1. Who we are
The company responsible for processing your personal data is Kull Leadership AB, a Swedish company registered by the Swedish Company Registration Office, registration number 556511-6133, with registered office in Gothenburg, Sweden.
When we use “we”, “us” and “our” in this Privacy Policy we mean Kull Leadership AB.
This Privacy Policy does not apply to third parties to whom you provide your personal data.

2. Personal data we collect and use
We need to process your personal data in different situations, such as to enable us to perform under a contract, to meet our legal obligations or to pursue our legitimate interests. We process the following information for the purposes listed below:

2.1 Providing and invoicing for our products and services
To enable us to provide our products and services we need to process your personal data. The personal data we process for this purpose consists of your name, address, email, telephone number, employer, product/service specification, shipping address, billing information and other payment information (such as credit card numbers).
We process this personal data to perform under our contract with you. We will keep the data for as long as it is necessary for us to fulfil our purpose.

2.2 Hosting and publishing information regarding our events
We sometimes host and participate in different events (such as presentations, social events, courses, workshops, seminars etc.) where we process your personal data. The personal data we process for this purpose consists of your name, title, employer and recordings (e.g. sound, picture and videos). We process this personal data under our legitimate interest. Our legitimate interest is to be able to communicate and publish information on our events to participants and other interested parties.

We inform participants, the organizers and the client prior to doing any recordings. The information for hosting the events will be kept until no longer needed. Any personal information we communicate or publish will be kept for as long as we deem it’s interesting for the intended audience.

2.3 Optimizing our e-commerce website (using Cookies)
If you visit our e-commerce website www.courageous-leader.com we will process your personal data to load the website accurately and to analyze your use to optimize the website. This is done by placing cookies on your device. A cookie is a small amount of information that’s downloaded to your computer or device when you visit our website.

We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. For more information on the cookies used and the retention periods, please see: https://www.shopify.com/legal/cookies.

The personal data we process consists of your version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the website. We process your personal data based on your consent. We will keep the data for as long as it is necessary for us to fulfil our purpose.

2.4 Communicate with you
We will communicate with you for example to invite you to events, to share news and other information related to our business, to respond to questions, to provide quotes, to be able to properly deliver and plan for the provision of services to you.
The personal data we process consists of your name, address, email, telephone and other relevant information shared between us.

We will process your personal data based on our legitimate interest. Our legitimate interest is to be able to communicate with you and for you to be able to communicate with us. We will keep the data for as long as it is necessary for us to fulfil our purpose.

2.5 Comply with our legal obligations
We will process your personal data to comply with applicable law, such as tax and accounting laws. The personal data we process consists of payment and billing information such as your name, address, email, telephone number, purchase specification, shipping address, billing information and other payment information. We will process your personal data based on our legal obligations. We will keep the data for as long as necessary to fulfil the legal obligations, for example during the
current year and another 7 years according to the Swedish Bookkeeping Act.

3. Sharing of personal data
We will share your personal data with our service providers such as IT service providers (for instance Shopify who is our supplier for our website e-commerce solution and is acting as our processor in accordance with our instructions). We may also need to share your personal information with public authorities and law enforcement agencies if we are legally required to do so.

4. International transfers of personal data
Our ambition is not to transfer your personal data outside of the EU/EEA. If we however need to transfer your personal data to a country that does not have been deemed adequate by the EU Commission, we will ensure that appropriate measures are put in place. This is done by ensuring that standard contractual clauses are put in place with the entity receiving your personal data. The standard contractual clauses can be found here: Standard contractual clauses for international transfers (europa.eu).

5. How we store and protect personal data
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

6. Third parties and other service providers
This website, our other communication channels and materials may include links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

7. Your rights
You have legal rights granted by the General Data Protection Regulation relating to the personal data we process about you. These are briefly explained below, and you can use your rights by contacting us via the channels described below.

- Right to access your personal data
You may request information regarding personal data that we hold about you and we will provide you with a copy of your personal data.

- Right to rectification
You have the right to have any inaccurate personal data about you rectified and to have any incomplete personal data about you completed.

- Right to erasure
You have the right to request that we delete the personal data we process about you. We must comply with this request if we process your personal data, unless e.g. processing is necessary for us to comply with our legal obligations or for the establishment, exercise or defense of legal claims.

- Withdrawal of Consent
Where you have given consent for the processing of your personal data, you may withdraw your consent at any time.

- Right to restriction
You may request us to restrict our processing of your personal data, if:
- you contest the accuracy of your personal data, for the period we need to verify the accuracy,
- the processing is unlawful and you request the restriction of processing rather than erasure of your personal data,
- we do no longer need your personal data for the processing purpose but you require them for the establishment, exercise or defense of legal claims, or
- you object to the processing while we verify whether our legitimate grounds override yours.
- Right to object
You may object to the processing of your personal data, provided that the processing is not based on your consent but on our legitimate interests or those of a third party. If so, we shall stop to process your personal data, unless we can demonstrate compelling legitimate grounds and an overriding interest for the processing or for the establishment, exercise or defense of legal claims.

- Direct Marketing
You have the right to object to our processing of your personal data for direct marketing purposes. If you make such an objection, we will cease to process your personal data for this purpose.

- Right to data portability
You have the right to receive your personal data that you have provided to us, and, where technically feasible, request that we transmit your personal data (that you have provided to us) to another organization. This right only applies if:
- we process your personal data by automated means;
- we process your personal data based on your consent, or because it is necessary for the execution or performance of a contract to which you are a party;
- your personal data are provided to us by you; and
- your right to portability does not adversely affect the rights and the freedoms of other persons.
You have the right to receive your personal data in a structured, commonly used and machine-readable format.

- Right to lodge a complaint
You can lodge a complaint to your local data protection supervisory authority or with any other data protection authority in the EU.

8. Changes to our Privacy Policy
We can update and modify this Privacy Policy at our discretion. Please review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. The Privacy Policy is current as of the date which appears on the top of the document.

9. How to contact us
If you have any questions or want to use your rights, you can contact us using the following contact details:

Company: Kull Leadership AB
Postal address: Rosengatan 9, 413 10 Göteborg, Sweden
Email: info@kulleadership.com

Updated: 2023 March 31