe that a piece of information about you is incorrect or incomplete, you have the right to request that the information be corrected or supplemented. Please notify our GDPR officer if there has been any change in your personal data that is good for us to know.

10.3 Delete data

You have the right to have your personal data - all or some according to your wishes - deleted, provided that it does not conflict with legislation or current agreements with you. Contact our GDPR officer if you want personal data deleted, which personal data it concerns, and preferably also what the reason is.

10.4 Limited processing of data

It is Zington's responsibility to limit the processing of your personal data, i.e., that your personal data should not appear in more places than is reasonable with regard to Zington's operations and a reasonable administrative burden for our employees. Let us know if you do not think we are meeting this in terms of your personal data, or if you have suggestions on how we can improve our processing in any respect to the benefit of your privacy.

10.5 Give and withdraw your consent

In some cases, we will ask for your approval/consent to process your personal data. You then have the right to notify our GDPR officer or your closest contact at Zington at any time that you want to withdraw your Consent, and then we will not continue the processing. If you have withdrawn consent, we will only continue to process the personal data required to fulfill contracts or other legal obligations and any other personal data that you have consented to us processing.

10.6 Oppose processing based on our legitimate interest

In some cases, Zington has determined that our need to process your personal data is so strong that we have a so-called legitimate interest. You have the right to object to our assessment of legitimate interest/balancing of interests at any time for reasons related to your situation. If we cannot show compelling reasons, we will stop processing these of your personal data in that way.

10.7 Direct marketing

You can opt-out of communication mailings from Zington, both digital and in paper format, at any time.

10.8 Data portability

If the processing is based on consent or fulfillment of a contract, you have the right to data portability. This means that you have the right to receive the personal data that you have provided to us and to transfer this data to another data controller organization. This should then be done in a way that is structured and commonly used, and in a machine-readable format. Unlike a registry extract (see above), this only includes some of the data that you have provided to us, e.g., your CV and material that you own the copyright to.

10.9 Automated decision-making

You have the right not to be subject to fully automated decision-making, including profiling, if such decision-making has legal consequences or similarly significantly affects you. Zington does not use automated decision-making in external contacts.

11. EXERCISING YOUR RIGHTS

11.1 To exercise your rights, if you have questions, or if you want to complain about our processing of your personal data, or if you want to make suggestions to Zington regarding privacy protection or data security, please feel free to contact us. Please provide your full name, contact details, and the information Zington needs to be able to process your request. Our contact details are:

Zington AB (org. no. 556651-7131) Birger Jarlsgatan 9 111 45 Stockholm Phone: 08 – 406 68 00 Email: dataskydd@zingtongroup.com

11.2 You also have the right and opportunity to file complaints regarding our processing of your personal data to the Data Inspection Board http://www.datainspektionen.se .

12. CHANGES

12.1 Zington reserves the right to supplement and adjust this policy at any time.

12.2 The latest version of this policy should always be available on Zington's website.

Cookie Policy